Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1698079069074.pdf (Seychelles)
2022 ANNUAL REPORT 1 | P a g e Chapter1: General Information Table of Contents SUBMISSION OF THE ANNUAL REPORT TO THE MINISTER RESPONSIBLE FOR FINANCE .................................................................................................................................................... 6 DIRECTOR’S FOREWORD..................................................................................................................... 7 ABOUT FIU .............................................................................................................................................. 10 SEYCHELLES TECHNICAL COMPLIANCE RATING – YEAR ENDING 2022 .......................... 16 YEAR IN REVIEW .................................................................................................................................. 18 CHAPTER 2: STRATEGIC PLAN 2019-2022 ...................................................................................... 19 CHAPTER 3: Enhancing Efficiency and Effectiveness of FIU............................................................. 20 Human Resources ..................................................................................................................................... 20 Resignation and staff turnover ................................................................................................................ 22 Information Technology ........................................................................................................................... 23 FINANCIAL MANAGEMENT ............................................................................................................... 23 CHAPTER 4: INSTILLING A CULTURE OF COMPLIANCE ........................................................ 25 Compliance with preventive measures .................................................................................................... 25 Transparency and beneficial ownership of legal persons and arrangements ...................................... 33 CHAPTER 5: MONITORING
 AND ANALYSIS ................................................................................. 37 Continuous improvement in operational, tactical and strategic analysis ............................................ 37 Threshold Reporting ................................................................................................................................. 37 Suspicious Transaction Reports (STRs) ................................................................................................. 41 Outgoing – Domestic & International Disseminations .......................................................................... 44 Freezing of Accounts ................................................................................................................................. 45 Information Exchange .............................................................................................................................. 45 Virtual Assets (“VA”) ............................................................................................................................... 46 CHAPTER 6: COOPERATION, COORDINATION AND COLLABORATION ............................. 48 MoU Signed ............................................................................................................................................... 48 National co-operation and coordination ................................................................................................. 49 International commitments, coordination and collaboration ............................................................... 51 CHAPTER 7: 2022 SUCCESSES, CHALLENGES AND PRIORIOTIES FOR 2023 ....................... 53 Professional Qualifications ....................................................................................................................... 65 2 | P a g e LIST OF ABBREVIATIONS ACCS Anti-Corruption Commission Seychelles ACO AGO AFI Alternate Compliance Officer Attorney General’s Office Alliance for Financial
 Inclusion AML/CFT Anti-Money Laundering and Countering the Financing of Terrorism Act, 2020 AMLA Anti-Money Laundering Act 2006, as amended BDC BO Bureau de Change Beneficial Owner CTTR Cash Transaction Threshold Report CBS CDD CFT Central Bank of Seychelles Customer Due Diligence Countering the Financing of Terrorism COMESA Common Market for Eastern and Southern Africa AUSTRAC Australian Transaction Reports and Analysis Centre CO Compliance Officer DNFBPs Designated Non-Financial Businesses and Professions ECOFEL Egmont Centre of FIU Excellence and Leadership ESA Eastern and Southern Africa 3 | P a g e ESAAMLG Eastern and Southern Africa Anti- Money Laundering Group FATF Financial Action Task Force FI Financial Institutions FIU FCIU FSA Financial Intelligence Unit Financial Crime Investigation Unit Financial Services Authority goAML goAML Web Application ICSP IBC IIC International Corporate Service Provider International Business Company Information & International Co-operation Division LEAs Law Enforcement Agencies LP ME MER ML Legal Professionals Mutual Evaluation Mutual Evaluation Report Money Laundering MOFEPT Ministry of Finance, Economic Planning and Trade NRA MoU MVD M&A NAC RBS REA RFI National Risk Assessment Memorandum of Understanding Motor Vehicle Dealer Monitoring and Analysis National Anti-Money Laundering and Combating the Financing of Terrorism Committee Risk Based Supervision Real Estate Agent Request for Information SMSA Seychelles Maritime Safety Authority 4 | P a g e SLA SPF SRC STR TAC TC TF Seychelles Licensing Authority Seychelles Pension fund Seychelles Revenue Commission Suspicious Transaction Report Technical Anti-Money Laundering and Combating the Financing of Terrorism Committee Technical Compliance Terrorist Financing UNODC United Nations Office on Drugs and Crime VA/VASP Virtual Asset/Virtual Asset Service Provider WTTR Wire Transfer Threshold Report 5 | P a g e SUBMISSION OF THE ANNUAL REPORT TO THE MINISTER RESPONSIBLE FOR FINANCE
 FINANCIAL INTELLIGENCE UNIT P. O.
Box 7021, Ile Perseverance, Seychelles Telephone: (+248) 4383400 Our Ref: Telephone: Date: March, 2023 The Honorable Naadir Hassan Minister of Finance, Economic Planning & Trade Liberty House Victoria, Mahé, Seychelles Dear Minister, In accordance with the provisions of section 24 of the Anti-Money Laundering and Countering the Financing of Terrorism Act, 2020, as amended, I am pleased to present to you the Financial Intelligence Unit’s Annual Report for 2022.
The report outlines the activities of the FIU during the course of 2022 in the pursuit of its statutory remit and demonstrates that the FIU remains an integral part of national efforts to counter money laundering and the financing of terrorism and proliferation of weapons of mass destruction in order to safeguard the stability of our country’s financial system.
Respectfully yours, Richard Rampal Director 6 | P a g e DIRECTOR’S FOREWORD In the year 2022 the Financial Intelligence Unit (“FIU”) has continued to play its role in safeguarding the integrity of the Seychelles’ financial system collaboratively with its key stakeholders and partners.
The FIU has focused on restructuring its workforce, strengthening the Strategic Analysis Unit and enhancing the country’s compliance with the Financial Action Task Force’s (“FATF”) international standards on combating money laundering and the financing of terrorism & proliferation.

These activities were undertaken whilst consistently delivering on all of FIU’s functions as specified in the Anti-Money Laundering and Countering the Financing of Terrorism Act, 2020 (“AML/CFT Act, 2020”).
It therefore gives me great pleasure to present our Annual Report for the year 2022.

The report provides details of activities undertaken for the year under review, highlighting the challenges as well as stipulating the priorities for the year 2023.

In 2022, FIU restructured its workforce.


The restructuration established four (4) divisions being; (1) Monitoring and Analysis, (2) Legal and Compliance, (3) Information Technology and Security and (4) Corporate Affairs; appropriately grouping the various functions of the FIU as specified in the AML/CFT Act 2020.
With the assistance of two (2) consultants the FIU championed the reorganization of the monitoring and analysis division’s operations paving the way for the development of quality operational and strategic analysis reports.

Eventually, FIU aspires to share strategic insights into emerging financial crime trends and patterns to the benefit of reporting entities (“REs”) and other relevant stakeholders hence improving detection of financial crimes by REs and relevant stakeholders.
The Operational and Tactical Analysis Unit (“OPTAC”) received a total of 212 suspicious transaction reports (“STRs”) from banking institutions, non-bank financial institutions, lawyers, bureau de change, fiduciary services, insurance companies, capital markets and casinos.

7 | P a g e Significant efforts have equally been devoted to promoting compliance with the Beneficial Ownership (“BO”) Act and Regulations 2020.
Nine (9) awareness sessions have been delivered with several governmental ministries, domestic companies and the non-profit organization (“NPO”) sector.

A first compliance review of legal persons to the BO Act was conducted during the last quarter of 2022 where it was observed that legal persons’ records reviewed showed sound understanding of their obligations under the Act.
Therefore, it is anticipated that with feedback received from the FIU the legal persons will, in due course be fully compliant with all aspects of the BO Act and Regulations, as amended.

In terms of information technology, FIU has consistently been working to upgrade its analytical system to capture intelligence and streamline business processes.

During the year 2022, crucial preliminary works were completed to customize the Seychelles FIU digital goAML platform.
It is expected that in 2023 the platform will be adapted to enable real time submissions of reports by reporting entities to the FIU as prescribed under the AML/CFT Act, 2020.

Budget wise, FIU ended the year on a good note as it succeeded to fully utilize its funds delivering on key activities outlined in its operational plan.
FIU being a budget dependent entity began the year with an allocated budget of SR 19.2 million and concluded the year with consolidated expenses amounting to a total of SR 18.8 million.

The FIU workforce attended a total of thirty (30) international seminars, workshops or training; both virtual and physical, and seven (7) local ones covering a wide range of subject areas in monitoring and analysis, legal and compliance, IT and support services.
Coincidently, 2022 marked the last year of the FIU 2019-2022 Strategic Plan.

The strategic plan had five (5) strategic pillars with a total of thirty-one (31) key action points to allow the FIU to reach its desired vision.

Overall, FIU managed to implement twenty-two (22) out of the planned activities representing a 70% success rate.

The FIU is proud of this achievement.


The activities that were not completed will be incorporated in the succeeding Strategic Plan; 2023-2025 presently 8 | P a g e being finalized.

The target for the upcoming three (3) years is for the institution to achieve an 85% success rate, and the team is looking forward to this challenge.

Looking ahead, for the year 2023, the FIU will continue to further the advancement of all its divisions.
Additionally, discussions have been initiated to explore the possibility of establishing a suitable public-private partnership framework for improved public-private sector collaboration and information sharing.

