Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1694861595139.pdf (Fiji)
FIJI FINANCIAL INTELLIGENCE UNIT 2020 AN NU AL R EPO R T OUR VISION “Protecting Fiji from Money Laundering” STRATEGIC PILLARS The strategic pillars that support our vision are: 1.

Financial Intelligence 2.

Preventive Measures 3.

Technology Driven Processes 4.

Partnerships 5.

Our People KEY STRATEGIES 1.

Develop and disseminate quality intelligence products for our stakeholders.

2.

Improve the quality and use of our intelligence products.

3.
3.

Promote the understanding of money laundering risks and methods in Fiji.

4.

Promote a risk based implementation of the preventive measures under the FTR Act.

5.

Enhance financial institutions and businesses understanding of their obligations under the FTR Act.

6.

Effectively supervise financial institutions and businesses for compliance with the FTR Act and take appropriate enforcement action in case of non-compliance.

7.

Effective data reporting.

8.


Develop innovative data management systems and analytic tools.

9.

Improve data quality and information security.

10.

Enhance our network for information sharing.

11.

Strengthen relationships with domestic and international partners.

12.

Provide support to international partners on AML/CFT initiatives and engagements.

13.

Cultivate a skilled, motivated and high performing team.

14.
14.

Ensure corporate governance through strong internal controls and performance reporting.

TABLE OF CONTENTS 2020 ANNUAL REPORT FIJI FINANCIAL INTELLIGENCE UNIT 1.

FIU ROLE AND RESPONSIBILITIES 2.

DIRECTOR’S FOREWORD 3.

GOVERNANCE STRUCTURE 4.

EXPENDITURE STATEMENT & NOTES 5.

OUR ACHIEVEMENTS A.

Receipt and Analysis of Financial Information B.


Dissemination of Financial Intelligence C. Supporting and Supervising Financial Institutions D. Domestic Coordination and Engagement E. International Engagement and Contribution 6.

OPERATIONAL GOVERNANCE AND COMMUNICATION 7.

STRATEGIC PLAN 2020 - 2024 8.

NATIONAL AML COUNCIL 9.

APPENDICES 10.

SELECTED KEY STATISTICS 2016 - 2020 11.

SELECTED KEY EVENTS 2020 2020 STRATEGIC ANALYSIS REPORT FIJI FINANCIAL INTELLIGENCE UNIT 1.
STRATEGIC ANALYSIS OVERVIEW 2.

SUMMARY OUTCOMES 3.

OUTCOMES - SUSPICIOUS TRANSACTION REPORTS 4.

OUTCOMES - CASH TRANSACTION REPORTS 5.

OUTCOMES - ELECTRONIC FUNDS TRANSFER REPORTS 6.

OUTCOMES - BORDER CURRENCY REPORTS 7.

EMERGING AND CONTINUING MONEY LAUNDERING TRENDS 8.

CASE STUDIES 9.
CASE STUDIES 9.

GLOSSARY 2 3 6 12 14 14 17 21 28 30 35 39 47 50 56 57 63 65 66 73 75 77 80 81 88 1 FIU ROLE AND RESPONSIBILITIES The Financial Intelligence Unit (FIU) is one of the leading agencies in Fiji that is responsible for preventing and detecting money laundering and terrorist financing activities.

The FIU is established under the Financial Transactions Reporting (FTR) Act.

The role and functions of the FIU are provided under the FTR Act.
8. comply with international AML/CFT standards; 9. supervise financial institutions for compliance with the FTR Act; 10. take appropriate enforcement action in case of non-compliance; 11. provide education and training to its stakeholders; 12. lead and facilitate national coordination; and The core role of the FIU as an intelligence agency is to receive, analyse and disseminate financial intelligence to relevant law enforcement agencies.
13. maintain networking and information sharing with domestic and foreign partner stakeholders and agencies.

The FIU is also Fiji’s anti-money laundering (AML) and combating the financing of terrorism (CFT) regulator and the lead agency on AML/CFT policy formulation, compliance and enforcement.

The FIU also plays an important role in international AML/CFT initiatives by contributing to global AML/ CFT programmes, policy discussions and information exchange network.
The FTR Act and Regulations specifies a range of measures that financial institutions1 in Fiji must implement in order to prevent the use of Fiji’s financial system from money laundering, terrorist financing and other serious criminal activities.

The vision of the FIU is to protect Fiji from money laundering.
It achieves this vision through the following key functions: 1. receive financial transactions and other information from financial institutions; 2. gather additional from financial institutions, government and other stakeholder agencies; information 3. analyse information; 4. develop intelligence; 5. refer intelligence and information of possible money laundering activities or other serious criminal activities to appropriate law enforcement and regulatory agencies; 6. assist domestic and foreign law enforcement agencies in their investigation and prosecution of money laundering and other serious criminal activities; 7. develop AML/CFT policies, FIU enforceable guidelines and advisories under the FTR Act; The FIU is modelled as an “administrative FIU” that is currently administered by the Reserve Bank of Fiji.
The FIU also conducts periodic strategic analysis and its outcomes are used by FIU partners including the private sector financial institutions and designated non-financial businesses and professions (DNFBP).

The FIU shares its intelligence and information both spontaneously and upon request to various partner agencies, both domestic and foreign.

The National AML Council provides assistance to the FIU on broad AML policy and national coordination framework.
The RBF provides funding and general administrative support for the FIU’s operations.

The Fiji Police Force (FPF) and the Fiji Revenue and Customs Service (FRCS) provide additional staffing support to the FIU.

The FIU does not have formal investigative powers to arrest and charge suspects or restrain properties.

The FIU does not have a prosecutorial role.


The FIU’s role as a financial intelligence body in Fiji has become an integral part and contributor in successfully investigating and prosecuting money laundering and other serious crimes.

1 The definition of “financial institutions” under the FTR Act includes Designated Non-Financial Businesses and Professions (DNFBPs) and other non- traditional financial institutions such as non-banks, mobile phone money remitters, lawyers, accountants and real estate agents.
2 3 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 2 DIRECTOR’S FOREWORD I am pleased to present the 2020 Annual Report of the FIU.

This is the 15th Annual Report of the FIU.

In 2020, the FIU continued to develop, implement and enforce AML/CFT preventive measures, financial intelligence management, information exchange, and created awareness on ML and TF trends and typologies.
Despite the many challenges, FIU’s operational resilience and business continuity measures helped us successfully accomplish our key performance targets, the deployment of the Work From Home (WFH) process during the nationwide lockdown due to the global pandemic.

including through 2020 also saw the initial rollout of our new five-year strategic plan for 2020 – 2024.
The FIU’s five strategic pillars on financial intelligence, preventive measures, technology driven processes, partnerships and our people are closely linked to the statutory functions of the FIU under the FTR Act and also reflect priorities that we consider vital in order to achieve our vision.

In the intelligence front, we noted a new typology on Covid-19 related online scam in 2020, together with an escalation of cybercrime cases that targeted several Fijians from a particular locality in Fiji.
On preventative measures, we strengthened our engagement with the financial institutions (including lawyers, accountants and real estate agents) and other industry stakeholders through development of new AML/CFT policies, onsite compliance examinations and training.

This led to more quality reporting and the effective implementation of FIU enforcement capabilities that support the deterrence of non-compliance of the preventative measures.
In relation to reporting requirements, 2020 noted the highest number of EFTRs of 1,866,000 which was attributed by increased reporting from the MPMR and MRSP sectors.

In 2020, the FIU continued as the secretariat for the National AML Council and working groups and as Fiji’s primary contact point for Asia/Pacific Group (APG) on Money Laundering.

The National Risk Assessment (NRA) and the Non-Profit Organisations (NPO) framework were reviewed in 2020 and will be finalised in 2021.
The FIU also continued to review its governance arrangement with the RBF to ensure autonomy and independence.

The 2020 Annual Report is divided into two parts: • Annual Report section; and • Strategic Analysis section.

The Annual Report section highlights key functional and operational outputs while the Strategic Analysis section highlights the underlying patterns and trends.

transactions and other In 2020, the FIU received a total of over 2.5 million reports.
The financial reporting to FIU experienced a ripple effect of the global pandemic.

There was a 77 percent decrease in BCRs due to the COVID-19 travel restrictions, however, EFTRs received increased by 23 percent from 2019.

This was largely attributed to the mobile phone sector remittances.

In addition, most of the national and international meetings, workshops and seminars during 2020, were conducted virtually.
2 3 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 The FIU will continue to remain in the forefront of combating money laundering and terrorism financing in Fiji by collaborating with the respective reporting institutions, and domestic and international partner agencies.

I would like to thank the Governor and the Board of the Reserve Bank of Fiji for providing financial and administrative support to the FIU in 2020.
I would also like to thank the Acting Commissioner of Police and the Acting Chief Executive Officer of the FRCS for seconding their officers to the FIU.

I look forward to working more closely with our stakeholders in 2021 in achieving our vision of “Protecting Fiji from Money Laundering”.
Razim Buksh Director Financial Intelligence Unit Foreign investors, local business and ordinary Fijians are protected from illicit financial transactions Contribute to the investigation and prosecution of fraud, corruption, tax evasion and other complex financial crimes Safety and integrity of Fiji’s financial system Detection, reporting and investigation of suspicious transactions Financial Intelligence Unit Conduct background and due diligence checks National and international networking and information exchange Fiji’s compliance with international AML/CFT requirements Implement preventive customer due diligence measures 4 5 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 2020 AT A GLANCE Received 1,866,197 Electronic Funds Transfer Reports Received Received 736 Suspicious Transaction Reports 619,987 Cash Transaction Reports Handled 70 requests for due diligence on 90 entities and 114 individuals Disseminated 270 Intelligence reports Issued 74 Ad-hoc policy advisories Managed More than Analysed 192 Authorised users of the FIU’s online IT system 18 Million Financial transaction reports in our database 684 Suspicious Transaction Reports Handled 266 Border Currency Reports Handled 125 Requests for investigative assistance from law enforcement agencies Provided training to 104 employees of financial institutions Made 645 Enquiries to financial institutions Managed network of Conducted Conducted 134 registered AML Compliance Officers of financial institutions (since 2006) 2 3 AML on-site compliance examinations of law firms AML on-site compliance examinations of real estate agents 4 5 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 3 GOVERNANCE STRUCTURE Statutory Agency The FIU is a centralised, independent, administrative and a statutory agency of the Fijian Government that was established in 2006 under the FTR Act.
The powers, duties and functions of the FIU are clearly defined in the FTR Act.

Minister for Justice The Minister for Justice is the line Minister responsible for the FTR Act.

Pursuant to section 23(3) of the FTR Act, the Minister is directly responsible for the performance of the Director FIU.

The Minister is also responsible for appointing the Director FIU on the recommendation of the National AML Council.
Governor of the Reserve Bank of Fiji Pursuant to a ministerial delegation under the FTR Act, the Director FIU reports to the Governor of the RBF for the discharge of the Director’s powers, duties and functions provided under the FTR Act.

Subsequent to this delegation and on the recommendation of the Governor, the Board of Directors of the RBF approved the organisation structure and annual funding of the FIU.
Director of the FIU The Director FIU exercises the powers, duties and functions of the FIU as specified in the FTR Act.

The Director FIU is responsible to the Minister for Justice or such other person as the Minister may appoint, in the performance of his duties.

Following the Minister’s delegation of his responsibility in 2005, the Director is now directly responsible to the Governor of the RBF in the performance of his duties.

Director FIU is a member of the National AML Council.
He is also the advisor to the Minister and the Governor on matters relating to combating money laundering, terrorist financing and related offences in Fiji.

The Director is responsible for the preparation and implementation of FIU’s strategic and annual work plans and its annual budget.

Accountability to the Governor The Director FIU meets monthly with the Governor of the RBF and also provides monthly reports on the FIU’s performance and achievement of work plan targets.
The Director of the FIU provides regular progress updates to the National AML Council, Governor and Board of the RBF on key FIU outputs and outcomes.

The FIU complies with the administrative policies, processes and procedures of the RBF including human resources, IT resources and other policies and processes of the RBF.
FIU GOVERNANCE AND ACCOUNTABILITY FRAMEWORK Minister for Justice Governor and RBF Director FIU National AML Council • Minister responsible for the FIU • Responsible for the • Responsible for the powers, under the FTR Act.

• Delegated his responsibilities under the FTR Act to the Governor of the RBF in 2005. administration of the FIU under the delegation of powers from the Minister for Justice.

functions and duties of the FIU as specified in the FTR Act.
• Reports directly to the Governor • Responsible for the approval of FIU annual work plan and budget.

of the RBF.

• Advisor to Government on • Responsible for providing advice and assistance to the FIU on the prevention of money laundering and terrorist financing activities in Fiji.

• Provides recommendations to matters relating to combating ML and TF.

the Minister and Governor on the appointment of the Director.
6 7 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 The National AML Council The National AML Council provides broad policy advice, assistance and guidance to the FIU on the prevention of money laundering, terrorist financing and related activities in Fiji.

The Council is also responsible for making recommendations to the Minister on the appointment of the Director of the FIU.
The FIU also receives indirect financial support from the FPF and the FRCS through staff secondment to the FIU on a full-time basis.

The secondment arrangement is provided under MOAs the FIU has signed with the two agencies.

The FIU does not currently receive any direct funding support from the Fijian Government.

The FIU provides regular reports and updates to the National AML Council.
The National AML Council is established under the FTR Act and its members, roles and functions are also provided under the FTR Act.

Funding and Administration The FIU is fully funded by the RBF and is organised as a separate functional group within the RBF’s organisation structure.

The annual budget of the FIU is submitted for the approval by the Board of the RBF each year.

The FIU is accountable to the Governor and the Board for the use of funds allocated annually.
The FIU has been administratively housed within the RBF since 2006.

The FIU is subject to all the administrative protocols, policies and procedures of the RBF.

The FIU does not prepare and publish annual financial statements on its operations.

The expenditure of the FIU is included in the financial statements of the RBF and is subject to the Bank’s internal and external audit (refer to the section on Expenditure Statement and Notes for more information).
Operational Governance The Fiji FIU implements Egmont Group of international FIUs best practices on FIU operating standards, protocols and procedures on the following key responsibilities: Egmont Group FIU Responsibilities 1 International cooperation and information exchange 2 Receipt of confidential and sensitive information 3 Analysis and intelligence development 4 Information security 5 Compliance & enforcement 6 Operational independence and governance The FIU also complies with the Financial Action Taskforce its Interpretive Note on financial intelligence units.
(FATF) Recommendation 29 and 6 7 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Recommendation 29.
Financial intelligence units Countries should establish a financial intelligence unit (FIU) that serves as a national centre for the receipt and analysis of: (a) suspicious transaction reports; and (b) other information relevant to money laundering, associated predicate offences and terrorist financing, and for the dissemination of the results of that analysis.
The FIU should be able to obtain additional information from reporting entities, and should have access on a timely basis to the financial, administrative and law enforcement information that it requires to undertake its functions properly.

INTERPRETIVE NOTE TO RECOMMENDATION 29 (FINANCIAL INTELLIGENCE UNITS) A.

GENERAL 1.

This note explains the core mandate and functions of a financial intelligence unit (FIU) and provides further clarity on the obligations contained in the standard.
The FIU is part of, and plays a central role in, a country’s AML/CFT operational network, and provides support to the work of other competent authorities.

Considering that there are different FIU models, Recommendation 29 does not prejudge a country’s choice for a particular model, and applies equally to all of them.

B.

FUNCTIONS a) Receipt 2.

The FIU serves as the central agency for the receipt of disclosures filed by reporting entities.
At a minimum, this information should include suspicious transaction reports, as required by Recommendation 20 and 23, and it should include other information as required by national legislation (such as cash transaction reports, wire transfers reports and other threshold-based declarations/disclosures).

b) Analysis 3.

FIU analysis should add value to the information received and held by the FIU.
While all the information should be considered, the analysis may focus either on each single disclosure received or on appropriate selected information, depending on the type and volume of the disclosures received, and on the expected use after dissemination.

FIUs should be encouraged to use analytical software to process information more efficiently and assist in establishing relevant links.

However, such tools cannot fully replace the human judgement element of analysis.
FIUs should conduct the following types of analysis: • Operational analysis uses available and obtainable information to identify specific targets (e.g.
persons, assets, criminal networks and associations), to follow the trail of particular activities or transactions, and 8 9 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 to determine links between those targets and possible proceeds of crime, money laundering, predicate offences or terrorist financing.
• Strategic analysis uses available and obtainable information, including data that may be provided by other competent authorities, to identify money laundering and terrorist financing related trends and patterns.

This information is then also used by the FIU or other state entities in order to determine money laundering and terrorist financing related threats and vulnerabilities.
Strategic analysis may also help establish policies and goals for the FIU, or more broadly for other entities within the AML/CFT regime.

c) Dissemination 4.

The FIU should be able to disseminate, spontaneously and upon request, information and the results of its analysis to relevant competent authorities.

Dedicated, secure and protected channels should be used for the dissemination.
• Spontaneous dissemination: The FIU should be able to disseminate information and the results of its analysis to competent authorities when there are grounds to suspect money laundering, predicate offences or terrorist financing.