Being the Director of such an important organization and reviewing with gratification the progress made by the institution it is impossible to conclude without deep acknowledgement, appreciation and thankfulness to the team that has made yet another year possible.
Being part of the fight against money laundering and countering terrorist financing is exciting and satisfying but also require continuous commitment and dedication.

The effort of each team member is duly recognized.

To the readers, as you peruse through the pages of this annual report, we take the opportunity to reassure you that we, the Seychelles FIU remain committed to our vision, ‘Safeguarding our island state from financial crimes’, until next year.
Richard Rampal Director of the FIU 9 | P a g e ABOUT FIU In June 2006 FIU was first established Seychelles underwent its first Mutual Evaluation in 2008 Operated as a hybrid FIU between 2006-2016 In 2016 Seychelles underwent its first NRA which was completed in 2017 Seychelles underwent its second Mutual Evaluation in 2018 2017 Seychelles FIU was established as an administrative FIU In 2020 the AML/CFT Act 2020 came into force Seychelles started its second NRA in 2022 An administrative FIU Recommendation 29 of the FAFT 40 recommendations requires countries to establish an FIU with the responsibility for acting as a national center for receipt and analysis of suspicious transaction reports and other information relevant to money laundering, associated predicate offences and terrorist financing; and for the dissemination of the results of that analysis.
The Seychelles FIU operates as an administrative FIU where it receives, analyses and disseminate suspicious transaction and other reports.

It does not have investigative or prosecutorial powers and it functions as an interface between the financial sector (and, more generally, entities and professionals subject to reporting obligations) and the law enforcement authorities in charge of financial crime investigations and prosecutions.
10 | P a g e In addition to its core monitoring and analysis function, the FIU is also tasked with supervision, compliance and prevention as well as informational cooperation and data exchange.

Sections 13 and 27 of the AML/CFT Act 2020 sets out comprehensively the functions of the FIU.
The FIU’s functions are to:  receive and request disclosure of financial information on transactions and other information relevant to suspected money laundering and terrorist financing activities;  receive reports on threshold reports and declarations of cross-border movements of cash above the prescribed sum;  collect, analyze and assess the information it receives to substantiate possible existence of money laundering or terrorist financing activities;  where appropriate, make financial intelligence disseminations to appropriate law enforcement and supervisory authorities which are relevant for the investigation or prosecution of money laundering and terrorist financing offences;  monitor compliance by DNFBPs (specified in Part C of the First Schedule (except those at serial number 7 and 8) of the AML/CFT Act 2020) with their obligations under the Act and its regulations;  raise the awareness of the general public and reporting entities about the risks and impact of money laundering and terrorist financing activities related to Seychelles;  compile and maintain statistics and conduct research into the trends and developments in money laundering and the terrorist financing activities  undertake due diligence checks and other inquiries on behalf of government departments or authorities.
11 | P a g e FIU’S VISION, MISSION AND VALUES Vision Safeguarding our island state from financial crimes.
Mission To deter, detect and disrupt domestic and international money laundering, terrorism financing and proliferation financing and contribute to a resilient financial system through ensuring regulatory compliance, effective supervision, the development of high-quality intelligence reports and the enhancement of domestic and international cooperation in line with international best practices and standards.

Values Fairness and Mutual respect in the workplace.
Treating everyone fairly promoting mutual respect and common decency.

Integrity and confidentiality.

Acting with strong ethics is a priority for everyone representing the organization.

Uncompromising in the pursuit of truth.

Being highly committed to unravelling facts, deterring financial crimes is key for our employees.
12 | P a g e 13 | P a g e THE ORGANIZATIONAL STRUCTURE Director Deputy Director Corporate Affairs Legal & Compliance Monitoring & Analysis Corporate Affairs Legal and Compliance Monitoring & Analysis Information Technology and Security Information Technology and Security The Corporate Affairs Division provides operational support for the execution of FIU’s work.
The primary functions of this Division include office management, financial and administrative management, human resources, staff learning and development, security services and information communication technology.

The Legal and Compliance Division is made up of three (3) units.

The Legal Unit is responsible to protect and advance the interests of the FIU by providing legal advice, support and analysis to other divisions.
The division is The Monitoring and Analysis Division is made up of three (3) units.

Operational and Tactical Analysis (“OPTAC”) Unit, Strategic Analysis Unit and Information Exchange Unit & Registry Unit.

The Information Technology and Security Unit is responsible for FIU’s information and technology needs, cyber security, as well as maintaining the GoAML platform and the Beneficial Ownership platform.
“OPTAC” Unit is responsible for the analysis of STRs which 14 | P a g e also responsible for enforcement actions.

The Policy and External Relations Unit is tasked with providing policy advice, research, drafting of policies and reports related to AML/CFT matters and FIU functions.

It also manages the relationships with domestic stakeholders, regional bodies and international partners on AML/CFT matters.
The Supervision Unit is responsible to monitor and carry out inspections of reporting entities under the supervision of the FIU both through on-site and off-site initiatives.

The inspections assess compliance with the AML/ CFT Act and BO Act and inform on outreach and awareness strategies.

As a result, the unit is able to provide guidance and feedback to reporting entities.
include producing financial analysis reports and dissemination of Intelligence Reports to domestic LEAs involved in the fight against ML and TF.

Strategic Analysis Unit assumes a more strategic view and carries out trend analysis of economic crimes and threshold reporting to assist key decision making.

Information & International Co- operation Unit is responsible to handle all domestic and international exchange of information as well as to create a centralized database for the keeping of FIU statistics.
It is also currently responsible for maintaining and providing access to the BO database.

15 | P a g e SEYCHELLES TECHNICAL COMPLIANCE RATING – YEAR ENDING 2022 The Financial Action Task Force (FATF) is an intergovernmental standard setting organization.

The 40 recommendations created by the FATF provide counter-measures against money laundering, terrorist and proliferation financing, and other threats to the global financial system.

They also set out principles and minimum standards for action.
Seychelles is a member of the ESAAMLG, a FATF-Styled Regional body whose objective is to assist countries in the region to achieve the effective implementation of and compliance with the 40 Recommendations, Seychelles was last assessed against the 40 Recommendations in 2018 where it was rated Compliant (C) on 10 Recommendations, Largely Compliant (LC) on 10 Recommendations, Partially Compliant (PC) on 16 Recommendations and Non-Compliant (NC) on 4 Recommendations.
Since then, Seychelles has taken measures aimed at addressing the technical compliance deficiencies identified and the table below reflect the progress made by Seychelles.

It is expected that technical compliance ratings for Recommendations 5, 19, 25, 28 and 34 improve by next year following the re-rating request submitted to ESAAMLG in September 2022.
16 | P a g e Recommendations and Corresponding Ratings C 15 LC LC PC PC 16 17 18 19 PC 20 PC NC 21 22 C 23 LC 24 C 25 LC 26 C 27 C 28 NC LC LC C PC C C LC LC LC PC LC LC PC 29 30 31 32 33 34 35 36 37 38 39 40 LC C C LC PC PC LC C LC LC LC LC 17 | P a g e YEAR IN REVIEW 212 STRs received 334 other disclosures Value: 1 Strategic Financial Intelligence Report produced 2193 Threshold reports processed 64 Domestic disseminations made 18 international disseminations 9 BO Awareness Sessions conducted 10 AML/CFT Awareness Sessions conducted 141 DNFBPs registered 2 new MoUs signed 3 staff recruited 37 seminars, workshops, trainings facilitated 18 | P a g e CHAPTER 2: STRATEGIC PLAN 2019-2022 FIU completes its 2019-2022 Strategic Plan Strategic planning is a process in which an organization's leaders define their vision for the future and identify their organization's goals and objectives.
The process includes establishing the sequence in which those goals should be realized so that the organization can reach its stated vision.

The 2019-2022 Strategic Plan of FIU aside from providing a strategic overview of the institution considered the Financial Action Task Force’s (“FATF”) approach for assessing technical compliance with the FAFT Recommendations, and for assessing whether and how the AML/CFT system is effective.
This ensured that the strategies adopted by the institution aligns with national strategy leading to conformity to the FAFT Recommendations and ultimately an effective AML/CFT system.

The strategic plan had five (5) strategic pillars with a total of thirty-one (31) key action points and measures to allow the FIU to reach its desired vision.

The priority areas were formulated from the analysis of the Seychelles AML/CFT framework established through the NRA and MER.
Overall, the FIU managed to implement 22 out of the 31 planned activities in the strategic plan representing a 70% success rate; refer to Annexure 1 Strategic Plan review 2019-2022 for details of activities that have been implemented, as well as those that were not able to be implemented during the three (3) years.

The activities that were not completed at the end of 2022 will be incorporated in the FIU Strategic Plan 2023-2025.
19 | P a g e CHAPTER 3: Enhancing Efficiency and Effectiveness of FIU Human Resources Maintaining our commitment to support a high performing workforce Employees are fundamental to the success of organizations as they offer valuable knowledge, skills and expertise.

FIU being an organization that relies heavily on specific technical expertise is committed to recruiting the right people and dedicated to supporting its workforce in becoming high performers.
FIU Staff Complement Figure 1: FIU Staff Complement THE SEYCHELLES FIU Directorate Corporate affairs Information Technology Legal & Compliance Analysis & Monitoring 7% 34% 27% 9% 23% Table 1: The Divisions/Units and Number of Employees Division Units Director Number of Employee 1 20 | P a g e Directorate Deputy Secretary Corporate Affairs Information Technology Legal & Compliance Analysis & Monitoring Total Head Operations Administration Finance Human Resources Security Legal Policy & External Relations Supervision and Compliance Operational & Tactical Analysis Strategic Analysis Information Exchange OSINT & VASP Figure 2: Percentage of Female and Male employees 1 1 1 6 1 1 3 4 1 2 7 7 2 5 1 44 21 | P a g e Resignation and staff turnover Figure 3: Resignation and staff turnover 50 45 40 35 30 25 20 15 10 5 0 FIU Annual Employee Resignation & Turnover Rate 44 45 44 41 14 3 6.82% 2019 5 2020 11.11% 31.80% 3 7.30% 2021 2022 Headcount Resignation Turnover % Staff Promotion Table 2: Staff promotion 2019-2022 2019 2020 2021 2022 Number of Promotions 0 1 4 4 Division/Unit Operational & Tactical Operational & Tactical Unit, Legal & Compliance Division, Information Exchange and Strategic Analysis Unit Operational and Tactical Unit Information Exchange Unit Corporate Affairs Division and Legal & Compliance Division Staff Training and Capacity Development 22 | P a g e The dynamic nature of the financial sector calls for the upskilling of staff as the FIU needs to remain aware and understand the various vehicles that criminals are likely to use or ways of how the financial system may be manipulated for illicit purposes.
Therefore, staff development remains paramount.

Staff training on AML/CFT and BO measures, frameworks and systems were conducted throughout the year 2022.

Information Technology Paving the way for a modernized FIU In response to the global pandemic in early 2020 and throughout the past year, FIU has focused on ensuring that it has the appropriate tools, technology and systems in place to continue to securely deliver on its critical intelligence and compliance mandates.
FIU has also been working to upgrade it analytical system to capture intelligence and streamline business processes and to keep pace with the rapid technological innovation that is taking place in the financial sector and all sectors around the world.
FINANCIAL MANAGEMENT In accordance with section 21 of the AML/CFT, Act 2020 the funds of the FIU consist of monies appropriated by the National Assembly for the use of the FIU, any Government grants including sums from the Asset Recovery Fund and the designated account, made to it and any donations received with the prior written approval of the Minister.
For the year 2022, the FIU was appropriated a total of SR 19.2 million by the National Assembly, within which SR 10.97 million was allocated to programme 1; Governance, Management and Administration and SR 8.23 million to programme 2; the programme that supports the FIU in fulfilling its core technical functions as prescribed under Part V of the AML/CFT Act 2020.
Table 26: 2022 Budget 2022 Budget ‘000 23 | P a g e Budget for the year 2022 Programme 1 Programme 2 SR 19,199 SR 10,973 SR 8,226 Table 27: 2022 Actual Expenditure 2022 Actual Expenditure Actual expense for the year 2022 Programme 1 Programme 2 ‘000 SR 18,771 SR 10,967 SR 7,804 Figure 7: Allocated Budget 2020-2022 Allocated Budget 2020-2022 ('000) D E T A C O L L A U I F T E G D U B 2022 2021 2020 0 5,000 10,000 15,000 20,000 25,000 30,000 The FIU continuously keeps proper accounts and other relevant record of accounts, and prepare in each financial year a statement in such form and manner approved by the Auditor General.
The accounts are audited in accordance with Article 158 of the constitution.

24 | P a g e CHAPTER 4: INSTILLING A CULTURE OF COMPLIANCE Compliance with preventive measures An important consideration underlying the FATF Recommendations is the degree of money laundering or terrorist financing risk for particular types of institutions, businesses, or professions, or for particular customers, products, transactions, or countries.
Therefore, the FIU in its capacity as the supervisory authority for Designated Non-Financial Businesses and Professions (“DNFBPs”) recognizes its duty to ensure compliance through conformity with the respective laws and regulations but does so by ensuring that it takes due consideration to identify the degree of risk of its obliged entities.
Further, FIU ensures compliance with preventive measures including registration of reporting entities, monitoring appointment of compliance officers, outreach and awareness programs, inspections etc.

of its obliged entities which are detailed below.


AML/CFT Framework: FIU Supervised Sectors In accordance with the AML/CFT Act 2020, the FIU is responsible to supervise the following reporting entities (“REs”) being lawyers, accountants and auditors, real estate agents, high value dealers, dealers in precious metals and stones and the Seychelles Pension Fund which are categorised as DNFBPs.
Table 3: FIU Supervised Sectors DNFBPs Accountant and Auditors Lawyers and Notaries Real Estate Agents High Value Dealers – Motor Vehicle Dealers Dealers in Precious metals and stones Number 68 30 10 21 11 25 | P a g e Pension Fund Total numbers of DNFBs 1 141 Registration of reporting entities with the FIU In accordance with the requirements of section 31 of the AML/CFT Act and Regulation 7 of the AML/CFT Regulations, all reporting entities specified under the First Schedule of the AML/CFT Act have an obligation to register with the FIU.
As such, for the purpose of fulfilling this obligation, all specified reporting entities are required to register on the goAML platform a reporting system that has been developed by UNODC for the use of FIUs.

Refer to table 4x below for the breakdown of percentage registration on the platform as at December 31st 2022, per respective sector under the FIU’s regulatory purview.

Table 4: Breakdown of percentage registration - FIU Reporting Sectors Total No.

of Reporting Entities Total No.


of Registered Entities % Registration Accountant/Auditors Dealers in Precious Metals & Stones Lawyers & Notaries Motor Vehicle Dealers Pension Fund Real Estate Agents 68 11 30 21 1 10 61 11 29 20 1 10 Total 141 132 Table 5: Breakdown of percentage registration - CBS 90% 100% 97% 95% 100% 100% 94% 26 | P a g e Reporting Sectors Total No.

of Reporting Entities Total No.


of Registered Entities % Registration Banking Institutions 8 Bureau De Change – Class A 13 Bureau De Change – Class B 8 Credit Union 1 Non-Bank Credit Institutions 2 Payment Service Provider Total 1 33 8 12 6 1 2 1 30 100% 92% 75% 100% 100% 100% 91% Table 6: Breakdown of percentage registration: FSA Reporting Sectors Total No.

of Reporting Entities Total No.


of Registered Entities % Registration International Corporate Service Providers Funds Administrator Gambling Insurance Securities Total 104 7 11 41 115 278 97 5 9 28 78 217 93% 71% 82% 68% 68% 78% Table 7: The table below reflects the registration of REs under the respective Supervisory Authority.

: Supervisors Total No.

of Reporting Entities Total No.
of Registered Entities % Completed FIU 141 132 94% 27 | P a g e CBS FSA Total 33 278 452 30 217 379 91% 78% 84% Non-compliance to the obligation to register with the FIU being contrary to the provisions of the AML/CFT Act, the FIU has continued to monitor compliance with this obligation in order to communicate to the respective supervisory authorities for appropriate actions, Appointment of CO and ACO by Reporting Entities In line with Section 34 (1) of the AML/CFT Act, all REs shall appoint a Compliance Officer (“CO”) and an Alternate Compliance Officer (“ACO”) respectively.
However, as per Regulations 8 (2) of the AML/CFT Regulations, an RE with less than five (5) staff members is exempted from appointing an ACO with the necessary approval of the Supervisory Authority.

As of December 31st, 2022, the FIU has approved a total number of 135 COs, 27 ACOs and approved the exemption of 102 ACOs with respect to the entities under its supervision, as per the table 9x below.

Table 8: Appointment of CO and ACO by REs SECTOR Total No.

of RE No.

of Approved CO No.

of Approved ACO No.


of Approved Exemptions for ACO Motor Vehicle Dealers 21 Real Estate Agents Accountant/Auditors 10 68 20 10 65 9 0 11 11 9 51 28 | P a g e Lawyers & Notaries Pension Fund Dealers in Precious Metal & Stones 30 1 11 29 0 11 3 1 3 23 0 8 Total 141 135 27 102 Risk Assessment of Reporting Entities: Mechanism introduced to identify risks.
In line with the Risk Based Assessment (“RBA”) framework in place, the FIU has implemented mechanisms to assess the money laundering and terrorist financing (“ML/TF”) risks for the reporting entities under its purview.

The said framework is flexible, allowing for the timely and effective response to significant events such as changes in management or in business activities.
The FIU uses different types of supervisory tools to assess compliance of the REs which include but not limited to statistical questionnaire, desk-based monitoring mechanism and on-site examination audit tools to assess the adequacy of the REs’ systems and processes.

The result obtained from the RBA is further used to determine the frequency, intensity and scope of the AML/CFT supervision to be performed by the FIU.
Further, during the year 2022 focus groups were held with the supervised REs, where FIU had the opportunity to have an insight on their perceived risks, concerns, challenges etc.

Based on the RBA framework currently in place and information gathered, the FIU conducted both on-site and off-site supervision on selected REs as outlined below.
On-site Supervision Pursuant to section 57 (1) (b) of the AML/CFT Act, the FIU is empowered to assess the premises at which an RE under its supervision carries out its business to conduct an examination.