Based on the FIU’s analysis, the dissemination of information should be selective and allow the recipient authorities to focus on relevant cases/information.
• Dissemination upon request: The FIU should be able to respond to information requests from competent authorities pursuant to Recommendation 31.

When the FIU receives such a request from a competent authority, the decision on conducting analysis and/or dissemination of information to the requesting authority should remain with the FIU.

C. ACCESS TO INFORMATION a) Obtaining Additional Information from Reporting Entities 5.
In addition to the information that entities report to the FIU (under the receipt function), the FIU should be able to obtain and use additional information from reporting entities as needed to perform its analysis properly.

The information that the FIU should be permitted to obtain could include information that reporting entities are required to maintain pursuant to the relevant FATF Recommendations (Recommendations 10, 11 and 22).

b) Access to Information from other sources 6.


In order to conduct proper analysis, the FIU should have access to the widest possible range of financial, administrative and law enforcement information.

This should include information from open or public sources, as well as relevant information collected and/or maintained by, or on behalf of, other authorities and, where appropriate, commercially held data.
8 9 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 D. INFORMATION SECURITY AND CONFIDENTIALITY 7.

Information received, processed, held or disseminated by the FIU must be securely protected, exchanged and used only in accordance with agreed procedures, policies and applicable laws and regulations.
An FIU must, therefore, have rules in place governing the security and confidentiality of such information, including procedures for handling, storage, dissemination, and protection of, as well as access to such information.

The FIU should ensure that its staff members have the necessary security clearance levels and understanding of their responsibilities in handling and disseminating sensitive and confidential information.
The FIU should ensure that there is limited access to its facilities and information, including information technology systems.

E. OPERATIONAL INDEPENDENCE 8.

The FIU should be operationally independent and autonomous, meaning that the FIU should have the authority and capacity to carry out its functions freely, including the autonomous decision to analyse, request and/or disseminate specific information.
In all cases, this means that the FIU has the independent right to forward or disseminate information to competent authorities.

9.

An FIU may be established as part of an existing authority.

When a FIU is located within the existing structure of another authority, the FIU’s core functions should be distinct from those of the other authority.

10.
10.

The FIU should be provided with adequate financial, human and technical resources, in a manner that secures its autonomy and independence and allows it to conduct its mandate effectively.

Countries should have in place processes to ensure that the staff of the FIU maintain high professional standards, including standards concerning confidentiality, and should be of high integrity and be appropriately skilled.

11.
11.

The FIU should also be able to make arrangements or engage independently with other domestic competent authorities or foreign counterparts on the exchange of information.

F. UNDUE INFLUENCE OR INTERFERENCE 12.

The FIU should be able to obtain and deploy the resources needed to carry out its functions, on an individual or routine basis, free from any undue political, government or industry influence or interference, which might compromise its operational independence.

G. EGMONT GROUP 13.
G. EGMONT GROUP 13.

Countries should ensure that the FIU has regard to the Egmont Group Statement of Purpose and its Principles for Information Exchange Between Financial Intelligence Units for Money Laundering and Terrorism Financing Cases (these documents set out important guidance concerning the role and functions of FIUs, and the mechanisms for exchanging information between FIUs).

The FIU should apply for membership in the Egmont Group.

H. LARGE CASH TRANSACTION REPORTING 14.


Countries should consider the feasibility and utility of a system where financial institutions and DNFBPs would report all domestic and international currency transactions above a fixed amount.
Source: FATF Recommendation 29 10 11 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Independence and Functional Autonomy of the FIU While the FIU is administratively dependent on the RBF, the technical and core functions of the FIU are independent of the RBF.

The Director FIU is responsible and accountable for the decisions relating to the delivery of the FIU core outputs.
The functional and operational independence of the FIU is provided under Part 4 of the FTR Act.

The FTR Act requires that the consideration for appointment of Director FIU by the Minister (Governor of the RBF under delegation of authority) is subject to the recommendation of the National AML Council.

To ensure that the functions of the FIU are not influenced by other parties, the Director of the FIU is solely vested with the powers to discharge the statutory and functional responsibilities of the FIU.
The Director devotes all his time for the FIU and does not participate or contribute to the role and functions of the RBF.

The FIU also maintains its organisational independence with following operational, the governance and administrative measures: 1.

Separate legislation, namely the FTR Act, establishing the FIU, its powers and functions; 4.

Strategic Plan outlining its vision, pillars and strategic goals; 5.
Annual Workplan and budget outlining its annual deliverables to meet its Strategic Plan and the required financial resources to meet these deliverables; 6.

IT resources to enable and support the FIU in the delivery of its functions; 7.

Networking with domestic and international partners on AML initiatives and projects; 8.

Member of the Egmont Group of global FIUs; 9.


Access to the Egmont Secure Web (ESW) which enables the FIU to securely exchange information with 165 other FIUs who are members of the Egmont Group; 10.

Case Management System to store and manage the FIU’s STR cases; 11.

Communication processes to enable the FIU to communicate effectively with its partners and the public; 12.

FIU database for receiving, storing and analysing from financial transaction reports financial institutions; 13.
Training of staff to ensure they are skilled and 2.

Fiji FIU corporate logo indicating is status as an qualified to carry out their functions; and independent government agency; 3.

Fiji FIU website to publish all FIU public information; 14.

Engagement in national committees to support national objectives that are linked to the FIU’s vision.
10 11 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 4 EXPENDITURE STATEMENT & NOTES The RBF continued to fund the operations of the FIU in 2020.

The FIU’s total expenditure for 2020 was $801,000 compared to $878,000 in 2019.

The expenditure of the FIU is incorporated into the financial statements of the RBF and is audited as part of its annual accounts.
The RBF also provided other administrative support services to the FIU in 2020 in the areas of human resource management, accounting, information technology services, security services and other general administrative services.
Fiji Financial Intelligence Unit Statement of Expenditure For the year ended 31 December 2020 Expenses Salaries & wages Meetings IT expense Consultancy Insurance Printing, publications & stationery Other expenses Total expenses Note 31 December 2020 31 December 2019 $ $ 746,000 748,000 4,000 16,000 19,000 7,000 5,000 4,000 73,000 16,000 22,000 10,000 5,000 4,000 801,000 878,000 The statement of expenditure has been audited up to 31 July 2020.
The figures from 1 August 2020 to 31 December 2020 will be audited as part of the financial statement of the RBF in 2021.

12 13 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Fiji Financial Intelligence Unit Notes For the year ended 31 December 2020 1.

Salaries & Wages The total staff costs amount to $746,000 (2019: $748,000) for the year ended 31 December 2020.
The staff costs capture the total remuneration paid to the employees of the Financial Intelligence Unit.

2.

Meetings Overseas Local 31 December 2020 31 December 2019 $ - 4,000 4,000 $ 67,000 6,000 73,000 Courses, meetings and seminars cover the costs of attending local and overseas courses, conferences, meetings and trainings.

The closure of country borders and the suspension of international flights has significantly reduced the current year’s expenditure.

3.
3.

IT Expense Licenses and maintenance Internet 31 December 2020 31 December 2019 $ 15,000 1,000 16,000 $ 12,000 4,000 16,000 The computer costs are for the annual maintenance and licensing costs for the Financial Intelligence Unit’s databases and the internet related charges.

4.

Consultancy The consultancy cost amount to $19,000 (2019: $22,000) for the year ended 31 December 2020.
The cost include the Financial Intelligence Unit’s databases subscription fees for intelligence gathering and membership to the Egmont Group.

5.

Insurance The insurance costs which amount to $7,000 (2019: $10,000) relate to the term life covers that is provided to the employees of the Financial Intelligence Unit.

6.
6.

Printing, Publications & Stationery Printing and Publication Public Relations 31 December 2020 31 December 2019 $ 1,000 4,000 5,000 $ 5,000 - 5,000 The printing, publications and stationery capture the cost of printing the Financial Intelligence Unit’s annual and border currency reports, publications and public relation materials.

7.
7.

Other Expenses Communication Advertising and General Expense 31 December 2020 31 December 2019 $ 2,000 2,000 4,000 $ 2,000 2,000 4,000 The other expenses amounted to $4,000 for the financial year ended 31 December 2020 (2019: $4,000).

12 13 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 5 OUR ACHIEVEMENTS A.
Receipt and Analysis of Financial Information A key function of the FIU is to analyse suspicious transaction reports and other financial transaction reports that it receives from financial institutions2, members of the public and other agencies in Fiji.

Highlights of financial transaction reports received by the FIU in 2020 are provided below.

The FIU also conducts strategic analysis of financial transaction reports received which is provided in the strategic analysis section of this Annual Report.
In 2020, the FIU received a total of 2,487,186 financial transaction and other reports.

These reports consisted of suspicious transaction reports (STR); cash transaction reports (CTR); electronic fund transfer reports (EFTR) and border currency reports (BCR).
Financial Transaction Reports Received 2016-2020 Year 2016 2017 2018 2019 2020 STR CTR 579 650 632 622 736 591,636 623,213 968,693 794,044 619,987 EFTR 1,148,711 1,220,602 1,357,246 1,515,681 1,866,197 BCR 547 792 969 1,102 266 1,741,473 1,845,257 2,327,540 2,311,449 2,487,186 145,123 153,771 193,962 192,621 207,266 TOTAL Monthly Total Average Source: Fiji FIU Financial Transaction Reports Received 2006-2020 EFTR 12,591,472 BCR 18,855,902 7,017 Total STR3 9,307 Suspicious Transaction Reports The FIU received 736 STRs4 in 2020 or an average of 61 STRs per month compared to 622 STRs reported in 2019.
Suspicious Transactions Reported 2016-2020 No.

of STRs 800 600 400 200 0 650 632 622 579 736 2016 2017 2018 2019 2020 Years Source: Fiji FIU Financial institutions are required under section 14 of the FTR Act, regulation 24 of the FTR Regulations and sections 1 and 2 of FIU Enforceable Guideline 1 to report suspicious transactions to the FIU.
A suspicious transaction is a transaction or attempted transaction which a financial institution has reasonable grounds to suspect may be related to a “serious offence, a money laundering offence or an offence of the financing of terrorism”.

Cash Transaction Reports The FIU received 619,987 CTRs in 2020 or an average of around 51,666 CTRs per month.

This is a decrease of 22 percent compared to 794,044 CTRs reported in 2019.
CTR 6,248,106 2 Financial institutions include designated non-financial businesses and professions.

3 Includes 1,145 STRs that were reported between 2000 – 2005 under section 61 of the Proceeds of Crime Act.

4 The number of STRs reported and the funds that are involved in suspicious transactions do not necessarily indicate the size of money laundering activity in Fiji.
However, these transactions have been subject to a greater level of scrutiny by reporting financial institutions and have been flagged and reported as questionable, unusual and suspicious transactions.

The figure suggests money laundering symptoms, risk and vulnerabilities in Fiji.

14 15 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Cash Transactions Reported 2016-2020 No.
of CTRs 1,200,000 1,000,000 800,000 600,000 400,000 200,000 0 968,693 794,044 591,636 623,213 619,987 2016 2017 2018 2019 2020 Years Source: Fiji FIU Financial institutions are required under section 13(1) of the FTR Act and regulation 25 of the FTR Regulations to report to the FIU any cash transaction of $10,000 and above or its equivalent in foreign currency.

Cash includes coin or paper money, bank drafts, bank cheques, bearer bonds, travelers cheques, postal notes and money orders.
Electronic Funds Transfer Reports The FIU received 1,866,197 EFTRs in 2020 or an average of around 155,516 per month.

This is an increase of 23 percent compared to 1,515,681 EFTRs reported in 2019.

The total EFTRs received in 2020 included 250,820 EFTRs in domestic remittances.

Electronic Funds Transfer Reported 2016-2020 No.


of EFTRs 2,000,000 1,866,197 1,600,000 1,515,681 1,220,602 1,357,246 1,200,000 1,148,711 800,000 400,000 0 2016 2017 2018 2019 2020 Years Source: Fiji FIU Commercial banks and remittance service providers (including mobile phone money remitters) are required under section 13(2) of the FTR Act and regulation 26 of the FTR Regulations to report to the FIU all international electronic fund transfer transactions.

There is no monetary threshold for EFTRs.


Border Currency Reports In 2020, the FIU received 266 BCRs.

This is a decrease of 76 percent compared to 1,102 BCRs received in 2019.

This decrease is due to COVID-19 travel restrictions which drastically reduced the number of travellers into and out of Fiji in 2020.

Border Currency Declarations 2016-2020 No.
of BCRs 1200 1000 800 600 400 200 0 969 1,102 792 547 266 2016 2017 2018 2019 2020 Years Source: Fiji FIU BCR Declarations by Direction of Travel 2016-2020 Persons Declaring Declarations made by inbound travellers Declarations made by outbound travellers TOTAL Source: Fiji FIU 2016 2017 2018 2019 2020 265 375 434 436 81 282 417 535 666 185 547 792 969 1,102 266 14 15 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 FIUs Reporting and Intelligence Development As required under section 25(1) of the FTR Act, the FIU is required to analyse and assess all reports and information that it receives, including information that is received from members of the public.
The FIU uses tactical analysis procedures as set out in its standard operating manual to analyse all STRs and develop intelligence of possible money laundering or other serious offences.

Other reports received by the FIU, such as, the CTRs and EFTRs, while not analysed in detail, provide critical information which is used to analyse STRs.

During 2020, the FIU continued to use Fiji FIU’s Information Management System Online (FFIMSO) in its intelligence processes.
The FIU uses its Alert and Monitoring System (AMS) which monitors all financial transaction reports maintained on the FFIMSO database for identifying suspicious transactions.

The FIU also undertakes data mining to analyse financial transaction data captured in the FFIMSO database.

The data mining process identifies links, relationships and patterns of suspicious financial activities.
The AMS and data mining process proactively identifies suspicious transactions and reports this to FIU analysts for their further analysis.

FFIMSO also consists of the Transaction Query System (TRAQ) which is the central repository for financial transaction reports reported to the FIU by financial institutions.
TRAQ enables the FIU staff to perform efficient profiling by utilising search tag features to obtain information regarding specific names, bank accounts, transaction dates, dollar amounts and other relevant transaction details.

The FIU launched its Case Management System (CMS) in February 2019.

CMS is a custom designed software that centrally stores all STR information, case analysis details and dissemination reports.
Analysts are able to raise queries directly through the system, conduct analysis and automatically generate case dissemination reports and link charts.

CMS also offers certain management functions, such as, review and approval of STR closures, generation of management reports and system audits for each STR.

BCRs are collected by FRCS at the border and sent to the FIU for data mining and analysis for possible currency smuggling, tax evasion, money laundering and related criminal offences.
FIU Enquiries with Financial Institutions As part of its analysis process, the FIU makes enquiries with financial institutions.

The queries are aimed at developing further intelligence on information already provided in the STRs.

FIU queries may also be in relation to an ongoing investigation of money laundering and serious offences or proceeds of crime cases.

The FIU has powers to obtain information from financial institutions and DNBPs under sections 14(3), 25(1)(c), 25(1)(h) and 28 of the FTR Act.
In 2020, 645 queries for further information were made by FIU to commercial banks (91 percent) and other financial institutions (9 percent).

Monthly FIU Queries to Financial Institutions 2020 Commercial Banks Other Financial Institutions No.

of Queries 100 80 60 40 20 0 J F M A M J J Months A S O N D Source: Fiji FIU 16 17 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 FIU Queries to Financial Institutions (Excluding Commercial Banks) 2020 B.
Dissemination of Financial Intelligence No.

of Queries 25 20 15 10 5 0 Finance Companies Insurance & Superannuation Money Remittance Others Financial Institutions (excluding commercial banks) Source: Fiji FIU The queries sent to financial institutions included requests for: Intelligence Reports to Law Enforcement Agencies law Disseminating enforcement agencies is a core function of the FIU.
Financial intelligence enables our law enforcement partners to investigate predicate crimes, money laundering and terrorist financing activities.

intelligence financial to The FIU’s intelligence reports also provide profiling of suspected proceeds of crime and proceeds linked to tax evasion.

The FIU analyses suspicious transaction and other financial transaction information such as CTR, EFTR and BCR to develop intelligence.
1 customer transaction history 2 customer identification details 3 customer account details The results of the FIU’s analysis of STRs are disseminated to relevant law enforcement agencies in a case dissemination report (CDR).

6 follow up and clarification 5 customer transaction queries 4 copies of documents such as identification documents In 2020, 270 CDRs were referred to law enforcement agencies compared to 84 CDRs in 20195.
The CDRs were developed from reports of suspicious transactions received in 2020 and prior to 2020.

7 originator information enquiries 8 payment instrument (cheque) details 9 customer payment and asset details In 2020, the majority of the queries sent to financial institutions were for: (i) customer transaction history, (ii) customer identification details, and (iii) customer account details.

Case Dissemination Reports 2016-2020 No.


of CDRs 448 195 500 400 300 200 100 0 321 270 84 2016 2017 2018 2019 2020 Years Source: Fiji FIU 16 5 Due to strict confidentiality requirements, this annual report does not discuss details of cases currently being investigated as a result of the FIU’s intelligence.