As such, five (5) onsite examinations were conducted in the year 2022 whereby two (2) reporting sectors were targeted namely the Real Estate Agents and the Motor Vehicle Dealers.

The scope of the onsite examinations was specific to the below obligations.
 Obligation to apply customer due diligence; 29 | P a g e  Obligation to submit Cash Transaction Threshold Report and Suspicious Transactions Report to the FIU; and  Monitoring of transactions and activities.

Table 9: On-site supervision Sector No.


of examinations Real Estate Agents Motor Vehicle Dealers 2 3 The main findings were as follows:  Lack of / inadequate customer due diligence measures  Lack of / inadequate monitoring of transactions  Non and late submission of Cash Threshold Transaction Reports Off-site Supervision: Revision of the AML/CFT Compliance Policies In line with section 33 (1) of the AML/CFT Act, an RE is obligated to establish and maintain internal control systems and procedures.
As such, all high-risk and medium-risk REs were directed to submit their respective AML/CFT compliance manual for review.

A total number of forty-seven (47) REs were requested to submit their manuals and out of the 47, twenty-eight (28) manuals were received and reviewed respectively.

Refer to the table 10 below.


With respect to the guide provided on how to write an AML/CFT compliance manual, the manual should cover all obligations of a reporting entity and should also clearly outline the procedures/processes in place with regards to same.

From the review it has been noted that most deficiencies were in respect to omitting to outline certain obligations such as; 1.

Registration with FIU (36% non-compliant) 30 | P a g e 2.

3.
3.

Obligation to cease transaction (39% non-compliant) Monitoring of transaction (46% non-compliant) Table 10: Revision of the AML/CFT Compliance Policies Sector Lawyers Motor Vehicle Dealers Real Estate Agent Pension Fund Total No.

of manuals requested No.
of manual received and reviewed 31 10 5 1 47 20 4 3 1 28 High-risk and medium risk REs directed to submit their respective AML/CFT manuals Sector as per their risk rating 35 30 25 20 15 10 5 0 LEGAL PRACTIONNERS MOTOR VEHICLE DEALERS REAL ESTATE AGENTS RATING [HIGH] RATING [MEDIUM] 31 | P a g e Awareness One of FIU’s primary obligation as a supervisory authority, consistent with the standard for guidance and feedback established by the FATF in Recommendation 34, is to provide awareness to its supervised entities on their AML/CFT obligations in such a way as to help them understand the mandatory nature of these obligations and help them to build and enhance their compliance systems To this end, outreach to its supervised entities remain at the forefront of FIU’s AML/CFT efforts and it continued with its awareness initiatives in this reporting period.
In the year 2022, the FIU provided several awareness and guidance in line with the obligations of a reporting entity stipulated in the AML/CFT Act.

The awareness and guidance sessions were conducted both physically and via telephone.

The sessions covered different AML/CFT obligations including appointment of compliance and alternate compliance officer, AML/CFT compliance manual, suspicious transaction report and registration with the FIU.
Table 11: Awareness sessions Sector Lawyers Real Estate Agents Accountant/Auditor Motor Vehicle Dealers No.

of awareness 4 2 1 3 Apart from the formal sessions, the FIU engages regularly with its supervised entities by phone and email in order to respond and provide appropriate guidance on a broad spectrum of queries relating to their obligations under the AML/CFT Act.
FIU’s outreach activities in 2022 also included engaging in focus group discussions with the different supervised sectors within the framework of the National Risk Assessment.

The sessions allowed the reporting entities to ask questions and express concerns.
32 | P a g e The outreach and awareness initiatives have also provided valuable feedback from the supervised entities to the FIU which will be considered as it continues the implementation of its risk-based supervision programme, At the end of 2022, the effectiveness of FIU’s outreach and awareness programme was analyzed and a strategy has been devised to enhance this programme in 2023.
Transparency and beneficial ownership of legal persons and arrangements One of the seven (7) distinct areas of the FAFT forty (40) recommendations is transparency and beneficial ownership of legal persons and arrangements, an area which the FIU has placed tremendous efforts in ensuring conformity with the standard.

The BO Act was enacted in 2020, and the BO Database was formally launched in July 2021.
Population of the BO database was undertaken in two phases – with the deadline of December 27th, 2021 for the non-domestic sector and January 31st, 2022 for the domestic sector.

The data presented in table 13x below is as of August 31st 2022.

An elementary assessment of the BO database was conducted to understand how users are populating the data and to make sense of what the data is showing.
Table 12: Population of the BO Database by non-domestic entities as at December 31st 2022 IBCs 59115 Total Entities in standing) Active (those good Total Population 54541 Total Compliance Non- 457 TRUSTS FOUNDATIONS CSLs 572 294 250 322 287 7 90 73 17 Percentage Population 92.3% 43.7% 97.6% 81.1% 33 | P a g e Percentage Non- Compliance 7.7 % 56.3% 2.4% 18.9% Population of Database by Non-Domestic Entities as at December 31st 2022 Table 13: Population of the BO database by domestic legal entities as at December 31st 2022.
Companies Associations Cumulative Registered Entities 8973 Total Active Entities Total Population 7781 2270 Percentage Population 29.2% Total Non-Compliance Percentage Compliance Non- 5511 70.80% 790 790 80 10.10% 710 89.90% Population of Database by Domestic Legal Entities as at 31st December 2022 BO Awareness Sessions All domestic entities under FIU’s supervision which includes domestic incorporated/registered companies, partnerships under the civil code and associations had until the 31st January 2022 to comply with the provisions of the Beneficial Ownership Act 2020.
A review of the statistics of domestic legal entities that had populated the database revealed that compliance with the obligation to populate the Seychelles BO database remains low on the 34 | P a g e domestic side.
Therefore, in the reporting period, from a risk-based perspective, it was decided to re-prioritize and focus time and resources in providing guidance to the domestic sector in order to secure improved compliance with the Beneficial Ownership Act, 2020 where compliance by the domestic sector lags behind.

This was done through various physical and virtual interactions with different sectors.

In the year 2022, FIU conducted nine (9) awareness sessions.
(Refer to Annexure 3) The FIU continues to monitor the compliance data and in collaboration with other stakeholders such as the Registrar of Companies/Associations and our technical assistance partners is revamping its BO Awareness strategy to ensure we maximize the impact of our efforts.
BO Compliance Review In October-November 2022, the FIU as the Competent Authority, under the BO Act, 2020, for companies incorporated or registered under the Companies Ordinance, 1972 conducted a series of onsite inspections to test the level of compliance of these legal persons to the following obligations: 1.

Maintaining of the BO register at the principal place of business of the resident agent; and 2.
Maintaining of duly completed BO declaration forms at the principal place of business of the resident agent; Out of 7781 companies incorporated or registered under the Companies Act, a sample of fifty (50) companies were selected for the purpose of compliance testing, which were conducted through the support of their respective Resident Agents.

Sampling was based on the following; i.

Companies compliant with certain statutory filing obligations under the Companies Ordinance, 1972; ii.
Companies having populated the BO Database; iii.

Companies having submitted their annual return to the company registrar; iv.

Companies holding a bank account with a domestic commercial bank; v. Companies registered with the Seychelles Revenue Commission; vi.

The top 50 companies having the highest annual turnover, based on the Seychelles Revenue Commission database; and vii.

Companies whose resident agent is a corporate body.
35 | P a g e In order to validate the accuracy of information provided on the Register of Beneficial Owner from the sample of 50 companies, the FIU utilized a multi-pronged verification approach which involved the verification of beneficial ownership information/ evidence; a) obtained from the company registry; b) obtained from the central BO database; c) kept on the register of beneficial ownership, at the office of the Resident Agent; d) held by the legal person; e) maintained by the banks on the relevant legal person; and f) kept by the auditors of these companies Following the onsite inspection companies and their respective Resident Agent were notified by letter, of the findings of the inspections.
In instances where there were issues with the maintenance of the above listed documents, companies and its respective Resident Agent were instructed to rectify same within twenty-one (21) days of receipt of the letter.

Below are the main findings of which required remedial action by the legal persons; 1.

Incomplete BO register (missing information such as date, name of BO, address of BO, nationality of BO); (Total number of BO register with discrepancies -13) 2.
BO declaration forms not being maintained;( Total number of beneficial ownership declarations being maintained at the principal place of business of the Resident Agent -41) and 3.

BO declaration forms signed by third parties instead of the BO themselves.
(Total number of BO declarations with discrepancies -12) 36 | P a g e CHAPTER 5: MONITORING AND ANALYSIS Continuous improvement in operational, tactical and strategic analysis To ensure continuous improvement in monitoring and analysis, certain structural elements are required to be in place that cuts across several FAFT recommendations including inter alia technologies, wire transfers, reporting of suspicious transactions, tipping off and confidentiality and international cooperation.
During the year, 2022 FIU has worked towards maintaining the necessitated standards with key achievements in Virtual Assets (“VA”) and Virtual Assets Service Providers (“VASPs”).

Threshold Reporting The Third Schedule of the AML/CFT Act stipulate the reporting threshold for cash transactions, wire transfers, gambling sector and Bureau de Change.

This is produced table 15x below.

Table 14: Reporting Threshold Reporting threshold for cash transactions.
Every reporting entity shall report each Reporting threshold applicable to wire transfers.

Reporting threshold applicable to gambling sector.

transaction that is carried out by or through it involving cash transactions of SCR 50,000 or more or the equivalent money in the currency of other countries.

Every reporting entity shall report each wire transfer that is executed of SCR50,000 or more or the equivalent money in the currency of other countries.
All licenses within the gambling sector shall report all transactions of its customers involving SCR 20,000 or more.

Reporting threshold applicable to Bureau de Change.

Every Bureau de Change shall report all transactions of its customers involving SCR 37 | P a g e 5,000 or more or the equivalent money in the currency of other countries.
Pursuant to section 5 of the AML/CFT Act, all reporting entities have the obligation to submit a report to the FIU, for transactions that meet or exceed the prescribed threshold.

The FIU received a total of 2193 threshold reports in 2022.

This represented a near 15% increase in number of submitted reports compared to 2021.

The threshold data is used in relevant strategic analysis works and enhances the operational analysis conducted by the FIU.
Bank and Non-bank financial institutions The bank and non-bank financial institutions submit two (2) report types to the FIU, that is the Cash Transaction Threshold Report (“CTTR”) and the Wire Transfer Threshold Report (“WTTR”).

For 2022, the FIU received 476 CTTRs and 372 WTTRs Table 15: Cash Transaction Threshold Report (“CTTR”) and the Wire Transfer Threshold Report (“WTTR”).

CTTR WTTR No.

of transactions 75,580 79,074 No.

of reports 343 372 No.

of transactions 90,655 127,055 No.


of reports 2021 2022 473 476 Bureau De Change The FIU received 841 threshold reports from the Class A Bureau de Change (“BDC”) which is a 15% increase compared to the 2021 figures.

It is to be noted that FIU was receiving reports from 12 class A BDCs in 2021, whereas in 2022 with a new entrant, 13 Class A BDCs were reporting.

Table 16: Bureau De Change threshold reporting No.

of reports No.
of reports No.

of transactions 38 | P a g e BDC Class A BDC Class B 2021 2022 2021 2022 732 841 240 300 130,162 163,482 5,959 11,727 Motor Vehicle Dealers For the reporting year, 12 cash threshold reports were received from 3 motor vehicle dealers.

Table 17: Motor Vehicle Dealers threshold reporting No.

of reports No.

of transactions 2021 2022 9 12 5 10 Precious Metals and stones The precious metal and stone sector started submitting cash threshold reports from the second half of 2021.
For 2022, the FIU received 27 reports.

Table 18: Precious metals and stones threshold reporting No.

of reports No.

of transactions 6 27 19 54 2021 2022 Gambling 39 | P a g e The gambling sector submitted 165 reports in 2022, representing a 53% increase.

However, it is to be noted that for the year under review, operations of the entities under this sector were not restricted compared to the previous two (2) years where activities were restricted due to the pandemic.
Table 19: Gambling Threshold reporting No.

of reports No.

of transactions 2021 2022 108 165 3,274 7,496 Strategic Analysis The FIU receives intelligence through its reporting regime and subsequently through its analysis can formulate reports of trends and patterns as it relates to money laundering and terrorist financing.
The FIU obtained the assistance of a technical expert, who has been assisting in regards to the development and implementation of a capacity building programme to mentor the staff within FIU.

The aim is to acquire the necessary analytical capacity and ultimately produce quality reports of money laundering and terrorist financing typologies and trends.
In accordance with its function under section 28 (5) (b) of AML/CFT Act, which relates to FIU’s analysis function, the FIU conducted an elementary assessment of the data being captured on the BO database.

The aim of the assessment was to gain a basic insight in respect to gaps and/or discrepancies in the information being populated onto the BO database.

The assessment analysed the BO information in terms of its adequacy and relevance.
It also entailed a comparison of the BO information against other data sets maintained by the FIU.

The findings allowed the FIU and the relevant partners to better assess the benefits of having a central BO database.

The findings were shared with the supervisory authorities and the National AML/CFT committee.
40 | P a g e Suspicious Transaction Reports (STRs) The Seychelles FIU is the national agency responsible for receiving, requesting, analyzing and disseminating financial intelligence as it relates to money laundering and the financing of terrorism.

Suspicious Transaction Reports (“STRs”) and other disclosures are submitted to the FIU, either electronically or through physical means.

For the year 2022, the FIU received a total of 212 STRs from the reporting entities.
Cases are prioritized on a risk-based approach.

This allows the FIU to efficiently utilize its resources and at the same time deliver quality intelligence.

Cases that are designated as high risk are allocated for further analysis, whereas cases which are rated as being low risk are kept in a centralized database and serve as a source of intelligence for future cases, request for information or strategic analysis.
Table 20: STRs For review year, the FIU has seen a decrease from 275 STRs which were submitted in 2021 to 212 STRs in 2022.

STRs STRs Received Other disclosures received 2020 263 32 2021 275 361 2022 212 334 A total of 334 voluntary disclosures were received from international and domestic private entities and other government agencies.

83% of the disclosures received were international disclosures received in relation to virtual assets.

Number of STRs received per sector for the year 2022.
Figure 4: STR submission per sector 41 | P a g e STR SUBMISSION PER SECTOR Lawyers Gambling Capital Market Insurance Bureau De Change Fiduciary Bank &Non Bank financial institutions Bank &Non Bank financial institutions Fiduciary Bureau De Change Gambling Capital Market Insurance Lawyers Similar to 2021 the main reporting sectors remains to be the bank and non-bank financial institutions and the fiduciary sector.
The FIU remains engaged with other supervisory and competent authorities to drive awareness and sensitization to improve the effectiveness of their monitoring framework as gatekeepers leading to improved reporting from other sectors.
Table 21: STR submission per sector Sectors Banking Institution and non-bank financial institutions Fiduciary BDCs Capital Markets Casino Lawyers Insurance Total Reason for suspicion Total 145 36 17 9 3 1 1 212 42 | P a g e Reporting entities are obligated to submit an STR to the FIU if they have reason to believe that a transaction or activity is related to a money laundering or terrorist financing or even any other criminal offences.
It is therefore imperative that REs know their customers and ensure that they have adequate measures in place to detect such suspicious transactions or activities.

For 2022, 26% of STRs received were submitted on the basis of unusual cash deposits.

These reports involved suspicions on the source of funds of multiple cash deposits or one-off large transactions to an account.

Money Laundering has been observed as the second most common reason for reporting.
STRs in this category have been seen to involve multiple offences, hence why the REs term it as money laundering.

In the adverse media category, the majority of the STRs were submitted by ICSPs and were in relation to an adverse information found online, involving either the director, shareholder, beneficial owner of an entity or the entity itself.

As for the fraud cases, these included mostly internet frauds and financial scams.
Table 22: STRs: Reason for reporting Reason for reporting Total STRs Unusual cash deposit Money Laundering Unusual account activity Adverse Media Fraud Corruption Failure to adhere to KYC requirements Tax Evasion Sanctioned Entity/Individual Unusual exchange of cash Drug trafficking 55 37 26 20 17 14 10 9 5 6 6 43 | P a g e Avoiding reporting threshold Known to LEA Regulatory breach Total 3 2 2 212 Outgoing – Domestic & International Disseminations Following the analysis of the intelligence received through the various report forms, the FIU disseminates its findings to the various stakeholders.
Pursuant to section 27 (1) (c) of the AML/CFT Act, the FIU disseminated 82 intelligence reports.

This included 18 disseminations made to international counterparts and 64 to domestic counterparts.

24 cases where the analysis was completed since 2022 are yet to be disseminated.
Table 23: Outgoing Domestic & International Disseminations Domestic disseminations International disseminations 2021 137 21 2022 64 18 The disseminations were made to the following authorities:  Local law enforcement agencies  Supervisory authorities  Government agencies  Other FIUs Figure 5: Dissemination of cases 44 | P a g e Freezing of Accounts The FIU exercised its powers under section 27 (d) and (e) on 19 accounts in 2022.
The total value of the assets held by the related bank accounts can be seen in table 25x below: Table 24: Freezing of accounts: Total value of the assets held by the related bank accounts Number Bank Accounts 7 2 1 9 Currency EUR GBP SCR USD Total Value of Funds 126,003.47 499.25 50,809.34 1,642,201.94 Information Exchange As part of its function, the FIU exchanges information with its partners domestically and internationally.

Information is shared either spontaneously or upon request.
The FIU strives to provide quality information in a timely manner in order to assist in investigations for the prevention of ML/ TF.

In 2022, the FIU received 200 domestic requests and 466 request for customer due diligence.

The FIU conducted sessions with the relevant partners in the last quarter of 2022 where it was conveyed how the FIU can provide assistance through request for information received from LEAs 45 | P a g e and other competent authorities.
Further emphasis was put on the quality of information that needs to be provided in a request for information in order to enable the FIU to better assist.

The FIU received 288 requests for information from international counterparts in 2022.

These included requests from Egmont group members1, FIUs which are not Egmont members and other international bodies.