Cases that involved proceeds of crime that were subject to monitoring, restraining, confiscation or forfeiture orders as a result of FIU’s intelligence are also not mentioned in this report.
Convictions of money laundering and proceeds of crime cases have been published as case studies and included in the FIU Strategic Analysis Report.
17 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Case Dissemination Reports to Law Enforcement Agencies 2016-2020 STRs Filed Away for Future Reference and Analysis 2016 - 2020 2016 2017 2018 2019 2020 83 310 193 44 128 Number of STRs Filed Away Source: Fiji FIU 2016 2017 2018 2019 2020 284 314 248 132 372 Law Enforcement Agency and Reason for Dissemination FRCS-Tax Division Possible violations under the Income Tax Act and VAT Act.
Fiji Police Force *including Transnational Crime Unit Possible violations under the Proceeds of Crime Act and serious offences under the Crimes Act and other relevant laws.

Immigration Department Possible violations under the Immigration Act and Passport Act.

FRCS-Customs Division Possible violations under the Customs Act.
58 84 62 8 67 5 2 8 0 10 12 7 14 7 5 Others6 37 45 44 25 60 Total 195 448 321 84 270 Source: Fiji FIU In 2020, 49 percent of the CDRs were disseminated to FRCS while 25 percent of CDRs were disseminated to the FPF.

Intelligence that is developed from a single STR is sent in some instances to more than one law enforcement agency as it may involve suspected violations of different laws.

After detailed analysis, the FIU also, filed away 372 STRs during 2020 compared to 132 STRs in 2019.
STRs are filed away for future intelligence references and analysis, intelligence gathering, the FIU is able to reasonably conclude that the transaction or information does not involve a money laundering offence or other serious offence.

if after analysis and Alert & Instruction Notices to Financial Institutions From time to time, the FIU may need to disseminate alerts or directives to financial institutions in relation to information it has received under the FTR Act.
The FIU issues Alert & Instruction Notices to financial institutions in order to protect the financial system from being used by adversely reported individuals and business entities.

An Alert & Instruction Notice contains information on adversely reported individuals and/or business entities that require enhanced due diligence and scrutiny by financial institutions.
Due to the sensitivity and confidentiality of the Alert & Instruction Notice, financial institutions are advised to circulate the Alert & Instruction Notices internally with caution.

There were 20 Alert & Instruction Notices issued by the FIU in 2020.
Alert & Instruction Notices Issued 2020 Issued To Details Date 9 January 31 January 25 February 26 February Alert Notice Number 1/2020 2/2020 3/2020 4/2020 Commercial Banks Commercial Banks Commercial Banks Money Remittance Service Provider 26 March 5/2020 Pharmaceutical Regulator Possible Advance Fee Fraud Surveillance on ATM facilities Possible Advance Fee Fraud Possible Advance Fee Fraud Possible Advance Fee Fraud 6 Other law enforcement agencies include FICAC (5), Foreign FIUs and law enforcement agencies (29) and Reserve Bank of Fiji (26).
18 19 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Issued To Details a law enforcement agency.

The FIU issued six such directives in 2020 to financial institutions.
Alert Notice Number 6/2020 7/2020 9/2020 All Commercial Banks and Money Remittance Service Providers All Commercial Banks and Money Remittance Service Providers All Commercial Banks and Money Remittance Service 10/2020 Land Transport Authority (LTA) 11/2020 Commercial Banks (x2) 12/2020 All Commercial Banks 13/2020 All Commercial Banks 14/2020 Commercial Bank 15/2020 All Commercial Banks 17/2020 Real Estate Agent 18/2020 Commercial Bank Date 25 March 17 April 21 May 21 May 15 June 9 June 30 June 15 June 30 June 17 July 10 August 24 August Commercial Bank (x3) All Commercial Banks and Money Remittance Service Providers All Commercial Banks 19/2020 11 September 20/2020 9 October 14 December Source: Fiji FIU 21/2020 23/2020 Law Firm Possible Covid-19 Related Online Scam Possible Advance Fee Fraud Possible LTA Impersonation Scam Possible LTA Impersonation Scam Enhanced Account Scrutiny Possible Advance Fee Fraud Possible Advance Fee Fraud Enhanced Account Scrutiny Possible LTA Impersonation Scam Enhanced Account Scrutiny Enhanced Account Scrutiny Enhanced Account Scrutiny Possible Advance Fee Fraud Cheque Washing Enhanced Account Scrutiny Directives to Financial Institutions The FIU has powers under section 25(1)(h) of the FTR Act to issue enforceable directives to financial institutions to take appropriate steps in relation to any information or report received by the FIU and to enforce compliance with the FTR Act or facilitate any investigation anticipated by the FIU or Directive Actions Taken Directive Actions FTR Act and Regulation Undertake enhanced due diligence on customers r20 FTR Regulations and s14 Enforceable Guideline 4 Ascertain the source, origin and legitimacy of funds s4(6) FTR Act, r20(2)(b) and r23 FTR Regulations Ascertain the nature of the customer's business and a comprehensive picture of the customer's transactions r18 FTR Regulations Ascertain the purpose, type, volume and value of funds s4(6) FTR Act, (r19 FTR Regulations Ascertain the ultimate destination of funds or part thereo Ascertain the ultimate beneficiary of funds or part thereof Ascertain any other party or third party associated or involved in the transaction s4(6) FTR Act and r19 FTR Regulations s4(7) FTR Act and r19 FTR Regulations r14 FTR Regulations and s.3 Enforceable Guideline 4 Monitoring of customer transactions s10 FTR Act and r17 FTR Regulations Retaining all relevant records s8 FTR Act and s7 Enforceable Guideline 4 Seeking written approval from the FIU before proceeding with any transaction s7(a) FTR Act, s19(3)(c) FTR Act and s8.1 Enforceable Guideline 4 In 2020, the FIU withdrew three directives that were previously issued.
The FIU also uses directives to temporarily suspend a transaction (not proceed any further with a transaction) until the financial institution satisfactorily performs all the necessary customer due diligence requirements provided under the FTR Act, FTR Regulations and FIU Enforceable Guidelines.

Section 7 of the FTR Act and regulation 19(3)(c) of the FTR Regulations requires financial institutions to “not proceed any further with a transaction” unless directed to do so in writing by the FIU.
18 19 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 The Alert & Instruction Notices and directives are enforceable instructions of the FIU and must be implemented by the financial institutions.

Investigative Assistance Provided to Law Enforcement Agencies The FIU provides assistance to law enforcement and regulatory agencies upon request.
The request for assistance from the law enforcement agencies are related to investigations of suspected money laundering activities and other predicate offences such as forgery and fraud, drug trafficking/dealing, human false trafficking, obtaining money by pretences, cybercrime, larceny and corruption.

The requests may also be related to investigations initiated by a CDR that was disseminated to a law enforcement agency.
FIU’s Intelligence Development Process RECEIPT The FIU receives financial information and other information from various reporting entities.

ANALYSIS Reports are analyzed by referring to various information sources to develop financial intelligence linked to suspected money laundering or serious criminal activities.

DISSEMINATION Financial intelligence is disseminated to relevant law enforcement authorities for their investigation.
DATA INFORMATION INTELLIGENCE FINANCIAL TRANSACTION REPORTS • Suspicious Transaction Report (STR) • Cash Transaction Report (CTR) • Electronic Funds Transfer Report (EFTR) Border Currency Report (BCR) E S A B A T A D U F I EXTERNAL DATABASES VOLUNTARY INFORMATION PUBLICLY AVAILABLE INFORMATION FOREIGN COUNTERPARTS Domestic Law Enforcement and Regulatory Agencies Other FIUs Foreign Law Enforcement and Regulatory Agencies Source: Fiji FIU In 2020, the FIU received 127 requests for assistance from local law enforcement agencies such as the FPF, FICAC, Department of Immigration and FRCS, compared to 222 requests in 2019.
Requests for Investigative Assistance 2020 Requesting Agency Number of Requests Number of Checks on Individuals Number of Checks on Entities FICAC Fiji Police Force 15 77 60 207 8 15 Requesting Agency Number of Requests Number of Checks on Individuals Number of Checks on Entities FRCS Immigration Department Others7 26 6 3 38 7 17 21 1 0 TOTAL 127 329 45 Source: Fiji FIU 7 Other requesting agencies include the Australian Federal Police, Fiji Competition & Consumer Commission and Office of the Solicitor General.
20 21 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 The FIU also assists law enforcement agencies in their own investigations by facilitating the process to trace and “temporarily suspend” funds that is suspected to be proceeds of crime and transacted or held within financial institutions to ensure that the funds are immediately secured while the formal investigations into the suspected criminal activity is underway.
Financial Institutions are directed by the FIU to perform enhanced due diligence of the customer, monitor transactions and identify source of funds.

Dissemination of Information to Foreign FIUs The FIU receives requests for information from foreign FIUs.

In 2020, the FIU received one request for information from a foreign FIU through the Egmont Secure Web (ESW) and other formal communication compared to 12 requests received in 2019.
The FIU sent six requests for information to foreign FIUs through ESW in 2020.
Information Exchanges with Other FIUs 2016-2020 Requests 2016 2017 2018 2019 2020 Made to Fiji FIU Made by Fiji FIU Source: Fiji FIU 11 7 25 10 13 10 12 5 1 6 Requests for Background Checks 2020 Requesting Agency Number of Requests Number of Checks on Individuals Number of Checks on Entities Fiji Dental Council iTaukei Affairs Board Mineral Resources Department Office of the Attorney General Investment Fiji Fiji Pharmaceutical and Biomedical Services Ministry of Economy Ministry of Local Government Ministry of Commerce, Trade, Tourism & Transport FRCS REALB Registrar of Companies RBF TOTAL Source: Fiji FIU Due Diligence The FIU conducts background and due diligence checks on individuals and entities upon a request made in writing from a Government department or authority as provided under section 25.1(m) of the FTR Act.
Requesting agencies are required to fill out the FIU request form and provide relevant details on the individuals and businesses that are under scrutiny and evaluation.

In 2020, the FIU received 70 requests for background and credibility checks compared to 89 requests received in 2019.

The checks were conducted on 114 individuals and 90 entities.
C. Supporting and Supervising Financial Institutions The FIU promotes a “risk-based” approach to implementing the FTR Act and provides guidance to financial institutions to comply through issuance of policies and providing training.

The requirements in the FTR Act, commonly referred to as “preventive measures” are based on international AML/CFT standards, the FATF Recommendations.
Entities and businesses that are required to comply with the requirements of the FTR Act include: 20 21 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 i. financial institutions such as, commercial banks, insurance companies and intermediaries, finance companies, money remitters, money changers, investment advisors, brokers and dealers, unit trust or managed funds, mobile phone money remitters ; and ii.
other DNFBPs, such as, accounting firms, law firms, real estate agents or businesses.

All entities and businesses that are covered by the FTR Act are referred to as “financial institutions” under the law.

Identification and Verification to reflect the repeal of the Business Licence Act 1976 on 31 July 2020.

Under these changes, financial institutions are no longer required to rely on a business license as an identification document for business customers.
In 2020, the FIU also reviewed and revised Enforceable Guideline 1 on Suspicious Transactions for issue in early 2021.

The revised Guideline 1 seeks to provide further requirements and guidance to financial institutions on their obligations to identify and report suspicious transactions.
Financial Institutions under the FTR Act Commercial Banks Real Estate Agents Finance & Credit Companies Lawyers Accountants Mobile Phone Money Remitters Financial Institutions Superannuation Fund Source: Fiji FIU Insurers and Insurance Brokers Foreign Exchange Dealers and Money Remitters Stock Exchange Money Changers Investment Advisers, Brokers and Dealers, Investment Fund AML Guidelines and Policy Advisories In 2020, the FIU continued to provide financial the institutions with advice and guidance on requirements under the FTR Act and Regulations.
The FIU provides advisories and guidelines aimed institutions gain a better at helping financial understanding of their obligations.
During 2020, the FIU issued one Policy Advisory and revised Enforceable Guideline 4 on Customer Policy Advisory Issued by FIU in 2020 Policy Advisory Date Issued Removal of Business License Requirement under the FTR Regulations 11 September 2020 Purpose of Policy Advisory is The purpose of this to Policy Advisory provide further guidance and clarification on the removal of the business licence certificate from the customer due diligence requirement under FTR Regulations.
Appendix 1 lists the Enforceable Guidelines issued by the FIU and RBF to date.

The Enforceable Guidelines provide detailed guidance on the requirements under the FTR Act relating to suspicious transaction reporting, cash transaction reporting and customer identification and verification.

Appendix 2 lists the Policy Advisories issued to date by the FIU.

These Policy Advisories address very specific issues relating to the FTR Act.
The FIU also provides policy advice on an ad-hoc basis, as and when requested by financial institutions.

In 2020, the FIU issued 74 ad-hoc policy advisories explaining various requirements of the FTR Act and Regulations.

To ensure consistent application and understanding of FTR requirements across all the covered financial institutions, the FIU disseminates its policy advisories to all the institutions.
22 23 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Ad-hoc Policy Advisories Issued by FIU in 2020 Nature of Advisory Number of Ad-hoc Advisories Issued Customer Due Diligence Requirements Transaction Reporting Requirements Other Issues (FIU Alert Notices, role of compliance officer, AML developments) TOTAL Source: Fiji FIU 28 31 15 74 requirements.
The Review of the Cash Transaction Reporting Requirements In 2020, the FIU commenced a scoping exercise in preparation for the review of the cash transaction reporting review explores expanding the definition of cash under the FTR Act and decreasing the current cash transaction reporting threshold.

The aim of the review is to simplify the current CTR reporting obligation that captures cash as well as certain non-cash transactions.

Any transaction of certain lower threshold will thus become reportable.
This review will continue in 2021.

AML Compliance Officers Forum The FIU continued to engage with the AML Compliance Officers of the various financial institutions during the year.

These forums provided a platform for the FIU to update the AML Compliance Officers on new regulatory developments and money laundering trends and to clarify policy requirements.

The FIU held two interactive forums for AML Compliance Officers during the year.
AML Compliance Officers Forum Date AML Forum Program 13 February 2020 The AML Forum program was focused on the obligations and requirements of the AML Compliance Officers under the FTR Act and Regulations.

The sectors covered in these forums included the commercial banks, finance companies, restricted money remitters, real estate agents, lawyers, accountants, insurance companies and brokers.
Date AML Forum Program The AML Forum program included: • a brief overview on to Enforceable Guideline 1 on suspicious transactions reporting; revisions the 28 October 2020 • quality reporting of STRs by the commercial banks; • feedback on the implementation of the FIU Alert & Instruction Notice; • a presentation from Office of the Director of Public Prosecution (ODPP) on restraining orders; and • a presentation from Fiji Independent Commission Against Corruption (FICAC) on real life scenario cases and experiences of FICAC collaborations with the FIU and the commercial banks.
The sector covered was the commercial banks.

Source: Fiji FIU Director FIU (far right) with the Commercial Banks AML Compliance Officers and FIU staff.

Ms Moira Konrote, Senior Legal Officer heading the Proceeds of Crime Taskforce, Office of the Director of Public Prosecutions (ODPP), speaking at the AML Forum.

Mr Frank Tora, Team Leader of Digital Forensic Unit, Fiji Independent Commission Against Corruption (FICAC), speaking at the AML Forum.
22 23 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 obligations under the FTR Act and Regulations, thus, brief AML trainings were conducted during the onsite examination by the examiners.

Upon completion of the compliance examination, the financial institutions are issued the final Compliance Reports.

The financial institutions have six months from the date of their reports to implement the recommendations given by the FIU.
The recommendations are also a directive for financial institutions to implement an “action plan” under Section 29(2) of the FTR Act.
Summary Findings for Onsite Compliance Examinations 2016 – 2020 Non-compliance Findings Number of Financial Institutions FTR Act and Regulations Breach No written AML/CFT Policy & Procedure in place • 10 law firms • 5 real estate agents • Section 21 of the FTR Act • Regulation 29 of the FTR Regulations Not performing CDD/ KYC on a risk-based approach • 7 law firms • 6 real estate agents • Regulation 3, 20 and 21 of the FTR Regulations Not maintaining minimum required records No indication of monitoring client transactions Suspicious transactions reporting • not aware of their obligations to report STR • possible STR not reported • not aware they must report attempted STRs • not able to identify red flag indicators for ML/ TF Cash transactions reporting • not aware of their obligations to report CTR • possible CTRs not reported • not aware bank cheques are reported as CTRs Lack of regular in-house AML training and awareness Source: Fiji FIU • 7 real estate agents • 8 law firms • 7 real estate agents • 1 accounting firm • Section 8 of the FTR Act • Section 10(1) of the FTR Act • Regulation 17 of the FTR Regulations • 10 law firms • 4 real estate agents • Section 14 of the FTR Act • Regulation 24 of the FTR Regulations • 8 law firms • 1 real estate agent (most REAs do not hold trust accounts) • 10 law firms • 5 real estate agents • 1 accounting firm • Section 13 of the FTR Act • Regulation 25 and 27 of the FTR Regulations • Section 21(1)b of the FTR Act • Regulation 33(3) of the FTR Regulations Commercial Banks AML Compliance Officers during the AML Forum.
During 2020, the FIU continued its engagement with the real estate and legal sectors to enhance industry level awareness and compliance.