In order to fulfill its mandate of analysis and dissemination the FIU also makes request for information to both domestic and international partners.
For the review year the FIU made 5388 local requests and 42 international requests for information.
Table 25: Information Exchange Domestic request received International requests received Due diligence checks and enquiries request received International dissemination received Domestic Request sent International requests sent Virtual Assets (“VA”) 2021 181 130 42 4174 10 2022 200 288 446 18 5388 42 The FIU was part of the national risk assessment that was carried out in 2022 on Virtual Asset /Virtual Asset Service Provider (“VA/VASP”).
The NRA was conducted with the aim to assess the money laundering and terrorist financing risk associated with having a virtual asset or virtual asset service provider sector in Seychelles.
As per FATF Recommendation 15 countries should: a) identify and assess the money laundering and terrorist financing risks emerging from virtual asset activities and the activities or operations of VASPs; 1 The Egmont Group is a united body of 166 Financial Intelligence Units (FIUs): FIUs are uniquely positioned to support national and international efforts to counter-terrorist financing.
FIUs are also trusted gateways for sharing financial information domestically and internationally per global anti-money laundering and counter-financing of terrorism (AML/CFT) standards.

The Egmont Group provides FIUs with a platform to securely exchange expertise and financial intelligence to combat money laundering, terrorist financing (ML/TF), and associated predicate offences.
46 | P a g e b) based on their understanding of their risks, apply a risk-based approach to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the risks identified; and c) require VASPs to take appropriate steps to identify, assess, manage and mitigate their money laundering and terrorist financing risks, as required.

The result of the NRA rated the VA/VASP as being high risk.
This result will be used to formulate the necessary policies and strategies regarding VA/VASP.

The FIU recorded a total of 276 voluntary disclosures which directly involved a virtual asset.
Figure 6: VA: Top 3 reasons for reporting Top 3 reasons for reporting Dark net market suspicious activity Money Laundering Sanctioned individual/entity 47 | P a g e CHAPTER 6: COOPERATION, COORDINATION AND COLLABORATION Building relationships to achieve our shared vision The FIU has participated actively in national and international cooperation, coordination and collaboration initiatives with the aim of building strategic relationships.
Such relationships are key in creating the necessary network to achieve the shared vision of protecting the global financial system against financial crimes.
MoU Signed In 2022 FIU signed three (3) Memorandum of Understanding (“MoU”), two (2) international MoU with the Participants of the International Anti-Corruption Coordination Centre Associate (IACCC) and the Financial Intelligence Unit of the Republic of Mozambique; and one (1) domestic MoU with the Department of Environment, within the Ministry of Agriculture, Climate Change and Environment.
MoU with participants of the International Anti-Corruption Coordination Centre Associate (IACCC) Pursuant to the international MoU, the FIU is now an associate member of the IACCC.

This status will facilitate the ability of the FIU to securely communicate and exchange intelligence to assist with the development of grand corruption cases and in so doing, support the work of our domestic and international partners.
MoU with Financial Intelligence Unit of the Republic of Mozambique 48 | P a g e The MoU with the Republic of Mozambique FIU establishes a basis for the development of an effective collaboration mechanism between the Authorities in the exchange of information and to improve the coordination and efficiency of cooperation efforts between the Authorities.

MoU with the Seychelles Ministry of Agriculture, Climate Change and Environment.
The local MoU with the Department of Environment came in response to the global call to action to increase our vigilance and response to the financial threats posed by the illegal wildlife trade.

Broadly speaking, the MOU allows for cooperation and collaboration between the FIU and the Department in order to discharge their respective statutory mandates as well as international obligations.
National co-operation and coordination FAFT Recommendation 2 requires counties to designate an authority or have a co-ordination or other mechanism that is responsible for national AML/CFT policies.
Mechanisms should be in place to enable policy makers, the FIU, law enforcement authorities, supervisors and other competent authorities to co-operate, and where appropriate, co-ordinate and exchange information domestically with each other concerning the development and implementation of AML/CFT policies and activities.

Such mechanisms should apply at both policymaking and operational levels.
This has led Seychelles to establish the National Anti-Money Laundering and Countering the Financing of Terrorism Committee (“NAC”), supported by the Technical Anti-Money Laundering and Countering the Financing of Terrorism Committee (“TAC”), where FIU is an active participant on both platforms.
National Anti-Money Laundering and Countering the Financing of Terrorism Committee (“NAC”) “NAC” as established in the AML/CFT Act, 2020 chaired by the Secretary of State for Finance constituted for seven (7) sittings in the year 2022.
They discussed subjects including but not limited to;  Seychelles technical compliance status to FAFT recommendations  The National Risk Assessment (“NRA”) 49 | P a g e  The AML/CFT Appeals Board  Asset Management Unit As prescribed by the AML/CFT Act, 2020 other members of the committee are; a) The Governor of Central Bank of Seychelles b) The Attorney-General c) The Commissioner of the Seychelles Police Force; d) The Registrar General; e) The Commissioner General of the Seychelles Revenue Commission; f) The Chief Executive Officer of the Financial Services Authority; g) The Chief Executive Officer of the Anti-Corruption Commission of Seychelles; h) The Director of the FIU and; i) The Director General for the Seychelles Intelligence Services.
Technical Anti-Money Laundering and Countering the Financing of Terrorism Committee (“TAC”) The Technical Committee comprises of technical experts from the Central Bank of Seychelles, the Financial Intelligence Unit, the Financial Services Authority, the Office of the Attorney General, the Anti-Corruption Commission of Seychelles, the Office of the Registrar General, the Seychelles Intelligence Service, the Seychelles Police, the Seychelles Revenue Commission, the Ministry responsible for Finance, the Ministry responsible for Foreign Affairs, the Ministry responsible for Internal Affairs and the Seychelles Licensing Authority.
TAC is chaired by the Deputy Director of the FIU and its primary objective is to supports NAC and its mandate.
During the year 2022, the committee has provided technical support on the following;  Preparation for the National Risk Assessment  Review of the Beneficial Ownership Act and Regulations  Seychelles re-rating application to the ESAAMLG which was submitted in September 2022  NPO Risk Assessment  VA/VASP Risk Assessment  OECD Report 50 | P a g e International commitments, coordination and collaboration Seychelles application for re-rating report to ESAAMLG – September 2022 The AML/ CFT framework of Seychelles was assessed against the FATF 2013 Methodology and the 2012 FATF Recommendations in the Second Round of Mutual Evaluations conducted by ESAAMLG.
The onsite component of the assessment took place between 20th November to 5th December, 2017.

The Report (“MER”) was adopted by the ESAAMLG Council of Ministers in September, 2018.

Informed by the findings of the MER, and following Seychelles’ first National Risk Assessment (“NRA”) in 2018, all relevant stakeholders have been actively engaged to undertake reforms to the legal and regulatory framework and remediating the technical deficiencies and limitations identified in Seychelles’ AML/ CFT framework.
The FIU has been instrumental in coordinating Seychelles’ efforts towards improving its technical compliance with the FAFT recommendations and communicating these to the Eastern and Southern Africa Anti-Money Laundering Group (“ESAAMLG”).

For yet another year, the country’s reporting obligations have been met with the latest re-rating report submitted in September 2022.
The Seychelles is optimistic that in 2023, it will record improvement in its technical compliance ratings for Recommendations 5, 19, 25, 28 and 34.

Since the MER Seychelles has made significant progress in addressing the technical compliance deficiencies identified and the FIU is set to support Seychelles in becoming fully compliant with the FATF forty (40) technical recommendations.
It is the national aspiration that in due course the country will become fully technically compliant and will therefore be able to progress to concentrating on compliance to the FAFT immediate outcomes (“IOs”) which are the benchmark against which the effectiveness of the country’s AML/CFT system is judged.
Seychelles’ second round review: Exchange of Information for tax purposes 51 | P a g e FIU participated in Seychelles’ second round review on the exchange of information for tax purposes, where FIU contributed in providing information on the availability of beneficial ownership and identity information with the aim of improving Seychelles’ status from being partially compliant to compliant.
FIU provided information on the administration of the BO Act and Regulations, 2020 and the BO Database and also made a presentation during the on-site visit which was held in December 2022.Seychelles will receive feedback on the Seychelles’ status in 2023.

Collaboration with other agencies: OPTAC Analysts from the FIU were seconded to an LEA for a period of six (6) months in the effort to enhance cooperation and exchange of information.
Further, analysts have participated in various working groups with law enforcement and supervisory authorities, where the FIU has been able to provide its support through its analytical function and its network of international counterparts.

52 | P a g e CHAPTER 7: 2022 SUCCESSES, CHALLENGES AND PRIORIOTIES FOR 2023 Launched the beneficial ownership database for the domestic sector.
Designed the electronic platform for use by core function for recording feedback from stakeholder pertaining to intelligence report disseminated.

Major Achievements for 2022 Reinitiated remote session with the UNODC consultant for configuration of the goAML platform for reporting.

Initiated the disaster recovery plan and continued with infrastructure upgrades to ensure that FIU is at par with the information security requirements set by the Egmont group.
Embarked on a technical assistance programme with the EU Global facility for AML/CFT to design and implement a new beneficial ownership database with all registry functions.

Participated in the ESA Regional grouping to finalize implementation of a secure platform for information exhange within the region.

53 | P a g e 2022 Challenges Staff retention FIU is continuously challenged in retaining competent employees.
The financial sector continues to attract trained staff that eventually joins the private sector.

Attracting new staff is also a challenge for the unit.

The Seychelles labour market is small comparing to the available posts for professionals, as a result the quality of staff that FIU aim to attract is not always available.