The engagement was through one-on-one meetings and forums with AML Compliance Officers.

Supervision of Financial Institutions for Compliance with the FTR Act The FIU and RBF are required under the FTR Act to supervise and ensure that financial institutions comply with the FTR Act and Regulations.
AML/CFT Supervision Supervisor of Financial Institutions and Designated Non-Financial Businesses and Professions RBF FIU Finanial Institutions licensed by RBF under the following laws: 1.

Banking Act 2.

Exchange Control Act 3.

Companies Act 4.

Insurance Act Other financial institutions not under the supervision of the RBF: 1.

Accountants 2.

Lawyers 3.

Real Estate Agents 4.


Other Financial Institutions The FIU conducted onsite compliance examinations of two law firms and three real estate agents in 2020.

Overall, these businesses were not fully aware of their 24 25 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 The results of the assessments were shared with the management of the respective businesses with recommendations for further improvements in internal processes.
ii.

to encourage financial institutions to fully comply with the FTR Act, FTR Regulations and FIU instructions, guidelines and directives; and to deter any future non-compliance.

The FIU also continued with its off-site assessment and review of transaction reporting and record keeping obligations of financial institutions in Fiji.

The FIU relied on the onsite supervision programme of the RBF to assess the compliance of RBF licensed financial institutions with the FTR Act and Regulations.
The legal basis for applying enforcement action is provided under the FTR Act and FTR Regulations.

The penalties in the FTR Act apply to a financial institution and can be applied to natural and legal persons that breach the AML/CFT requirements.

Furthermore, an “officer” (including: director, officer, employee, agent or consultant) of a financial institution is also liable to the above penalties.
Enforcement A component of the FIU’s compliance function is to apply enforcement action where there has been a breach of the FTR Act by a financial institution.

Enforcement action is part of the FIU’s compliance strategy.

The objectives of an enforcement action are as follows: During 2020, the FIU reviewed its enforcement framework with the aim of better capturing the requirements of the FTR Act.

This work will continue into 2021.


The following enforcement actions were undertaken by the FIU in 2020: i. to bring about behavioural change within financial institutions their obligations under the FTR Act, FTR Regulations and FIU instructions, guidelines and directives; implement to 1.

In 2020, the FIU identified one commercial bank and two money remitters that breached the FIU Alert & Instruction Notice.
Breach of FIU Alert & Instruction Notice 2020 Financial Institution FIU Alert & Instruction Notice Breached Number of transactions in breach of the Alert & Instruction Notice Individuals to refrain from conducting transactions Enforcement Action Taken by FIU Commercial Bank X 5/2019 Money Remitter A 5/2019 7 5 Beneficiary (1) • Non-Compliance Letter issued • Meeting with Commercial Bank X Beneficiary (2) • Non-Compliance Letter issued • Meeting with Money Remitter A 24 25 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Financial Institution FIU Alert & Instruction Notice Breached Number of transactions in breach of the Alert & Instruction Notice Individuals to refrain from conducting transactions Enforcement Action Taken by FIU Money Remitter B 7/2020 Money Remitter B 7/2020 Source: Fiji FIU • Ordering Customer (1) • Beneficiary Customer (1) Beneficiary (1) 1 1 • Non-Compliance Letter issued (1st breach) • Non-Compliance Letter issued (2nd breach) • Meeting with Money Remitter B 2.
Financial institutions are required to report their CTRs and EFTRs within 5 working days from the date of transaction.

During 2020, there were 30 breaches of the five days transaction reporting requirement.

The FIU addressed these breaches by immediately issuing notifications to the respective financial institutions to rectify the breaches.

In all the cases, the financial institutions were able to rectify the breach within a reasonable time.
In 2020, only one money remitter was issued two formal non-compliance letters on their delay in EFTR reporting.

3.

As part of continuous data quality improvement, the FIU reviews the reports submitted by financial institutions to identify data quality issues and ensure that fields (especially mandatory fields) in the transaction reports are entered accurately.
The data quality issues, once identified by the FIU staff or AMS, are entered in a register and communicated immediately by the FIU to the relevant financial institution for its necessary action.

In 2020, the FIU identified 11 data quality issues which were communicated to and effectively resolved by the relevant financial institution.

Reporting Requirement Non-Compliance 2016 – 2020 Data Quality Issues Identified in 2020 Reporting Requirement Non- Compliance No.
of breaches of the 5 days reporting requirement No.
of formal non- compliance letters/ correspondences issued Source: Fiji FIU 2016 2017 2018 2019 2020 Financial Institution Data Quality Issues Noted Actions Taken Commercial Bank Incorrect information entered in a batch of EFTRs reported Issue was clarified - no amendments required 28 22 28 23 30 Commercial Bank EFTRs duplicated 8 8 8 2 2 Finance Company CTR incorrectly reported as a STR Duplicated EFTRs removed by FIU STR removed by FIU and Finance Company reported CTR as required 26 27 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Financial Institution Data Quality Issues Noted Actions Taken Commercial Bank Possible EFTR not reported EFTR reported by the Commercial Bank Finance Company Possible CTR not reported CTR reported by the Finance Company Commercial Bank Possible CTR not reported CTR reported by the Commercial Bank FX Dealer FX Dealer FX Dealer Mandatory reporting fields for EFTRs not completed Issue rectified by FIU and FX Dealer re-commenced reporting Mandatory reporting fields for EFTRs not completed Issue rectified by FIU and FX Dealer re-commenced reporting Incorrect information provided in STR reported STR rectified by FX Dealer Finance Company Incorrect information provided in CTR reported CTR rectified by FIU Mobile Phone Money Remitter Mandatory reporting fields for EFTRs not completed Source: Fiji FIU Ongoing – Mobile Phone Money Remitter to provide missing information for FIU to rectify 4.
A remittance service provider was referred to a law enforcement and regulatory agency for conducting financial transactions in breach of the Exchange Control Act and its condition of licence as an Authorised Foreign Exchange Dealer.

5.

The RBF, during its onsite examination of a money remittance service provider, identified material breaches of key requirements of the FTR Act and other related laws.
The RBF used its supervisory powers, in consultation with the FIU, to consider taking enforcement action on the money remittance service provider.

Engagement with the Reserve Bank of Fiji The FIU continued to work closely with the RBF in the supervision of RBF licensed financial institutions.

The FIU also joined the RBF during its AML/CFT compliance examinations of money remittance service providers and their sub-agents in Nadi, Lautoka, Labasa and Savusavu.
The FIU provided policy advice to RBF as and when needed on the AML/CFT compliance issues.

In 2020, the FIU provided a presentation to RBF on the proper implementation of FIU Policy Advisory 1/2019 on establishing source of funds.

Training and Awareness Programme for Financial Institutions In 2020, the FIU provided training and awareness presentations to various financial institutions which were attended by a total of 104 employees.
The training covered the financial institutions’ obligations under the FTR Act and Regulations.
26 27 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Trainings to Financial Institutions 2020 Sector Number of Employees Law Firms Real Estate Agents Accountants Commercial Banks TOTAL Source: Fiji FIU 42 30 7 25 104 D. Domestic Coordination and Engagement National AML Council The FIU continued to contribute to national AML/CFT coordination and networking through participation in various committees, working groups and taskforce.
This includes taking the lead role in work related to the Forfeited Assets Fund, APG Mutual Evaluation and the Follow-Up Reports for Fiji.

The FIU provides secretarial support for the National AML Council and its three AML Working Groups (Legal Working Group; Supervisors and Regulators Working Group; and Law Enforcement Working Group).

There was one meeting of the National AML Council in 2020.

It continued to progress key national outputs during the year.
Its work was also supported by the three AML Working Groups (Refer to section on National AML Council for more information).

The Director FIU is a member of the National AML Council and participated in the Council’s activities for 2020.

Other FIU staff also actively contributed to the work of the AML Working Groups.

The FIU provided high level updates to the Council on key issues such as the updates on Fiji’s compliance with the FATF Recommendations.
The FIU provided advice to the Council on measures needed to address the deficiencies raised in Fiji’s 2016 mutual evaluation report (MER) relating to transparency of companies’ beneficial owners, review of the non- profit organisation sector, financial sanctions relating to terrorist financing and proliferation financing and extradition.

The Council members also endorsed the commencement of the work on the new National AML Council Strategic Plan.
Engagement and Exchange of Information with Partner Agencies The FTR Act provides the FIU with the mandate to enter into MOAs with other agencies.

The MOAs allow the FIU to exchange information and enhance networking and cooperation with domestic partner agencies.

In 2020, the FIU signed a MOA for the exchange of information with Post Fiji Pte Limited.
The MOA will strengthen FIU’s profiling capabilities, by providing access to additional information, such as money order transactions and postal services data when conducting intelligence analysis.

The FIU is currently engaging with other agencies to enter into MOAs in 2021, including Interpol, Fiji National Provident Fund, iTaukei Land Trust Board and the Ministry of Lands.

Signing of MOA between FIU and Post Fiji Pte Limited.
From left, FIU Director, Razim Buksh and Chief Executive Officer, Post Fiji Pte Limited , Dr Anirudha Bansod.

28 29 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 The FIU has signed MOAs with 13 local partner agencies to date.

The FIU continued to engage with these partner agencies during 2020.

As part of these MOA arrangements, authorised officers from the FPF, FRCS, FICAC and RBF continued to have direct access to the FIU’s central database.
In 2020, there were 26 officers who had direct access to the FIU database.

The officers used this arrangement to obtain intelligence on persons or entities of interest who are subject to their investigations and profiling.

Officers from FRCS and the FPF continued to be seconded to the FIU in 2020 as provided under the MOA arrangement.

Two seconded officers were from FRCS and one officer was from the FPF.
Secondment Officers for 2020 from left: Pritika Sharma (FRCS - Tax), Salaseini Tawake (FRCS - Customs) and CPL Katoanga Lekai (FPF) MOAs with Domestic Partner Agencies Agency Date MOA Signed Type of MOA Immigration Department FRCS Fiji Police Force Investment Fiji Ministry of Justice 12 July 2007 Information exchange 28 November 2007 12 September 2014 (amendment) 24 January 2008 11 December 2014 (amendment) 13 June 2008 3 July 2008 Information exchange and secondment of two staff with the FIU Direct access to FIU database Information exchange and secondment of a staff with the FIU Direct access to FIU database Information exchange Information exchange Agency Land Transport Authority FICAC Joint Taskforce RBF/ FRCS/FIU Maritime Safety Authority of Fiji RBF Fijian Elections Office Real Estate Agents Licensing Board Post Fiji Pte Limited Source: Fiji FIU Date MOA Signed 5 October 2009 3 November 2009 Type of MOA Information exchange Information exchange 14 April 2010 Information exchange 16 August 2012 17 April 2014 11 August 2016 Information exchange Information exchange Information exchange 24 April 2017 Information exchange 19 March 2020 Information exchange Non-Profit Organisations Framework Non-Profit Organisations (NPO) provide support to the public and private sectors in order to improve living conditions, promote development, improve education and, more generally, encourage social progress.
However, the sector has vulnerabilities that increase its risk of exploitation for terrorist financing.

The FIU is coordinating the NPO sector review in Fiji with the APG and the Ministry of Justice.

The APG is supporting Fiji in this project to ensure Fiji’s compliance with FATF Recommendation 8 and Immediate Outcome 10.

This review will continue in 2021.


National Risk Assessment Countries are required to identify, assess and understand the money laundering (ML) and terrorist financing (TF) risks that they face.

This means that countries must undertake a national assessment of its ML and TF risks.

The details of this requirement are provided under the FATF Recommendation 1 and its Methodology.

Fiji conducted its first ever national risk assessment (NRA) in 2015.
Countries are also required to assess ML/TF risk on an “ongoing basis” and to keep the NRA up-to-date.

In 2020, there was a review of the ML threats component of the NRA of 2015.

This review will be finalised in 2021.

28 29 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 National Combined Law and Security Agencies The Director of the FIU is a member of the National Combined Law and Security Agencies (NCLASA) Committee.
NCLASA is Fiji’s national information sharing framework on security issues comprising approximately 38 agencies.

The NCLASA framework is to create an environment for information sharing and co-operation between members.

Unexplained Wealth Taskforce The FIU contributed to the work of the Taskforce during 2020.

The Taskforce is made up of representatives from the FIU, FPF, FRCS and FICAC.

The objective of the Taskforce is to enable member agencies to network and collaborate on cases of unexplained wealth.
Cyber Security Working Group The FIU is part of Fiji’s national cyber security working group on technical, legal and security issues.

The FIU contributed to the discussions of the Working Group during 2020.

Counter Terrorism Officials Working Group The FIU is a member of the Counter Terrorism Officials Working Group (CTOG), a national Working Group which is responsible for developing and implementing Fiji’s counter terrorism strategy.
Human Trafficking National Action Plan Taskforce The FIU is part of the Human Trafficking National Action Plan Taskforce that contributed to the National Plan of Action To Eradicate Trafficking in Persons & Child Trafficking document which was endorsed by the Fiji’s National Security and Defence Council in 2020.

The FIU’s role include receiving, analysing and detecting reports of transactions possibly linked to human trafficking.
Fijian National Identity Card (FNIC) Taskforce The FNIC Taskforce was endorsed by cabinet in October 2019 to provide input for the review of the Fijian national identification (ID) management strategy, requirements for a national ID and possible solutions.

The FIU advised the Taskforce on the identification and verification requirements under the FTR Act.

The FIU contributed to the meetings of the FNIC Taskforce in 2020.
Training and Awareness Programs for Law Enforcement Agencies The FIU provides training and awareness briefings to law enforcement agencies on money laundering and the role and functions of the FIU.

E. International Engagement and Contribution Fiji Mutual Evaluation - Progress Update Fiji’s mutual evaluation report (MER) was tabled at the 2016 APG Annual Meeting and identified key gaps and deficiencies for Fiji to address.
The MER noted that Fiji had 23 non-compliant/partially compliant ratings with the FATF 40 Recommendations and 11 low or moderate levels of effectiveness on the 11 Immediate Outcomes on effectiveness.

Fiji submitted its first and second Follow-Up Report (FUR) in January 2017 and 2018.

Its third FUR was submitted in January 2019 and fourth FUR in October 2020.

Fiji’s fourth FUR did not seek any re-rating.

Fiji is in the process of addressing the remaining deficiencies in the FATF Recommendations.
Since submissions of the four FURs (2017, 2018, 2019 and 2020), the APG has upgraded Fiji’s compliance ratings for 17 FATF Recommendations to a “largely compliant” or “compliant” ratings (from either a non-compliant or partially compliant rating).
30 31 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Fiji’s Technical Compliance Ratings: APG MER and FURs 2016 - 2020 Rating MER 2016 Ratings Upgraded in 2017 Ratings Upgraded in 2018 Ratings Upgraded in 2019 Current Rating as at end 2020 Rec.
Description 1 Assessing Risks & Applying a Risk Based Approach 7 6 2 National Co-operation & Co-ordination 3 ML Offence 4 Confiscation & Provisional Measures 5 Financial Institutions Secrecy Laws Terrorist Financing Offence Targeted Financial Sanctions related to Terrorist Financing Targeted Financial Sanctions related to Proliferation Financing 8 Non Profit Organisations 9 10 Customer Due Diligence 11 Record Keeping 12 Politically Exposed Persons 13 Correspondent Banking 14 Money or Value Transfer Services 15 New Technologies 16 Wire Transfers 17 Reliance on Third Parties 18 Internal Controls 19 High Risk Countries 20 Reporting of Suspicious Transactions Tipping Off and Confidentiality 21 Designated Non-Financial Businesses and Professions (DNFBP) 23 DNFBP- Other Measures 22 24 25 26 Transparency and Beneficial Ownership of Legal Persons Transparency and Beneficial Ownership of Legal Arrangements Regulation and Supervision of Financial Institutions 27 Powers of Supervisors 28 Regulation and Supervision of DNFPBs 29 LC C PC PC LC C LC LC LC PC PC LC C PC NC NC PC C PC PC PC C C PC PC PC PC NC LC LC NC PC PC PC LC LC PC C C 31 30 FIU Responsibilities of Law Enforcement & Investigative Authorities Powers of Law Enforcement & Investigative Authorities 32 Cash Couriers 33 Statistics 34 Guidance and Feedback 35 Sanctions 36 International Instruments 37 Mutual Legal Assistance 38 MLA Freezing and Confiscation 39 Extradition 40 Other Forms of International Cooperation Key: C: Compliant LC: Largely Compliant PC: Partially Compliant NC: Not Compliant LC PC LC PC PC LC C PC LC LC LC LC C C C LC LC LC LC C LC LC LC C C PC PC PC C LC C C C C C LC LC LC C LC LC LC LC PC PC LC LC LC C C LC LC C LC LC LC LC C PC LC 30 31 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Fiji’s Effectiveness Ratings: APG MER 2016 Immediate Outcomes IO - 1 Risk, policy and coordination Moderate IO - 2 International cooperation Moderate IO - 3 Supervision Moderate IO - 4 Preventive measures
 Moderate IO - 5 Legal persons and arrangements Low IO - 6 Financial intelligence Moderate IO - 7 ML investigation & prosecution Moderate IO - 8 Confiscation Low IO - 9 TF investigation & prosecution Low IO - 10 TF preventive measures & financial sanctions Low IO - 11 PF financial sanctions Low Key: High level: IO is achieved to a very large extent; Minor improvements needed Substantial level: IO is achieved to a large extent; Moderate improvements needed Moderate level: IO is achieved to a large extent; Moderate improvements needed Low level: IO is not achieved or achieved to a negligible extent; Fundamental improvements needed Source: Fiji FIU Rating MER 2016 Moderate Moderate Moderate Moderate Low Moderate Moderate Low Low Low Low Asia Pacific Group on Money Laundering Fiji is a member of the APG, an autonomous collaborative and international organisation currently comprising of 41 member countries.
The FIU, as the designated lead agency for Fiji, liaised closely with the APG in 2020 on various national outputs, APG governance and other policy and mutual evaluation matters including the submission of the 4th Follow-Up Report.