Shifting nature of Financial Crimes The evolution of financial crimes will remain a challenge for FIU as well as other insitutions tasked with safeguarding the financial system.
As new solutions are detected to deter financial crimes, criminals develop new ways to circumvent deterent or detection framework to commit crimes.

Information sharing Effective information sharing is one of the cornerstones of a well-functioning AML/CFT framework.

Given that the Seychelles is a small jurisdiction FIU is challenged with creating an appropriate public-private interaction that will encourage the exchange of information which will ultimately aid in the fight against financial crime.
Abilities within the public sector to appropriately, timeously and effectively share information within and across different authorities and agencies must also be enhanced as it currently presents a challenge.

Priorities for the year 2023 In the year 2023 budget will be allocated to; 54 | P a g e  producing timely and accurate financial intelligence reports to assist domestic partners in the national fight against illicit activities through enhanced detection and investigation of suspected offences.
 enhancing supervisory activities;  developing strategies to attain suitable public-private partnership and high public-public coordination  maintaining regional and international networking and;  improving effectiveness and efficiency through modernization and innovation of our processes.

55 | P a g e Strategic Priorities Strategic Objective 1: Develop new and strengthen existing financial intelligence framework to detect and deter economic crimes.
Within strategic objective 1 the priority for the year 2023 is to develop FIU's capacity to improve on operational analysis, strategic analysis and virtual assets.

Emphasis will also be placed on establishing public-private partnership to ensure effective information sharing.

Strategic Objective 2: Promote and enhance compliance with the Seychelles AML/CFT/CPF/BO framework, through awareness, supervision and enforcement.
Within strategic objective 2 the priority for the year 2023 is to put in place the proper mechanism for enforcement, emphasis will also be placed on creating a proper framework for DNFBPs and creating a forum with them to maintain two-way communication with the sectors.

Strategic Objective 3: Enhance our capabilities and governance processes to operate efficiently and effectively.
Within Strategic Objective 3 the priority for the year 2023 is to develop the necessary SOPs and policies for internal processes to assist in improving on organisational performance and governance.

Strategic Objecive 4: Foster a culture that enables innovative and technology driven solutions Within Strategic Objective 4 the main focus for the year 2023 is to implement an enterprise approach for infrastructure applications and upgrade the IT infrastructure to accommodate for future IT upgrades.
56 | P a g e ANNEXURE 1: Strategic Plan Review- 2019-2022 STRATEGIC PLAN REVIEW – 2019-2022 Strategic pillar (s) Planned Activities Status Implemented.

Implemented.

Implemented.

Implemented.

1.

Robust system to detect financial and deter crime 1.

A training programme for Financial Analysts to improve the level of tactical, operational and strategic analysis on information received to better identify possible indicators of financial crime.

2.
2.

Partner with Foreign FIU’s from mature to organize jurisdictions exchange programmes for FIU staff.

3.

Seek Technical Assistance (“TA”) from foreign counterparts to support the FIU with resident financial specialists to mentor staff and prepare training programmes for the transference of knowledge and skills.

partners international 4.


Develop protocols and interface to reinforce communications with LEAs and supervisory authorities and to maximize appropriate dissemination and use of FIU’s analytical products activity, to investigate crimes tax evasion), disrupt (including secure activity, criminal prosecutions and confiscate proceeds of crime.

detect AML/CFT financial 5.


Engage with REs in a meaningful partnership, particularly in regards to improving the quality of STRs reporting, ML and TF typologies and emerging threats.

Implemented.

Implemented.

57 | P a g e 6.

Strengthen information exchanges and participation of the FIU in initiatives to meet national and international obligations.

Implemented.

supervisors domestically 7.


Develop a coordinating mechanism for all the sectoral supervisors to and coordinate information effectively exchange with on other supervisory approaches, supervisory supervisory and expectations competent actions, other authorities where necessary, to the national continuously update understanding of ML/ TF and PF risk.

and 1.
and 1.

Develop and implement a supervisory program providing for the risk-based supervision of relevant reporting sectors under the FIU’s purview.

application of 2.

Conduct risk-based independent or joint supervision both on the DNFBP and NPO sector.

3.

Enforce timely and appropriate sanctions in cases of non-compliance in terms of the AMLA.

4.

Design and deliver independent or joint outreach and awareness raising seminars on AML/CFT/CPF for all RE under the FIU’s regulatory purview.

1.
1.

Secure resources financial the FIU’s to improve technology its to infrastructure workforce and improve the quality of the material it receives and produces.

support 2.

Introduce and monitoring tools to support proactive analysis new Implemented.

Implemented.

Implemented.

Implemented.

Outstanding.

Outstanding.

58 | P a g e 2.

Compliance and system culture 3.

Information communication Technology identification of trends and patterns from information/ data received and disseminated.

3.
3.

Install and management system operations.

implement a case to support 4.

Work with relevant LEAs to obtain access to key extrinsic data sources to support and enhance FIU’s analytical functions.

5.

Build capacity and skills of IT personnel to support the institution on critical applications or systems.

6.
6.

Employ technology to standardize system for electronic filling of reports, to improve the quality and speed of feedback and process for analysis and generating of statistical regulatory data compliance process as well as management.

to support the 1. Review engagement, the AMLA through stakeholder to harmonize the new legislation for to effectiveness increased reporting improve entities their AML understanding of obligation and compliance level within the jurisdiction.

and 4.
and 4.

Strategic positioning Outstanding.

Outstanding.

Implemented.

Outstanding.

Implemented.

2.

Increase the visibility and presence of the FIU in Global fora such as Egmont group and ESAAMLG.

Implemented.

3.

Engage with domestic stakeholders to deliver sensitization programme on AML related issue to create a culture of compliance within the jurisdiction.

Implemented.

59 | P a g e 4.


Reinvigorate the FIU to amplify domestic acuity by promoting effectiveness, institutional integrity, increasing cooperation and the quality of the FIU’s operational outputs.

5.

Reshape and strengthen reporting the FIU, relation with entities through outreach, effective monitoring and supervision; and take timely and equitable enforcement action to redress cases of non- compliance.

6.
6.

Promoting the FIU through the use of technology its support to information infrastructure workforce.

5.

An innovate, high- performing and diverse workforce 1. Review and the FIU’s revise operational structure to reflect its new vision, mission and strategic direction as the lead AML/CFT regulator in the country; training and strategy 2.

Develop a talent for FIU, development through an institutional capability and talent gap analysis; conduct the of 3.
Develop and implement a training to and development programme ensure that employees have the skills needed to achieve FIU’s mandate and mission; and to advance within the Divisions.

4.

Promote innovative thinking at all staff levels to address evolution within the financial sector and methods to deter potential abuse.

Implemented.

Outstanding.

Outstanding.

Implemented.

Outstanding.

Implemented.

Implemented.

5.

Identify and address barriers to recruiting and retaining a diverse and Implemented.
60 | P a g e high performing workforce through the development of scheme of service for FIU staff.

6.

Strengthen the FIU’s internal communications, collaboration and ethical conduct across and within and organizational programs through the conduct of specialized training sessions.

functions Implemented.

7.

Set up performance management development system to clearly define and performance expectations and formally evaluate employee performance.

communicate Implemented.

8.


Set up relevant policies to promote and support sound operational and environmental practices.

Outstanding.