During 2020, the FIU participated in the following key APG activities: i. liaised with APG on Fiji’s NPO Sector Review; ii.

contributed the APG mutual evaluation programme by participating as an assessor for to the mutual evaluation of another APG member; and iii.
participated in various APG surveys and contributed to discussion papers; iv.

Mutual Evaluation Committee; and v. Ad-Hoc Strategic Review Committee.

The FIU continued to liaise with the APG on various AML/CFT issues relevant to Fiji during the year.

Memorandum of Agreements with Foreign FIUs The FIU may enter into MOAs with foreign FIUs or law enforcement agencies for the exchange investigation or of prosecution of a money laundering offence, terrorist financing offence or any other serious offence.
The FIU has signed MOAs with 29 foreign FIUs to date.
information relevant to the 32 33 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 MOA with Foreign FIUs Agency Name of FIU Date Australia Australian Transactions Reports and Analysis Centre 19 May 2011 Bangladesh Financial Intelligence Unit 9 June 2015 Belgium Financial Intelligence Unit 3 September 2012 Brazil Council for Financial Activities Control 3 July 2013 Cambodia Cambodia FIU 5 December 2017 Canada Financial Transactions and Reports Analysis Centre of Canada 12 July 2011 Cook Islands Cook Islands FIU 21 July 2011 France The Unit for Intelligence Processing and Action Against Illicit Financial Networks 12 July 2011 Agency Name of FIU Date Republic of China (Taiwan) Republic of Marshall Islands Russia Thailand United Kingdom United States of America Anti-Money Laundering Division, Investigation Bureau, Ministry of Justice 10 July 2012 Banking Commission- Financial Intelligence Unit 24 July 2017 Federal Financial Monitoring Service (Russian Federation) The AML Office of the Kingdom of Thailand The Serious Organised Crime Agency United Kingdom FIU The Financial Crimes Enforcement Network 28 June 2013 25 October 2011 12 July 2011 5 June 2014 (Amendment) 12 July 2011 Vanuatu Vanuatu FIU 8 March 2013 India India FIU 5 June 2014 Source: Fiji FIU Indonesia Israel Japan Korea Lebanon Macau SAR China Malaysia Papua New Guinea Philippines Indonesian Financial Transaction Reports and Analysis Center Israel Money Laundering Prohibition Authority Financial Intelligence Centre Korea FIU Special Investigation Commission Financial Intelligence Office Unit Perisikan Kewangan, Bank Negara Malaysia 10 July 2009 6 February 2013 9 June 2015 6 May 2011 5 June 2014 6 and 13 March 2012 3 February 2010 Papua New Guinea FIU 29 January 2018 The Anti-Money Laundering Council, The Financial Intelligence Unit of the Republic of the Philippines 13 July 2011 Samoa Samoa FIU 8 March 2013 Solomon Islands South Africa Sri Lanka Solomon Islands FIU 12 July 2011 Financial Intelligence Centre Financial Intelligence Unit of Central Bank of Sri Lanka 11 July 2012 21 July 2011 Association of Pacific Island FIUs The FIU is a member of the Association of Pacific Island FIUs (APIFIU).
APIFIU was established in 2011 and currently has 12 FIUs as its members namely the FIUs of Cook Islands, Fiji, Nauru, Niue, Palau, Papua New Guinea, Republic of Marshall Islands, Samoa, Solomon Islands, Tonga, Vanuatu and Kiribati.

The FIU also provided advice during the year to regional FIUs on various aspects of Fiji’s AML/CFT framework.

Egmont Group The Fiji FIU is a member of the Egmont Group of FIUs.

The Fiji FIU continued to participate in the activities of the Egmont Group during 2020.
This included contributing to Egmont surveys conducted during the year, reviewing and providing comments on Egmont governance papers, projects and questionnaires.

As a member of the Egmont Group of FIUs, the Fiji FIU is committed to sharing information with 165 32 33 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 other Egmont Group members.
During 2020, the Fiji FIU continued to provide assistance and information to other Egmont Group members upon request via the ESW.

The Fiji FIU fully complies with the Egmont Group key governance instruments, namely the: 1.

Egmont Charter; 2.

Operational Guidance; 3.

Principles of Information Exchange; and 4.

Support and Compliance Process.

The Fiji FIU is also a member of the Egmont Group’s Membership, Support, and Compliance Working Group (MSCWG) and Asia and Pacific Regional Group (APRG).
Inclusion Alliance for Financial Inclusion The FIU is a member Alliance of the for Financial (AFI) Global Standards Proportionality Working Group (GSPWG).

The aim of GSPWG is to provide a platform to facilitate peer learning on issues policymakers and regulators face in achieving a balance between financial inclusion, integrity and stability, and to examine the proportionate implementation of the standards set by global standard setting bodies.
The FIU participated in the virtual meetings of the GSPWG during the year.

The Fiji FIU was the co-chair of the GSPWG in 2020.

During the year, the GSPWG worked on knowledge products and organised technical webinars for members.

In 2020 the GSPWG completed and launched a the risk-based implementation of AML/CFT requirements.

This toolkit is aimed for use by policymakers.

to support toolkit AUSTRAC AUSTRAC is Australia’s FIU.
In 2020, the FIU continued to benefit from its engagement with AUSTRAC through sharing of AML/CTF information and intelligence.

AUSTRAC also provided the FIU with AML/CTF technical assistance and training.
Technical Assistance and Training provided by AUSTRAC 2020 Technical Assistance/ Training Status AUSTRAC/Refinitiv webinar on World Check Tips and Tricks Completed Pacific AML/CFT Webinar Series Completed FIU Regional Forum collaboration Ongoing IT system solution Source: Fiji FIU Ongoing Source: Egmont Group 34 35 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 6 OPERATIONAL GOVERNANCE AND COMMUNICATION Professional Development of Staff Due to the Covid-19 pandemic restrictions, meetings and workshops were conducted virtually in 2020.
FIU also provided on-the-job training to new secondment staff from FRCS and the FPF who joined the FIU during the year as part of the secondment rotation programme.

b. the reporting of FIU performance and operations to the Governor; c. d. the need to remove any misperceptions on the RBF’s role in the operations of the FIU; and further strengthening independence of the FIU.
the autonomy and Trainings, Meetings and Conventions 2020 Month Course Venue Organiser In 2020, FIU’s internal governance arrangements were revised to include the following measures: February August Multinational Communications Interoperability Program (MCIP) Cyber Services, Cyber Training STI Webinar on Combatting Money Laundering and Terrorism Financing During the Pandemic AUSTRAC/Refinitiv webinar on World Check Tips and Tricks Suva, Fiji Suva, Fiji Republic of Fiji Military Forces (RFMF) and US Indo Pacific Command The IMF – Singapore Regional Training Institute (STI) Suva, Fiji AUSTRAC December Pacific AML/CFT Webinar Series Suva, Fiji Source: Fiji FIU AUSTRAC, ANZ and the Asian Development Bank Governance The FIU continued to provide monthly reports on its operations to the Governor of the RBF and the Chairman of the National AML Council.
The FIU also provided regular updates to the National AML Council on key AML/CFT national initiatives and projects.

In 2019 and early 2020, the RBF commenced a review of the governance arrangements between the RBF and FIU.

In particular this review looked at: a. the role of the Director FIU in RBF Executive Management Committees; a.
The Director FIU ceased to be a member of the RBF Executive Management and membership of all related Executive Management Committees and no longer contribute to RBF executive and policy decisions; b.
The Director FIU reports directly to the Governor; c. The FIU AML section has been excluded from the RBF Annual Report, and from other RBF publications; d. The FIU will continue to be funded by the RBF under a separate budget approved by the RBF Board; e. The FIU has reverted to using its own official logo and no longer uses the joint RBF logo; f. The FIU will set-up its own IT infrastructure in 2021/2022 that will be fully autonomous and independent from RBF, including the use of @fijifiu.gov.fj email domain; and g. Other corporate measures, such as, separate uniform for FIU staff.
Communication The FIU uses the media and its website to communicate key AML/CFT initiatives to the general public.

In 2020, the FIU issued three press releases (Refer to Appendix 3).

34 35 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Summary of Press Releases 2020 Press Release No.
Date Issued 08/2020 19 March 2020 The Financial Intelligence Unit Signs Memorandum Of Understanding With Post Fiji Pte Limited 12/2020 27 March 2020 Covid-19 Related Online Scam The FIU engaged two project officers to assist in the FIU data migration and digitisation project.

The FIU also engaged a temporary worker as part of the RBF’s and National Employment Centre attachment programme.
Governance Structure 2020 4 September 2020 Fiji Financial Unit Annual Report 2019 Intelligence Attorney General & Minister for Justice Governance 01/2020 Source: Fiji FIU Director Financial Intelligence Unit Functional Operations Financial Intelligence Unit National AML Council Advisory Governor Reserve Bank of Fiji Governance Board Reserve Bank of Fiji Budget Staffing As at the end of 2020, the FIU had nine permanent staff and three officers on secondment from partner agencies (one FPF officer and two FRCS officers).
FIU Organisation Structure 2020 Intelligence Analyst.

Seconded from FPF Intelligence Analysts.

Seconded from FRCS (Customs) Intelligence Analysts.
Seconded from FRCS (Tax) Intelligence Analyst Intelligence Analyst Policy & Compliance Analyst Manager Intelligence Management Intelligence Management Division Manager Policy & Compliance Policy & Compliance Division Manager IT Management (vacant) Director FIU IT Management Division Administration Senior Systems Analyst Systems Analyst Senior Secretary HR and Other Support (Provided by RBF) 36 37 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Other Assistance Provided to the FIU The FIU received indirect funding assistance from FRCS and the FPF through the secondment of their staff with the FIU in 2020.
The salaries of the seconded officers were fully funded by their respective agencies.

Fiji FIU’s Information Management System Online [FFIMSO] FFIMSO consists of two online web application systems, namely Online Data Delivery System (ODDS) and TRAQ.

ODDS is used by financial institutions to securely report financial transaction reports online.

TRAQ is used by FIU staff and direct data access (DDA) officers for search, analysis and profiling purposes.
Financial institutions continued to use ODDS to report their transactions (STR; CTR; EFTR) electronically to the FIU.

As at the end of 2020, 142 financial institutions had registered on FFIMSO.

FFIMSO received an average of 207,266 financial transaction reports per month in 2020.

At the end of 2020, the FFIMSO database received over 18.85 million financial transaction reports from financial institutions since on-line reporting commenced in 2008.
ODDS was accessed by 106 authorised users, 5,917 times during 2020.

TRAQ was accessed by 13 FIU officers, 1,527 times; and 26 direct database access officers, 157 times during 2020.

There were a total of 192 authorised users of FFIMSO (ODDS and TRAQ users) at the end of 2020.

FIU Case Management System [CMS] FIU has an online case management system for managing suspicious transaction reports and its analysis.
The system can automatically generate case dissemination reports and link charts and centrally stores all the cases in its database.

FFIMSO Registration Sector Commercial Banks Foreign Exchange Dealers & Money Remitters Mobile Phone Money Remitters Finance Companies Law Firms Insurance & Superannuation Accounting Firms Securities and Brokers Real Estate Agents Money Lenders Others TOTAL Source: Fiji FIU No.
of Reporting Entities Registered for Online Reporting to the FIU CMS Work Flow 6 10 2 12 49 12 11 3 26 1 10 142 Upload • STRs uploaded to CMS • STR notification received by Manager Intelligence Management (MIM) on new STRs • MIM assigns STRs to Intel analysts through CMS • Analysts receive assigned STRs notification via email Assign Analysis • Searches done on internal and external database • Queries are sent to compliance officers via CMS • Results collated and data entry is done on CMS • Links charts and case dissemination reports are automatically generated based on data entered • Analyst send their cases to MIM for review • MIM can request analyst for amendments or forward the case to DFIU for approval via CMS • Results collated and data entry is done for CMS • DFIU will approve the case for further amendments or Dissemination or File Away Approval Dissemination • Analyst selects the relevant law enforcement authorities for the dissemination of financial intelligence on CMS • Dissemination through email, fax, courier or hand delivery • Users can generate reports automatically • Data analysis • Audits • Management reporting Reports 36 37 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 FIU Response to Covid-19 Pandemic The FIU was able to manage its core operations by deploying a Work-From-Home (WFH) process.
FIU staff were provided with laptops and access to work from home during the lockdown period.

There were also continuous communication between staff via emails and the staff Viber group during the lockdown period.

The 2020 global pandemic and the Fijian Government’s efforts to ensure the safety and wellbeing of Fijians including the lockdown and closure of the borders, also tested FIU’s operational resilience and business continuity measures.
After the nation lockdown was lifted, the FIU continued to follow all the health and safety measures of the Fijian health authorities.

In particular, the FIU strictly followed the use of hand sanitisers, face masks and social distancing restrictions, attending virtual meetings, workshops and organised AML forums with a limited number of participants.

Understanding the circumstances faced by financial institutions, the FIU released Circular No: FIU 14/2020 on 30 March 2020.
The circular acknowledged the difficulties that financial institutions may have encountered and advised them to contact the FIU for delays or disruptions in their reporting.

The FIU also contributed to the Fijian Government’s initial effort on contact tracing.

38 39 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 7 STRATEGIC PLAN 2020 – 2024 The FIU has rolled out its 5-year Strategic Plan for 2020 – 2024.
The Strategic Plan outlines the vision “Protecting Fiji from Money Laundering” and five key strategic pillars that will guide the FIU to achieve its overall vision for the next five years.
The five strategic pillars that support the vision are: Financial Intelligence Our People FIU Strategic Pillars Preventive Measures Partnerships Technology Driven Processes These pillars are linked to the statutory functions of the FIU under the FTR Act and also reflect priorities that are considered vital to achieve its vision.

The ambitious vision would bring many continuing and new challenges in the next five years for the FIU.

The Strategic Plan addresses these challenges.


The lessons learnt and efforts made by the FIU since it was established in 2006 will also help overcome these challenges.

The FIU will rely on its partner agencies from the Fijian Government, law enforcement and regulatory authorities, its regional and international counterpart agencies, as well as the private sector stakeholders to fulfil the vision of “Protecting Fiji from Money Laundering”.
In formulating the Strategic Plan, the FIU had reflected on continuous feedback from the following key stakeholders: The National AML Council; Law Enforcement Partner Agencies; The Board, Governors and Executive Management of the RBF; Office of the DPP; Ministry of Justice; Financial Institutions and Designated Non-Financial Businesses and Professions; The Egmont Group and the APG; and Parliamentary Standing Committee 38 39 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 2020-2024 Our Vision, Pillars, Strategies and Action Plan Our Vision: Protecting Fiji from Money Laundering i) Financial Intelligence 1.
Develop and disseminate quality intelligence products for our stakeholders.

1.1 Continue to strengthen our tactical analysis framework.

1.2 Disseminate quality financial intelligence to our partners on a timely basis.

2.

Improve the quality and use of our intelligence products.

2.1 Improve our understanding of the needs of our law enforcement partners.

2.2 Improve our data analysis capability to meet the needs of our partners.
2.3 Provide regular feedback to financial institutions on outcomes of reports of suspicious transactions.

3.

Promote the understanding of money laundering risks and methods in Fiji.

3.1 Develop and implement an effective strategic analysis framework.

3.2 Disseminate quality strategic intelligence products for financial institutions and other stakeholders.

3.3 Contribute to the review of the assessment of Fiji’s money laundering and terrorist financing risks.

ii) Preventive Measures 4.


Promote a risk based implementation of the preventive measures under the Financial Transactions Reporting (FTR) Act.

4.1 Maintain an ongoing understanding of the money laundering risks by sectors and by entities.

4.2 Develop risk based AML/CFT policies and guidelines as needed.

4.3 Engage with the industry and other regulators to address any policy obstacle to a risk based approach implementation.

5.
5.

Enhance financial institutions and businesses understanding of their obligations under the FTR Act.

5.1 Provide timely guidance to financial institutions and businesses on the AML/CFT requirements.

5.2 Develop and issue relevant AML/CFT guidelines.

5.3 Continue to provide effective training and awareness to financial institutions and businesses on their AML/CFT obligations.

6.
6.

Effectively supervise financial institutions and businesses for compliance with the FTR Act and take appropriate enforcement action in case of non-compliance.

6.1 Continue to strengthen our compliance and enforcement framework.

6.2 Undertake risk based compliance supervision of financial institutions.

6.3 Collaborate with the RBF in the supervision of RBF licensed financial institutions.

6.4 Effectively and promptly deal with non-compliance by financial institutions and businesses.
40 41 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 iii) Technology Driven Processes 7.

Effective data reporting.

7.1 Review and revise, as appropriate, Fiji’s threshold reporting framework.

7.2 Explore real time central data integration.

7.3 Review and revise reporting forms to improve quality of data reported by financial institutions.

8.

Develop innovative data management systems and analytic tools.
8.1 Explore and implement a secure private network for remote access of FFIMSO by our partners.

8.2 Explore and develop new technology and mechanisms for secure and prompt dissemination of financial intelligence to our partners.

8.3 Modernise FIU’s data mining capabilities.

9.

Improve data quality and information security.

9.1 Implement data cleaning technology and processes within FFIMSO.

9.2 Continuously strengthen our information security framework.

iv) Partnerships 10.


Enhance our network for information sharing.

10.1 Enter into collaboration and information exchange agreements with new partners.

10.2 Continuously engage with partners for information exchange.

10.3 Strengthen existing partnerships.

11.

Strengthen relationships with domestic and international partners.

11.1 Support the work of the National AML Council as a member and secretariat.

11.2 Contribute to national policy making through our participation in inter-agency committees.
11.3 Represent Fiji and the FIU at international AML/CFT forums.

11.4 Provide technical assistance and training to our foreign counterparts and domestic partners.

12.

Provide support to international partners on AML/CFT initiatives and engagements.

12.1 Contribute to AML/CFT policy making at international level.

12.2 Support Egmont, APG, FATF and AFI initiatives and programs and contribute to planned projects.

v) Our People 13.

Cultivate a skilled, motivated and high performing team.
13.1 Provide opportunities for professional development and training to staff.

13.2 Ensure clear staff progression pathways.

13.3 Provide clear and regular feedback on staff performance.

14.

Ensure corporate governance through strong internal controls and performance reporting.

14.1 Provide timely and relevant performance reports on FIU operations to relevant stakeholders.

14.2 Comply with RBF requirements on governance reporting to the RBF Board.
14.3 Comply with relevant international standards on FIU operations.

40 41 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Pillar 1: Financial Intelligence We will produce high quality financial intelligence for our partners.

Our strategies to achieve this are: 1.

Develop and disseminate quality intelligence products for our stakeholders.

2.

Improve the quality and use of our intelligence products.

3.
3.

Promote the understanding of money laundering risks and methods in Fiji.

Our action plans under each strategy include: disseminate quality intelligence products for our stakeholders 11Develop and quality and use of our intelligence products 22 Improve the understanding of money laundering risks and methods in Fiji 33Promote the 1.1 Continue to strengthen our tactical analysis framework.

1.2 Disseminate quality financial intelligence to our partners on a timely basis.
2.1 Improve our 3.1 Develop and understanding of the needs of our law enforcement partners.

2.2 Improve our data analysis capability to meet the needs of our partners.

2.3 Provide regular feedback to financial institutions on outcomes of reports of suspicious transactions.

implement an effective strategic analysis framework.

3.2 Disseminate quality strategic intelligence products for financial institutions and other stakeholders.
3.3 Contribute to the review of the assessment of Fiji’s money laundering and terrorist financing risks.

42 43 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Pillar 2: Preventive Measures We will promote a safe and sound financial system to prevent or detect money laundering and terrorist financing activities.

Our strategies to achieve this are: 4.


Promote a risk based implementation of the preventive measures under the Financial Transactions Reporting (FTR) Act.

5.

Enhance financial institutions and businesses understanding of their obligations under the FTR Act.

6.

Effectively supervise financial institutions and businesses for compliance with the FTR Act and take appropriate enforcement action in case of non-compliance.
Our action plans under each strategy include: 44 Promote a risk based implementation of the preventive measures under the FTR Act Enhance financial institutions understanding of their obligations under the FTR Act 55 Effectively supervise financial institutions and take appropriate enforcement action 66 4.1 Maintain an ongoing understanding of the money laundering risks by sectors and by entities.

4.2 Develop risk based AML/CFT policies and guidelines as needed.
4.3 Engage with the industry and other regulators to address any policy obstacle to a risk based approach implementation.

5.1 Provide timely guidance to financial institutions and businesses on the AML/CFT requirements.

5.2 Develop and issue relevant AML/CFT Guidelines.

5.3 Continue to provide effective training and awareness to financial institutions and businesses on their AML/CFT obligations.

6.1 Continue to strengthen our compliance and enforcement framework.
6.2 Undertake risk based compliance supervision of financial institutions.

6.3 Collaborate with the RBF in the supervision of RBF licensed financial institutions.

6.4 Effectively and promptly deal with non-compliance by financial insitutions and businesses.

42 43 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Pillar 3: Technology Driven Processes We will implement technology driven processes in the performance of our functions.
Our strategies to achieve this are: 7.

Effective data reporting.

8.

Develop innovative data management systems and analytic tools.

9.

Improve data quality and information security.

Our action plans under each strategy include: reporting 77 Effective data innovative data systems and analytic tools 88 Develop quality and information security 99 Improve data 7.1 Review and revise, as appropriate, Fiji’s threshold reporting framework.

7.2 Explore real time central data integration.


7.3 Review and revise reporting forms to improve quality of data reported by financial institutions.

8.1 Explore and implement 9.1 Implement data cleansing technology and processes within FFIMSO.

9.2 Continuously strengthen our information security framework.

a secure private network for remote access of FFIMSO by our partners.
8.2 Explore and develop new technology and mechanisms for secure and prompt dissemination of financial intelligence to our partners.

8.3 Modernise FIU’s data mining capabilities.

44 45 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Pillar 4: Partnerships We will strengthen collaboration with our partners.

Our strategies to achieve this are: 10.

Enhance our network for information sharing.

11.


Strengthen relationships with domestic and international partners.

12.

Provide support to international partners on AML/CFT initiatives and engagements.
Our action plans under each strategy include: network for information sharing 1010 Enhance our 1111Strengthen our relationships with domestic and international 1212 Provide support to international partners on AML/CFT policy formulation and engagements 10.1 Enter into collaboration and information exchange agreements with new partners.

10.2 Continuously engage with partners for information exchange.

10.3 Strengthen existing partnerships.


11.1 Support the work of the National AML Council as a member and secretariat.

11.2 Contribute to national policy making through our participation in inter-agency committees.

11.3 Represent Fiji and the FIU at international AML/CFT forums.

11.4 Provide technical assistance and training to our foreign counterparts and domestic partners.

12.1 Contribute to AML/ CFT policy making at international level and implement relevant international standards.
12.2 Support Egmont, APG, FATF and AFI initiatives and programs and contribute to planned projects.

44 45 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Pillar 5: Our People We will enhance the potential of our people and our governance processes.

Our strategies to achieve this are: 13.

Cultivate a skilled, motivated and high performing team.

14.

Ensure corporate governance through strong internal controls and performance reporting.
Our action plans under each strategy include: Cultivate a skilled, motivated and high performing team 1313 1414 Ensure corporate governance through strong internal controls and performance reporting 13.1 Provide opportunities for professional development and training to staff.

13.2 Ensure clear staff progression pathways.

13.3 Provide clear and regular feedback on staff performance.

14.1 Provide timely and relevant performance reports on FIU operations to relevant stakeholders.
14.2 Comply with RBF requirements on governance reporting to the RBF Board.

14.3 Comply with relevant international standards on FIU operations.

46 47 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 8 NATIONAL AML COUNCIL The National AML Council is established under Section 35 of the FTR Act and is Fiji’s national AML/ CFT coordination committee.

v. Chief Executive Officer of the FRCS; and vi.

Director of the FIU.


The vision of the National AML Council is “an effective and efficient legal system and institutions to prevent and detect money laundering, terrorist financing and other serious financial crimes in Fiji.” The Council may invite other persons to attend the Council meetings.

There are five invited members of the Council.


These are: • Permanent Secretary, Ministry of Foreign Affairs; The Council’s missions are to: • Permanent Secretary, Ministry of Economy; i. provide sound and timely advice to the Minister and other relevant stakeholders on the prevention of money laundering and terrorism financing; ii.

promote a strong legal and institutional AML/ CFT framework; and iii.

facilitate networking and cooperation amongst relevant stakeholders.
The Council seeks to achieve these missions by: i. providing sound and timely advice to the Minister and other government agencies on policy and regulatory AML/CFT matters; ii.

promoting a strong legal, policy and institutional framework to comply with international AML/ CFT standards and best practices; iii.

supporting institutions in their efforts to combat money laundering and terrorist financing; iv.
encouraging and facilitating networking and cooperation between agencies; and v. providing advice to the FIU on AML/CFT issues.

The members of the National AML Council are: i.

Permanent Secretary for the Ministry for Justice, as Chairperson; ii.

Director of the ODPP; iii.

Commissioner of Police; iv.

Governor of the RBF; 8 As at the date of finalising this Annual Report.

9 As at the date of finalising this Annual Report.


• Permanent Secretary, Ministry of Defence, National Security and Policing; • Deputy Commissioner, FICAC; and • Director, Immigration Department.

The FIU is the secretariat to the Council.
National AML Council Members 2020 National AML Council Invited Members 2020 Yogesh Karan Acting Permanent Secretary Ministry of Foreign Affairs Makereta Konrote9 Permanent Secretary Ministry of Economy Manasa Lesuma Permanent Secretary Ministry of Defence and National Security and Policing Rashmi Aslam Deputy Commissioner Fiji Independent Commission Against Corruption Amelia Kotobalavu Komaisavai Acting Director Immigration Department Sharvada Sharma Solicitor-General and Permanent Secretary Ministry of Justice Christopher Pryde Director Office of the Director of Public Prosecutions Rusiate Tudravu Acting Commissioner Fiji Police Force Ariff Ali Governor Reserve Bank of Fiji Jonetani Vuto8 Acting Chief Executive Officer Fiji Revenue and Customs Service Razim Buksh Director Financial Intelligence Unit 46 47 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Functions of the Council The functions of the Council are provided for in section 35(5) of the FTR Act and are: Council Working Groups The National AML Council is supported in its work by three working groups, namely: i.
Legal Working Group; ii.

Supervisors and Regulators Working Group; and iii.

Law Enforcement Working Group.

The terms of reference of each Working Group is determined by the Council.

The Working Groups provide updates at the National AML Council meetings on its achievements.
1. to advise the FIU and the Minister on any matters relating to the prevention of money laundering or the financing of terrorism; 2. to make recommendations to the Unit and the Minister on any matter relating to the prevention of money laundering or the financing of terrorism; 3. to assist the FIU and the Minister in the formulation of policies or strategies relating to the prevention of money laundering or the financing of terrorism; and 4. to assist the FIU in coordination between various Government departments and with statutory corporations.
Terms of Reference of AML Working Groups AML Legal Working Group AML Supervisors & Regulators Working Group AML Law Enforcement Working Group • To facilitate the review of relevant •To facilitate networking and sharing of information amongst regulators regarding the supervision of financial institutions for compliance with the FTR Act.

•To conduct joint AML Compliance Programmes.

•To advise the Council on financial institution’s compliance with legislative AML requirements.
legislations to ensure that Fiji has an effective and globally acceptable legislative framework for combating money laundering and other related offences.

• To facilitate the ratification of relevant international conventions.

• To administer the forfeiture asset fund.

• To facilitate matters relating to international assistance and extradition.
Source: Fiji FIU • To facilitate networking amongst law enforcement agencies to enable: a) better sharing of information amongst agencies; b) the effective investigation and prosecution of money laundering and other related financial offences; and c) sharing of technical expertise and resources • To advise the Council on issues relating to investigation and prosecution of money laundering and other related offences.
the Working Groups are The members of representatives relevant agencies who contribute towards Fiji’s AML/CFT initiatives.

The chairpersons of the Working Groups are elected from by the members of the Working Group.

The FIU is a member and provides the secretariat of the three Working Groups.
48 49 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 National AML Council and Working Groups National AML Council Secretariat-FIU AML Legal Working Group AML Supervisors & Regulators Working Group AML Law Enforcement Working Group v. received and considered requests from agencies for funding assistance from the FAF; vi.
ongoing support and contribution to APG work, namely, Fiji’s contribution to the APG mutual evaluation programme, APG mandate paper and other governance issues; and vii.

ongoing review of Fiji’s national risk assessment.
ODPP (Chairperson) RBF (Chairperson) Immigration Department (Chairperson) Number of Working Group Meetings 2016-2020 Working Group 2016 2017 2018 2019 2020 1 1 Ad-hoc meeting 1 2 1 2 3 1 1 2 Ad-hoc meeting 0 0 1 Fiji Police Force FIU (member/ secretariat) Fiji Police Force Legal Ministry of Justice Ministry of Economy Ministry of Foreign Affairs Office of the Solicitor-General FIU (member/ secretariat) Law Enforcement Supervisors and Regulators Source: Fiji FIU FRCS ODPP FIU (member/ secretariat) FICAC Investment Fiji Ministry of Defence Council’s Activities in 2020 Key outputs driven by the National AML Council in 2020 were as follows: i. held the National AML Council Meeting in February 2020; ii.
submission of Fiji’s 4th Follow-Up Report to the APG on 1 October 2020.

The report outlined measures Fiji had taken since 2016 to implement the recommendations of the mutual evaluation report; iii.

the Council endorsed the commencement of the work on the new NAMLC Strategic Plan; iv.
drafted a guideline on Assessing Requests for Expenditure from the Forfeited Asset Fund (FAF); 48 49 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 9 APPENDICES APPENDIX 1: GUIDELINES ISSUED BY THE FIU Guideline Reference Title Date Issued Purpose of Guideline Guideline 1 Suspicious Transactions Guideline 2 Guideline 3 Reporting a Suspicious Transaction by Paper Reporting Cash Transactions of $10,000 or above by Paper 26 October 2007 26 October 2007 To provide guidance on how to identify suspicious transactions and report these suspicious transactions.
To provide guidance to financial institutions on how to complete a “suspicious transaction report” form.
22 May 2009 To provide guidance to financial institutions on how to report cash transactions of $10,000 and above using the paper report forms Guideline 4 Customer Identification and Verification 20 August 2009 Guideline 4 (Revised) Customer Identification and Verification Guideline 5 Risk Assessment of New Products, New Business Practices and Technologies 11 September 2020 31 January 2018 Guideline 6 Dealing with Higher Risk Countries 31 January 2018 27 March 2018 To explain the customer identification and verification requirements of the FTR Act and Regulations and provide practical guidance on how to apply these customer verification requirements.
To reflect the repeal of the Business Licence Act 1976 on 31 July 2020.

Requires financial institutions identify and assess the money laundering, terrorist financing and proliferation financing risks that may arise in relation to the development of new products and new business practices, including new delivery mechanisms.
Outlines further requirements relating to dealing with higher risk countries and countries that have been identified as having inadequate systems in place to detect or prevent money laundering, terrorist financing and proliferation financing risks emanating from these countries.