Success rate 22 Activities implemented out of 31 activities planned, the 9 activities that are outstanding are included in the 2023-2025 Strategic Plan.
ANNEXURE 2: International Seminars, Workshops and Trainings - 2022 Initiative International Meetings Trafficking in Human Beings and of Smuggling Immigrants (THB/SOM) Intelligence Sources Cash at the border Participants Details 1 4 AML/THB Project (Virtual) HMRC (Mr. John Osborne and Mr. Tim Hooper) in Collaboration with Seychelles Commission Revenue (Physical) 61 | P a g e and open of HMRC Presentation approach to Asset Recovery and Money Laundering investigations using a HMRC case study Asset forfeiture and Money Laundering Good governance in a digital trading and environment” Tax Transparency and Corruption Intelligence Criminal Analysis & Mapping of THB/SOM Criminal Networks Onsite Visit Technical Assistance and Mentoring on Anti‐Money Laundering and Countering the Financing of Terrorism (“AML/CFT”) National Risk Assessment (“NRA”) of Virtual Assets (“VA”) and virtual Assets Service Providers (“VASP”) Multi-stakeholder Meeting on Strategies to Prevent and Combat Organized Crime in Eastern and Southern Africa Regional Workshop on with Compliance International EU requirements Concerning the FAFT Recommendation 8 Workshop On Beneficial Ownership and 4 1 2 3 2 2 2 2 Trade-Based ML in the Ghoa: Analysis and Investigation- Meeting II Cybercrimes course investigation 1 3 HMRC (Mr. John Osborne and Mr. Tim Hooper) in Collaboration with Seychelles Revenue Commission (Physical) ILEA in Gaborone, Botswana (Virtual) United Nations Office on Drugs and Crime, World Bank and African Tax Institute project (Virtual) project European Union (referred as AML/THB project) (Virtual) hereafter Financial Services Authority (Physical) United Nations Office on Drugs and Crime (UNODC) (Virtual) ESAAMLG (Physical) Secretariat (ESAAMLG) EU AML/CFT Global Facility in collaboration with the Eastern and Southern Africa Laundering Anti-Money Group and Financial Intelligence Centre (FIC), South Africa (Physical) project European Union referred as AML/THB project (Virtual) USA - ILEA in Gaborone, Botswana (Virtual) 62 | P a g e group- Expert
 Working Formal Informal and cooperation between Anti- corruption LEA’s Anti-corruption LEA’s – London, United Kingdom Disrupting criminal trafficking and smuggling networks through increased Anti-Money Laundering and financial investigation capacity in the Greater Horn of Africa USA Forfeiture Laundering Course Understanding of Terrorist Financing Risk in the Non- Profit Organisations (NPO) sector Systems Analysis of Drug Trafficking Networks along the Southern Route Training-Asset and Money 2 1 1 1 2 2 Workshop on Introduction to Financial Investigations 4 Identification and Handling of Suspicious cash Regional workshop Beneficial Ownership on 7 2 AML/CFT International Standards/FATF Standards Course 9 INTERPOL- Financial Crime and Anti-Corruption Centre- UK (Physical) United Nations Office on Drugs and Crime (Physical) European Union project referred as AML/THB project (Physical) USA - ILEA in Gaborone, Botswana (Physical) UNOCT-UNCCT ESAAMLG (Physical) and and UNODC ROEA jointly with the Afghan Opiates Trade Project the (AOTP) Global Programme against Money Laundering, Proceeds of Crime and the Financing of Terrorism (GPML) (Physical) UNODC in collaboration with German cooperation Mr. Hannes Jansen van Vuren (Physical) UNODC Mr. Hannes Jansen van Vuren Eastern and Southern Africa Laundering Anti-Money Group in the collaboration European Union Anti-Money Laundering and Terrorism Financing Global Facility (EU Global Facility) and the South African Financial Intelligence Centre (FIC) (Physical) World (Physical) (ESAAMLG), Training Bank with 63 | P a g e Origin Trusts Development FATF Training (STC 18) and 7 2 Beneficial Ownership Course 1 Financial Investigations & Asset recovery for LEAs Workshop on Best Practices and of Mechanisms Producing Quality Financial Intelligence i2 Analyst’s Notebook I: Link and Case Charting and i2 Analyst’s Notebook 2: Importing & Data Analysis Strategic Approach & Risk Base Supervision (Gambling, Legal & Accountants) Professional 1 2 4
 7 Domestic Seminars, workshops and training Domestic Workshops and Trainings Use of Government Vehicles 1 Participants Result Based Management (RBM) Phase 1 10 Result Based Management (RBM) Phase 2 Result Based Management (RBM) Phase 3 Result Based Management (RBM) Phase 4 Performance management 8 8 2 1 Michael Darwin (Physical) & ESSAMLG FATF Secretariat (Physical) Commonwealth Africa Anti- Corruption Centre (CAACC), Botswana (Physical) COMESA (Physical) ESAAMLG Secretariat, in collaboration with Financial Reporting centre Kenya and GIZ (Physical) Intelligence Directorate, National Crime Agency, British High Commission, Addis Ethiopia Ababa, (Physical) EU/GF Details Ministry of Finance (Physical) Guy Morel Institute in Partnership with PSB and Ministry of Finance Guy Morel Institute in Partnership with PSB and Ministry of Finance Guy Morel Institute in Partnership with PSB and Ministry of Finance Guy Morel Institute in Partnership with PSB and Ministry of Finance PSB in collaboration with Guy Morel institute 64 | P a g e International Meetings International Initiative Meetings Meeting of Egmont IT Professionals Information Exchange Working Group Technical Assistance and Training Working Group Membership, Support and Compliance Working Group Policy and Procedures Working Group Technical assistance financed under the 11th EDF TCF Facilitators Call - Public Private and Public- Public Partnerships Webinar Participants Details 4 8 8 2 1 1 Egmont Working & Regional Groups Meetings (Virtual) Egmont Working & Regional Groups Meetings (Virtual) Egmont Working & Regional Groups Meetings (Virtual) Egmont Working & Regional Groups Meetings (Virtual) Egmont Working & Regional Groups Meetings (Virtual) FCG Germany and Project Director Ms. Milica Simin, alongside FIU’s experts Mr. Marc-Andrew Alix and Ms. Stella Attakpah.
AGA Africa (Virtual) Professional Qualifications Qualifications International Diploma in Money Laundering Participants 2 Details International Compliance Association (ICA) UK 65 | P a g e ANNEXURE 3: BO Awareness Sessions Date Audience Topic 24/01/2022 Ministry of Investment, Entrepreneurship & Industry Beneficial Ownership Act Mode Virtual Includes all the top management of the Ministry and the Minister 09/02/2022 Ministry of Investment, Entrepreneurship & Industry Beneficial Ownership Act Virtual Includes all the line staff of the different units of the ministry ESA, IEA, Secretariat and Policy Unit, SLA, SIB, SBS, Division of Science, Technology and Innovation 30/03/2022 CEPS including its members 11/05/2022 National Arts and Crafts Council (NACC) All associations affiliated with NACC 20/05/2022 National Sports Council (NAC) All associations affiliated with NAC) Beneficial Ownership Act Face-to-Face Beneficial Ownership Act Face-to-face Beneficial Ownership Act Face-to-face 26/09/2022 Fisheries & Agriculture Associations Beneficial Ownership Face-to-face 11/10/2022 Environmental NPOs 17/11/2022 Domestic Companies Act Beneficial Ownership Act Face-to-face Beneficial Ownership Act Face-to-face 66 | P a g e 17/11/2022 Religious Associations Beneficial Ownership Act Face-to-face ANNEXURE 4: List of MoU NUMBER OF COOPERATION ARRANGEMENTS - FOREIGN AND LOCAL # DESCRIPTION 1 2 FOREIGN AUTHORITIES/ORGA NISATIONS LOCAL AUTHORITIES/ORGA NISATIONS NUMBER OF MOU TO TA L NUMBER OF COOPERATION ARRANGEMENTS WITH LOCAL AUTHORITIES S. NO NAME OF THE ORGANISATION Seychelles Revenue Commission Financial Services Authority and Central Bank (Joint MOU) Seychelles Licensing Authority Anti- Corruption Commission of Seychelles Seychelles Intelligence Service AML/ CFT Supervisors Seychelles Licensing Authority Seychelles Maritime Safety
 Authority Department of Environment DATE OF MOU 04-Jan-09 6-Oct-2015 & 14-Oct-2015 29-Dec-20 14-Aug-20 17-Jul-20 09-Feb-20 5-Mar-21 29-Dec-21 22-Dec-22 NUMBER OF COOPERATION ARRANGEMENTS WITH ORGANISATION IN OTHER COUNTRIES 67 | P a g e S. NO NAME OF THE ORGANISATION Service de Renseignements Financiers de Madagascar COUN TRY Madaga scar South Africa Financial Intelligence Centre Republic of South Africa Financial Reporting Centre of the Republic of Kenya Kenya Financial Intelligence Centre of the Republic of Namibia Namibia Mauritiu s Financial Intelligence Unit, Mauritius Financial Intelligence Unit of the Republic of the Republic Angola Japan Financial Intelligence Center of the National Public Safety Commission of Japan Federal Financial Monitoring Service (Russian Federation) 9 Australian Federal Police Force 10 Financial Intelligence Unit of the Republic of Zimbabwe 11 Financial Intelligence Centre of the Republic of Zambia 12 Republic of Pananama Financial Intelligence Authority of the Republic of Uganda 13 14 Belgian Financial Intelligence Processing Unit CTIF Commercial Affairs Department of the Singapore Police force Financial Transactions and Reports Analysis Centre of Canada 15 16 17 Financial Intelligence Unit of the Kingdom of Swaziland 18 Australian Transaction Reports and Analysis Centre 19 Financial Intelligence Unit of Eswatini 20 Financial Intelligence Agency Republic of Botswana 21 Financial Monitoring Unit of Pakistan 22 Financial Intelligence Service of Republic of Djibouti 23 Bangladesh Financial Intelligence Unit 24 25 Financial Intelligence Unit of the United Republic of Tanzania GIZ (German international cooperation) with ESAAMLG FIUs The International Anti-Corruption Centre Associate Membership Scheme 26 27 The Financial Intelligence Unit of the Republic of Mozambique DATE OF MOU 11-Feb-12 14-May-12 & 23- May-12 9-Mar-13 9-Jul-13 9-Mar-13 9-Mar-13 27-Jun-13 & 03- Jul-13 6-Apr-14 23-May-14 & 31- May-14 9-Apr-14 9-Apr-14
 14-Nov-14 25-May-15 26-Sep-16 20-Jul-17 17-Oct-17 & 18- Dec-17 4-Sep-18 26-Sep-18 9-Apr-18 9-Mar-18 23-Dec-19 15-Jan-20 29-Jan-20 23-Apr-2021 & 29- Apr-2021 22-Nov-21 22- Feb- 2022 27 68 | P a g e Angola Japan Russia Australi a Zimbab we Zambia Panama Uganda Belgium Singapo re Canada Swazila nd Australi a Eswatini Botswan a Pakistan Djibouti Banglad esh Tanzani a German y UNOD C Mozam bique 69 | P a g e