Outlines requirements for dealing with domestic politically exposed persons and international organisation politically exposed persons.
Guideline 7 Guideline 8 Politically Exposed Persons AML Compliance Obligations of Real Estate Agents and Businesses Guidelines Issued by the RBF Banking Supervision Policy No.
6 Minimum Requirements for Licensed Financial Institutions for the Management of Money Laundering and Terrorist Financing Risk Restricted Money remitters and Money Changers Supervision Policy Statement No: 4 Insurance Supervision Policy Statement No:13 Source: Fiji FIU and RBF Minimum Requirements for the Management of Money Laundering and Terrorist Financing Risk Minimum Requirements for the Management of Money Laundering and Terrorist Financing Risk 1 October 2019 Provides guidance to real estate agents and businesses on their obligations under the FTR Act and Regulations.
November 2014 The Policy sets out the minimum requirements on establishing a risk management framework comprising of systems, structures, processes and people within which licensed financial institutions identifies, assesses, mitigates and monitors money laundering and terrorist financing risk.
October 2018 The Policy sets out the minimum requirements for money remitters and money changers in establishing a risk management framework comprising of systems, structures, processes and people within which a licensed entity identifies, assesses, mitigates and monitors money laundering and terrorist financing risk.
November 2018 The Policy sets out minimum requirements for insurance companies and brokers on establishing a risk management framework, comprising of systems, structures, processes and people within which the institution identifies, assesses, mitigates and monitors money laundering and terrorist financing risk.
50 51 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 APPENDIX 2: POLICY ADVISORIES ISSUED BY THE FIU Reference Subject Purpose of Advisory Issue Date 1/2007 Customer Due Diligence of Existing Customers’ Accounts To explain how and when due diligence is to be applied to existing customers of financial institutions 15 March 2007 Customer Due Diligence of Customers Who Have Insufficient or No Official Identification Documents To provide further guidance on how due diligence is to be applied to new customers who have insufficient or no official identification documents 11 April 2007 Identification and Verification of a Customer’s Signature To provide further guidance on how to identify and verify a customer’s signature 26 April 2007 Identification and Verification of Occasional Customers To provide further guidance on how to identify and verify occasional customers 5/2007 Risk Based Approach To provide guidance on how to apply the FTR Act and Regulations on a risk based approach 14 June 2007 22 June 2007 2/2007 3/2007 4/2007 6/2007 Application of Exemption Provisions for Reporting of Cash Transactions To provide guidance on how to apply the exemption provisions relating to cash transaction reporting requirements 9 July 2007 7/2007 Record Keeping To provide further guidance on the record keeping requirements of the FTR Act 11 July 2007 1/2008 2/2008 Identification and Verification of Customers of Insurance Providers Identification and Verification of Clients and Beneficiaries of Employer Funded Group Life Insurance Policies 1/2010 Identification and Verification of a Customer's Signature 2/2010 Use of Referee Letter to Verify a Customer's Identity 3/2010 Refugee Identity Card 4/2010 Identification of Customers of Telephone Financial Services 1/2012 Subsequent Reporting of Suspicious Transactions 2/2012 Voter Identification Card To provide further guidance to insurance companies, brokers and agents on their obligations to identify and verify their customers’ identity.
23 January 2008 To provide guidance on how insurance companies and intermediaries can apply the identification requirements to clients of employer funded group life insurance policies.

24 November 2008 To provide guidance on how to identify and verify a customer’s signature.

This Advisory supersedes and replaces Policy Advisory 3/2007 of 26 April 2007.
Pursuant to Section 4(4)(a )of the FTR Act, to allow financial institutions to rely solely on a letter from a suitable referee to verify a low risk customer who does not have or is unable to provide any formal identification documents.

To advise financial institutions of the identification documents pertaining to customers who have been granted Asylum Seeker and Refugee status by the Fiji Government.
To provide guidance to telephone service providers that provide financial services to customers on the customer identification requirements under the FTR Act and how it relates to the Compulsory Registration of Customers for Telephone Services Act (2010).
To provide clarification on the need for continuous reporting of customers who have been previously reported to the FIU as engaging in suspicious transactions To advise financial institutions of the inclusion of the Fiji Voter Identification Card for identification and verification of certain customers and clients.
11 August 2010 27 August 2010 17 September 2010 17 September 2010 28 March 2012 22 August 2012 50 51 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Reference Subject Purpose of Advisory Issue Date 1/2013 1/2018 FNPF/FRCS Joint Identification Card Parenthood Assistance Payment Programme 2/2018 Change in Account Name for Existing Private Companies To advise financial institutions of the inclusion of the FNPF/FRCS Joint Identification card for identification and verification of their customers and clients.
To provide clarification on the application of CDD requirements on bank account opening for recipients of the Parenthood Assistance Payment Programme.

To provide clarification on the customer due diligence (CDD) requirements under the Financial Transactions Reporting (FTR) Act and how it aligns to the requirements under the Companies Act on changes to names of existing Private Companies.
15 November 2013 8 August 2018 23 November 2018 1/2019 Establishing Source of Funds To provide further guidance and clarification on establishing a customer’s source of funds.

20 September 2019 Removal of Business License Requirement under the FTR Regulations The purpose of this Policy Advisory is to provide further guidance and clarification on the removal of the business licence certificate from the customer due diligence requirement under the Financial Transactions Reporting (FTR) Regulations.
11 September 2020 1/2020 Source: Fiji FIU 52 53 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 APPENDIX 3: PRESS RELEASES PRESS RELEASE Press Release No.
: 08/2020 Telephone: (679) 331 3611/322 3333 Facsimile: (679) 330 2094/331 6454 Date: 19 March 2020 Email: info@rbf.gov.fj or info@fijifiu.gov.fj THE FINANCIAL INTELLIGENCE UNIT SIGNS MEMORANDUM OF UNDERSTANDING WITH POST FIJI PTE LIMITED The Financial Intelligence Unit (FIU) and Post Fiji Pte Limited signed a Memorandum of Understanding [MOU] today.

The MOU will establish an effective framework to detect and investigate financial crimes, such as, money laundering and remittance scams in Fiji.
The Chief Executive Officer of Post Fiji Pte Limited, Dr Anirudha Bansod, said that Post Fiji is pleased to sign this Memorandum of Understanding, where Post Fiji can provide information and details to FIU on a case to case basis.

In considering the safety and security of all Fiji residents, the Post Fiji Chairman, Board and Management are committed to preventing criminals from abusing Post Fiji’s services.
Hence, it is important to share the required information to FIU, which is a statutory body the Government of Fiji.

Post Fiji will continue to ensure that the safety, privacy and security of Fiji residents are maintained.

The Director of the Financial Intelligence Unit, Mr Razim Buksh, said that the MOU will greatly assist the FIU to access additional information, such as, money order transactions and postal services data when conducting intelligence analysis.
This will further strengthen the FIU’s intelligence, networking and profiling capabilities.

Mr Buksh said partnership with Post Fiji is another important step in “protecting Fiji from money laundering”.

The Financial Transactions Reporting Act enables the FIU to enter into such arrangements.

The FIU has signed similar MOUs with 12 other agencies and stakeholders.

The FIU also has networking and information exchange arrangements with 163 FIUs internationally.
Dr Anirudha Bansod Chief Executive Officer Post Fiji Pte Limited Razim Buksh Director Financial Intelligence Unit 52 53 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 PRESS RELEASE Press Release No.
: 12/2020 Telephone: (679) 331 3611/322 3333 Facsimile: (679) 330 2094/331 6454 Date: 27 March 2020 Email: info@rbf.gov.fj or info@fijifiu.gov.fj COVID-19 RELATED ONLINE SCAM The Financial Intelligence Unit (FIU) received a report of a product scam connected to COVID-19 whereby a local pharmaceutical company paid for an order it never received.

This scam is relevant for the sale of coronavirus related health and sanitation products such as face masks, hand sanitisers and disinfectant wipes.
Director of the Financial Intelligence Unit, Mr. Razim Buksh, said that a local pharmaceutical company had contacted a foreign individual and business that was marketing face masks on Facebook.

The communication between the two parties later involved email and WhatsApp whereby the local pharmaceutical company paid $6,500 for its order using the banking details noted in the invoice sent by the supplier.
Mr. Buksh said that the local pharmaceutical company later received a fake confirmation from a freight company about the shipment of its order, however, the order has not been received to date.
Mr. Buksh said that with the COVID-19 pandemic, there is an increased reliance on the internet for information and services and therefore, it is crucial for local businesses and members of the public to remain vigilant about cyber security because online criminals are using this global crisis for their financial gain.

This week the Fiji Police Force posted a warning on Facebook about cyber criminals advertising services relating to COVID-19 on various websites.
The Fiji Pharmaceutical Society and Fiji Chamber of Commerce and Industry have been alerted and requested to raise awareness and warn its members and other relevant stakeholders of suppliers who market COVID-19 related health and sanitation products through email, social media and instant messaging (IM) applications such as Facebook, WhatsApp, Instagram, Twitter and Messenger.
Mr. Buksh urges businesses and members of the public to exercise extreme caution when trading on social media, conduct enhanced due diligence checks when engaging new suppliers, consult their local bank to verify transaction details before transferring funds to the supplier’s bank account, and consult the FIU to determine if a supplier is legitimate or not.
Furthermore, businesses and members of the public are urged not to respond to any unsolicited email from suppliers of such products, not to click on any link provided, not to open files attached to unsolicited emails, and not to share bank account and credit card details to unsuspecting online criminals.

Razim Buksh Director Financial Intelligence Unit 54 55 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 PRESS RELEASE Press Release No.
: 01/2020 Telephone: (679) 331 3611/322 3333 Facsimile: (679) 330 2094/331 6454 Date: 4 September 2020 Email: info@rbf.gov.fj or info@fijifiu.gov.fj FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 The Fiji Financial Intelligence Unit (FIU) Annual Report for 2019 was tabled in Parliament today, 4 September 2020 by the Attorney-General and Minister for Justice, Hon.

Aiyaz Sayed-Khaiyum.

The report provides information on key achievements and the performance of the FIU for 2019.
The FIU is responsible for implementing and enforcing the Financial Transactions Reporting (FTR) Act.

The FIU is the lead agency for preventing and detecting money laundering in Fiji.
The Director, Mr Razim Buksh said that the FIU has made substantial progress on delivery of our functions, duties and powers in the past 14 years since it was established in 2006 which includes: • • • stronger collaboration and networking with law enforcement partner agencies; enhanced technical resources, data-mining, analytics, and capacity of the FIU; strengthened information exchange with domestic and foreign agencies; • more developed preventative measures, customer due diligence and financial transaction reporting framework together with strong compliance and enforcement measures; and • FIU database containing more than 16million financial transaction information.
In 2019, the FIU received 622 suspicious transaction reports, 1,515,681 electronic fund transfer reports, 794,044 cash transaction reports and 1,102 border currency reports.
The FIU’s intelligence outcomes that were disseminated in 2019 to various law enforcement and other Government agencies include: (a) 84 intelligence reports totaling suspected tainted proceeds of $10million to various law enforcement agencies, (b) 222 investigative assistance on 67 entities and 318 individuals, (c) 89 due diligence and background checks on 99 entities and 162 individuals, and (d) 209 direct data searches by officers of FIU’s partner agencies on several suspected individual and entities.
This resulted in successful investigation of 19 border currency smuggling cases, one money laundering conviction, several successful investigation of cases on tax evasion, corruption, proceeds of crime, online scam, unexplained wealth and other predicate crime investigations in 2019.

The FIU continued its engagement with the lawyers, accountants and real estate agents and conducted onsite examinations to ensure that the requirements under the FTR Act and Regulations are effectively implemented.
In 2019, the FIU finalized its 2020 – 2024 strategic plan which reflects the environment in which the FIU will operate in the next five years, particularly focusing on technology driven processes.

Mr. Buksh said the outcomes in 2019 has been possible through the support of various partners such as the National AML Council, the law enforcement agencies, reporting financial institutions and other relevant agencies including the Reserve Bank of Fiji.
Click to download a copy of the 2019 Annual Report: https://www.fijifiu.gov.fj/Publications/Annual-Reports/FIU-Annual- Report-2019.aspx FIJI FINANCIAL INTELLIGENCE UNIT www.fijifiu.gov.fj 54 55 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 10 SELECTED KEY STATISTICS 2016 - 2020 SELECTED KEY STATISTICS 2016-2020 Year 2016 2017 2018 2019 2020 Suspicious Transaction Reports 579 650 632 622 736 Transaction and Currency Reports Received by FIU Cash Transaction Reports 590,385 623,213 968,693 794,044 619,987 Electronic Fund Transfer Transaction Reports 1,148,711 1,220,602 1,357,246 1,515,681 1,866,197 Border Currency Reports 547 792 969 1,102 266 Year 2016 2017 2018 2019 2020 Suspicious Transaction Reports Filed Away for future intelligence and analysis Case Dissemination Reports 284 195 Intelligence and Information Reports to Stakeholders Due Diligence Reports Information Dissemination Reports 210 Notices to Financial Institutions Alert Notices Directives 314 448 205 75 10 1 248 321 260 118 15 2 132 84 222 89 9 3 372 270 127 70 20 6 41 14 1 Enquiries with Financial Institutions Request for further information to financial institutions 464 502 446 603 645 Year 2016 2017 2018 2019 2020 Number of employees of Financial Institution 320 202 376 Education and Awareness Number of Financial Institutions Employees of Law Enforcement Agencies Source: Fiji FIU 6 67 8 80 5 65 79 1 152 104 4 0 56 57 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 11 SELECTED KEY EVENTS 2020 JANUARY DETAILS 13 21 24 27 29 FEBRUARY FNIC Taskforce Meeting FNIC Taskforce Meeting Presented at the REALB Talanoa session Training of the New Direct Database Access officers Pacific AML/CFT Supervisors Forum teleconference 11 13 21 26 28 MARCH 10 19 26 27 APRIL 3 - 16 MAY 5 JUNE 23 24 29 JULY 7 10 22 AUGUST 12 20 24 25 26 Meeting with Ministry of Defence & US officials Presented at Safer Internet Day 2020 on Cybersecurity Awareness E-Money Taskforce Meeting Conducted Induction for New AML Compliance Officers IMF/Everest Meeting 2nd National Real Estate Conference Meeting of the National AML Council Presented at Fiji ICT Awareness Session Meeting with Ministry of Lands FIU and Post Fiji Pte Limited signed a MOA for Information Exchange Issued Press Release No.
08/2020 - The Financial Intelligence Unit signs Memorandum Of Understanding with Post Fiji Pte Limited APG Mutual Evaluation Committee Meeting (Virtual) Press Release No.
12/2020 - Covid-19 Related Online Scam Work-From-Home due to COVID-19 lockdown Meeting with AUSTRAC (Virtual) Meeting with AUSTRAC (Virtual) Meeting with AUSTRAC (Virtual) Pacific AML/CFT Supervisors Forum (Teleconference) Asia and Pacific Regional Group Meeting (Virtual) EKYC Taskforce Meeting Meeting with AUSTRAC (Virtual) Presented at iTaukei Affairs Roko Tui Leadership Course APG Mutual Evaluation Committee Meeting (Virtual) AML Training/Briefing for an Accounting Firm DFIU/Governor Meeting Meeting with AUSTRAC (Virtual) RMI Assessment Team Meeting APG Mutual Evaluation Committee Meeting (Virtual) Meeting with AUSTRAC (Virtual) AUSTRAC/Refinitiv – World-Check Tips and Tricks training session (Virtual) FIU Management Committee meeting FIU Staff Briefing 56 57 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 SEPTEMBER 1 2 4 8 10 11 25 29 OCTOBER 1 6 7 8 12 13 20 28 29 AML Supervisors Working Group meeting FIU Management Committee meeting FIU Staff Briefing FIU Annual Report 2019 tabled in Parliament Issued FIU Press Release No.
01/2020 - Fiji Financial Intelligence Unit Annual Report 2019 DFIU/Governor Meeting Meeting with AUSTRAC (Virtual) Issued FIU Policy Advisory 01/2020 - Removal of Business License Requirement under the FTR Regulations Meeting with Digital Fiji Presented at RBF Supervisor’s Quality Management Team Meeting Submitted Fiji’s Fourth-Follow-Up Report to APG Meeting with Government of Tuvalu Officials (Virtual) FIU Management Committee Meeting FIU Staff Briefing RMI ME Meeting (Virtual) APG Ad Hoc Committee on the FATF Strategic Review (Virtual) Egmont Group-Asia and Pacific Regional Group Meeting (Virtual) Meeting with AUSTRAC (Virtual) DFIU/Governor Meeting RMI ME Meeting (Virtual) FIU AML Forum for the Commercial Banks APG Mutual Evaluation Committee Meeting (Virtual) NOVEMBER 5 6 10 11 20 24 Consultations with commercial banks on the draft revised Enforceable Guideline on STR FIU Management Committee Meeting AFI Global standards Proportionality Working Group Meeting (Virtual) DFIU/Governor Meeting FIU Staff Briefing South Pacific Central Banks – Virtual Governors Forum Meeting with AUSTRAC (Virtual) Secured online access to the Post Fiji Ltd system APG Ad Hoc Committee on the FATF Strategic Review Meeting (Virtual) DECEMBER 3 APG Mutual Evaluation Committee Meeting (Virtual) FIU Management Committee meeting 7 - 11 Pacific AML/CFT Webinar 8 9 10 DFIU/Governor Meeting FIU Staff Briefing High Court issues Fiji’s first unexplained wealth declaration under the Proceeds of Crime Act 58 59 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 d n a l a n o i t a n g n o r t S & / , n o i t p u r r o c , d u a r f , g n i r e d n u a l y r e v o c e r t e s s a , s e m i r c l i a c n a n fi x e p m o c l r e h t o / L
r c l i a c n a n fi x e p m o c l r e h t o / .
d e t c e t o r p i s n a m e r ” m e t s y s l i a c n a n fi “ s ’ i j i F & y e m l i t ; , .
s n o i t c a s n a r t l i a c n a n fi d n a e d a r t r i e h t t c u d n o c o t 58 59 59 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 60 61 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 STRATEGIC ANALYSIS REPORT 2020 60 61 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 2020 STRATEGIC ANALYSIS REPORT FIJI FINANCIAL INTELLIGENCE UNIT 1.
STRATEGIC ANALYSIS OVERVIEW 2.

SUMMARY OUTCOMES 3.

OUTCOMES - SUSPICIOUS TRANSACTION REPORTS 4.

OUTCOMES - CASH TRANSACTION REPORTS 5.

OUTCOMES - ELECTRONIC FUNDS TRANSFER REPORTS 6.

OUTCOMES - BORDER CURRENCY REPORTS 7.

EMERGING AND CONTINUING MONEY LAUNDERING TRENDS 8.

CASE STUDIES 9.
CASE STUDIES 9.

GLOSSARY 63 65 66 73 75 77 80 81 88 62 62 63 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 1 STRATEGIC ANALYSIS OVERVIEW Overview The Fiji FIU undertakes detailed analysis of financial transaction into meaningful outputs.

This is called strategic analysis.

information and converts it FIU receives as well as a summary of the trends and case studies identified in 2020.
This Report provides the key outcomes of strategic analysis on the various categories of reports that the Strategic analysis outcomes enable the Fiji FIU and its stakeholders to understand the patterns and trends on money laundering and related issues.

FIU analysis should add value to the information received and held by the FIU.
While all the information should be considered, the analysis may focus either on each single disclosure received or on appropriate selected information, depending on the type and volume of the disclosure received, and on the expected use after dissemination.

FIUs should be encouraged to use analytical software to process information more efficiently and assist in establishing relevant links.

However, such tools cannot fully replace the human judgement element of analysis.
FIUs should conduct the following types of analysis: Operational analysis Strategic analysis • uses available and obtainable information; • uses available and obtainable information, including data • identify specific targets (e.g.

persons, assets, criminal that may be provided by other competent authorities; networks and associations); • identify money laundering and terrorist financing related • follow the trail of particular activities or transactions; trends and patterns; and.
• determine links between those targets and possible proceeds of crime, money laundering, predicate • used by the FIU or other state entities in order to determine money laundering and terrorist financing related threats and vulnerabilities; and offences or terrorist financing.

• help establish policies and goals for the FIU, or more broadly for other entities within the AML/CFT regime.
Adapted from: FATF Recommendation 29, Interpretive Note Paragraph 3 62 63 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Strategic analysis aims to interpret the underlying patterns and setting operational priorities.
In FIU context, this implies developing trends that would enable an FIU to draw conclusions for the knowledge (strategic intelligence) as it relates to money laundering, strategic prevention of money laundering and the financing the financing of terrorism and other threats to the security of a of terrorism, and to provide input for policy formulation and for country’s financial systems.
Components of Strategic Analysis Constructing the argument, that is the logical flow of elements leading to the inference Developing inferences (an inference is the best estimate of the truth that can be drawn from facts, opinions or other inferences) Identifying connections or links between pieces of information, also used to support an inference Components of Strategic Analysis Examining data for patterns and similar concepts Developing a working hypothesis that addresses the “who”, “what”, “when”, “where”, “how”, and “why” of the activity Collecting, evaluating and collating further information as required Adapted from: Egmont Group of Financial Intelligence Unit’s Operational Guidance for FIU Activities and the Exchange of Information.
Strategic Analysis Products Typologies Trends Patterns Synthesis A systematic classification of a number of schemes that appear to be constructed in a similar fashion.

These are built on a series of indicators that show how money was laundered, which in turn increases general understanding of an issue or method of money laundering or the financing of terrorism.

When a typology occurs for any given event over a period of time, this can be classed as a trend.
Changes in crime types or the way in which money is moved are examples of trends.

This is a recurring characteristic or trait that helps in the identification of a phenomenon/problem and that serves as an indicator or model for predicting future behaviour.

This includes identifying connections that identify break-through ideas and opportunities in the detection of money laundering or the financing of terrorism.
Geographical/ regional analysis This shows the area of influence or location of the phenomenon.

Behavioural analysis This shows the type of operations, institutions and products used by the group.

Activity analysis This focuses on identifying weaknesses of an economic sector or activity.

s t c u d o r P i l s s y a n A c g e t a r t S i Advanced intelligence products These may include vulnerability assessments, risk assessments and significant event assessments.
Adapted from: Egmont Group of Financial Intelligence Unit’s Operational Guidance for FIU Activities and the Exchange of Information.
64 65 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 2 SUMMARY OUTCOMES Suspicious Transaction Reports primary Instrument Type - Cash Cash Transaction Reports Received Managed 736 141 from 622 in current authorised 2019 users of the FIU’s online IT system 86% from commercial banks 9% from MRSPs Total value Managed $56.2 141 current authorised users of the FIU’s online IT system Million from $57.4 million in 2019 Fijian currency97% 78% 33 years of age 58% from Central/ Eastern Division 99% from commercial banks 42% between $10,001 and $20,000 Received 619,987 Electronic Funds Transfer Reports Received 1,866,197 from 1,515,681 in 2019 74% from the Money Remittance Service Providers 85% inward remittance transactions Border Currency Reports Received 266 in 2020 from 1,102 BCRs in 2019 More outward declarations Total value $15.9 Million from $63.6 million in 2019 64 65 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 3 OUTCOMES – SUSPICIOUS TRANSACTIONS REPORTS Reporting Financial Institutions STRs were reported to the FIU by various financial institutions including members of the public.
The majority of the STRs continue to be reported by commercial banks (2020: 86 percent; 2019: 74 percent) followed by the money remittance service providers (2020: 9 percent; 2019: 22 percent).

The increase in the total number of STRs reported was due to “defensive reporting”10 by one of the commercial banks.

Summary of Reporting Financial Institutions Financial Institutions and Persons Reporting Number of Registered AML Compliance Officers No.
of STRs Received 2016 2017 2018 2019 2020 Commercial Banks Money Remittance Service Providers Finance Companies Members of the Public Regulatory Authorities Law Firms Accounting Firms Insurance Companies and Superannuation Fund Securities, Unit Trusts Real Estate Businesses Mobile Phone Operators Others11 TOTAL Source: Fiji FIU 6 367 407 391 459 636 10 166 149 183 136 68 11 3 4 16 - - 42 17 13 4 29 2 - Summary of Reporting Financial Institutions Banks Banks to Total Number of STRs Other Financial Institutions Money Remittance Service Providers to Total Number of STRs No.
of STRs 700 600 500 400 300 200 100 0 % 100 80 60 40 20 0 2016 2017 2018 Years 2019 2020 Source: Fiji FIU Value of Transactions Reported as Suspicious The total value of suspicious transactions that were reported in 2020 decreased to $56.2 million from $57.4 million in 2019.

The average value of a transaction reported in 2020 as suspicious was $76,359 compared to $92,283 in 2019.
The decrease in the total and average value of suspicious transactions reported is because there are more low value STRs than high value STRs in 2020.
Total Value of Transactions Reported as Suspicious 2016 2017 2018 2019 2020 74.7 49.1 78.8 57.4 56.2 579 650 632 622 736 128,968 75,503 124,684 92,283 76,359 Total Value ($ million) Number of STRs Average Value reported ($ per STR) Source: Fiji FIU 10 Defensive reporting occurs when financial institutions submit STRs that do not meet the threshold of suspicion, primarily due to fear of sanctions if the transaction later indicates criminal activity.

11 “Others” include STRs filed by foreign FIU’s.


66 67 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 “Grounds for Suspicion” in Suspicious Transaction Reports In 2020, majority of the STRs were reported on the grounds of suspected unusual account activity followed by other general indicators including one-off large transactions.
It was observed that a number of individuals were reported for other general indicators including large one-off transactions which did not match their customer profiles and/or employment status.

Total Value of Transactions Reported as Suspicious Number of STRs Total Value of STR $m 90 80 70 60 50 40 30 20 10 0 No.
of STRs 800 700 600 500 400 300 200 100 0 2016 2017 2018 2019 2020 Years Source: Fiji FIU Grounds for Suspicion on STRs Received 2020 Grounds for Suspicion Use Of Minors Account Unusually Large Foreign Transaction Avoiding Reporting Obligations Possible Unexplained Wealth FIU/Other Watchlist Violation of EC Requirements Counterfeit Financial Instruments Third Party Transaction Fraud Or Other Serious Offence Inconsistent with Customer Profile Unusually Large Transfer Unusual Use/Exchange Of Cash Suspicious Behaviour Advance Fee Fraud & Other Scams Tax Evasion Unusually Large Cash Transaction Other (One-Off Large Transaction) Unusual Account Activity 0 20 40 60 80 100 120 140 160 180 200 Number of STRs Source: Fiji FIU 66 67 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Suspicious Transactions by Transaction Value There is no monetary threshold under the FTR Act for reporting suspicious transactions.
Thus, any suspicious transaction must be reported to the FIU regardless of the amount involved in the transaction, including the reporting of attempted transactions.

Previous trends indicate that suspicious transactions do not always involve substantial dollar amounts.

41 percent of the STRs submitted by financial institutions in 2020 were reported on transactions valued below $5,000.
STRs involving large value transactions of more than $100,000 accounted for 17 percent of total STRs reported in 2020 compared to 9 percent in 2019.

Suspicious Transactions by Transaction Value Suspicious Transactions by Instrument Type ‘Cash’ continued the primary financial to be instrument type that is reflected in the STRs reported to the FIU in 2020.

Out of the 736 transactions reported as suspicious in 2020, 385 (52 percent) involved cash transactions.
The types of financial instruments involved in STRs include: 1.

Cash (local and foreign currency); 2.

Cheque (bank cheques/drafts, personal and company cheques); 3.

Remittances; and 4.

Other instruments (account-to-account transfers, credit cards and travellers cheques).
3% 14% Suspicious Transactions by Instrument Type Year Cash Cheque Remittances Others Total 6% 11% 13% 41% 2016 398 2017 409 2018 343 2019 286 40 67 62 90 2020 385 138 Source: Fiji FIU 93 113 186 193 144 48 61 41 53 69 579 650 632 622 736 $0-$5,000 $5,001-$10,000.00 Cash Cheque Remittances Others 11% Suspicious Transactions by Instrument Type $10,001-$20,000.00 $20,001-$50,000.00 No.
of STRs $50,001-$100,000.00 $100,001-$500,000.00 $500,001 and above Source: Fiji FIU Suspicious Transactions by Transaction Value Transaction Value Number of STRs Percentage of STRs $0 - $5,000.00 $5,000.01 - $10,000.00 $10,000.01 - $20,000.00 $20,000.01 - $50,000.00 $50,000.01 - $100,000.00 $100,000.01 - $500,000.00 $500,000.01 and above Total Source: Fiji FIU Years Source: Fiji FIU 68 69 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Suspicious Transactions by Currency Type The majority (97 percent) of the STRs reported in 2020 involved Fijian currency.
The suspicious transactions that involved foreign currency decreased to 3 percent of total STRs in 2020 compared to 7 percent in 2019.

Suspicious Transaction Reports by Customer Age 67 percent of STRs on individuals were reported on customers between the age of 26 and 54 years.

Age not stated decreased to zero in 2020 from 3 in 2019 due to an improvement in the quality of reports.
Suspicious Transaction Reports by Customer Age Year 2yrs – 18yrs 19yrs - 25yrs 26yrs - 32yrs 33yrs - 39yrs 40yrs - 46yrs 47yrs - 54yrs 55yrs and over Not Stated12 Total Source: Fiji FIU 26 53 95 80 86 68 30 72 94 86 91 127 3 0 418 508 Suspicious Transaction Reports by Customer Age 8, 2% 30, 6% 127, 25% 72, 14% 91, 18% 94, 18% 86, 17% 2 yrs - 18 yrs 19 yrs - 25 yrs 26 yrs - 32 yrs 33 yrs - 39 yrs 40 yrs - 46 yrs 47 yrs - 54 yrs 923 841 55 yrs and over Source: Fiji FIU Suspicious Transactions by Currency Type Fijian Currency Foreign Currency Fijian Currency % Change Foreign Currency % Change No.
of STRs 800 700 600 500 400 300 200 100 0 577 515 472 358 185 133 160 2016 2017 2018 Years 45 2019 % Change 100 713 80 60 40 20 0 45 2020 Source: Fiji FIU Suspicious Transaction Reports by Customer Type There were 841 (84 percent) personal customers reported in STRs compared to 158 (16 percent) reports on corporate and business entities in 2020.

The proportion of STRs reported in 2020 on individuals decreased slightly by 9 percent when compared to 2019.
This decrease was caused by fewer individuals being reported in a single STR when compared to 2019.

Suspicious Transaction Reports by Customer Type No.

of STRs 1,000 Individual Legal Entities 900 800 700 600 500 400 300 200 100 0 503 542 529 108 103 69 180 158 2016 2017 2018 Years 2019 2020 Source: Fiji FIU 68 69 12 Date of birth is not usually provided in STRs where the person reported is a beneficiary of advance fee fraud and is a foreign national.
FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Age of Convicted Money Launderers Analysis of money laundering and proceeds of crime conviction cases showed the following in relation to the age bracket of the persons involved.
Name of Individual Year STR was Reported Age at the time of the offence Year Convicted Prashil Prakash 2012 28 years old 2017 Money Laundering Convictions originating from STRs Aidong Zhang Source: Fiji FIU 2014 & 2016 51 years old 2019 Name of Individual Year STR was Reported Age at the time of the offence Year Convicted Manoj Khera 2004 31 years old 2014 Timothy Aaron O’Keefe 2005 25 years old 2005 Monika Arora 2007 28 years old 2011 2008 30 years old 2010 Other Money Laundering Convictions Name of Individual Age at the time of the offence Year Convicted Deepak Rajneel Kapoor 25 years old Robin Surya Subha Shyam 38 years old Faiyaz Khan Savita Singh Chris Ronil Singh 38 years old 32 years old 38 years old 2008 28 years old 2011 Mukeshwar Narayan Singh 21 years old 2008 40 years old 2011 Atisma Kirti Singh 2008 23 years old 2011 Sakiusa Vakarewa Josefa Saqanavere Savenaca Batibawa 31 years old 41 years old 47 years old Johnny Albert Stephen 2009 39 years old 2012 Katarine Gounden Fiu 31 years old Salendra Sen Sinha Anand Kumar Prasad Deo Narayan Singh Doreen Singh 2009 31 years old 2013 Kapil Kushant Samy Nitesh Kumar Nirmala Devi Natasha Nilma Singh Vikash Mehta Tuimoala Raogo Fazeel Razid Ali Manjeet Singh Rajneel Chaudary Preetika Anuwesh Lata 2010 24 years old 2012 2016 2011 23 years old 46 years old 2016 2012 2012 20 years old 2014 2013 2013 2015 2014 2014 29 years old 41 years old 27 years old 22 years old 23 years old 2015 2016 2016 2017 2017 2014 27 years old 2017 Vika Sadrau Rahul Rajan Naidu Avenai Danford Rimakshni Ranigal 34 years old 28 years old 29 years old 30 years old Rosheen Praveena Raj 42 years old Rine Munivai Sorby 54 years old Nousheen Mezbeen Hussain 25 years old Source: Fiji FIU Suspicious Transaction Reports by Geographical Location of Reporting Institutions The FIU receives STRs from various commercial centres in Fiji.
Majority of the STRs continue to be 2012 2013 2013 2015 2015 2016 2016 2016 2016 2016 2018 2018 2018 2018 2018 2018 2019 70 71 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 received from financial institutions based in the Central/Eastern Division due to concentration of economic and commercial activities in this division.

In 2020, STRs from the Western Division increased to 258 from 197 STRs received in 2019.
Suspicious Transaction Reports by Geographical Location of Reporting Institutions Western Central/Eastern Northern No.

of STRs Reasons for Suspicious Reporting A financial institution’s decision to report a transaction as suspicious is based on the evaluation of facts and context regarding a transaction(s) to determine if there is reasonable grounds to suspect that the transaction(s) is related to the commission of a money laundering, terrorist financing or other serious offence.
500 450 400 350 300 250 200 150 100 50 0 352 349 353 273 287 245 213 197 429 258 There should be “sufficient facts” or credible and objective evidence to support a financial institution’s suspicion and its decision to report a transaction(s) to the FIU.
17 41 2016 2017 68 72 48 2018 Years 2019 2020 Source: Fiji FIU Financial institutions are required under the FTR Act to know their customers in order to identify transactions that may be unusual, suspicious or questionable for an individual customer or a type or category of customer.

Examples of Reasons for Reporting Transactions as Suspicious Commercial Banks Commercial Banks 1.

2.

3.

4.
2.

3.

4.

A 26 year old was observed to be making large cash deposits followed by large payments to law firm trust accounts for the purchase of property.

The volume of transactions observed taking place in the account does not match the customer profile.

Customer has received funds on a particular date which is not in line with his normal credits.

Unable to verify source and reason for this credit.

Large amount of cash withdrawal in the customer account over the counter.
No supporting documents provided.

Customer claims to do a telegraphic transfer to New Zealand to his daughter.

Abnormal deposits being made on separate days in client’s account for which no documented evidence was provided, however, only reason client gave for one deposit was that it was from the sale of vehicle and savings from salary.

5.

6.

7.

Customer account activity has not been consistent with her known legitimate business or personal activities.
Continued use of personal account for business purposes.

3rd party came to do a deposit to a personal account.

Staff asked for evidence for funds and customer depositing refused to provide.

Customer then called account holder and he advised to reduce amount to $9,500.00 to avoid threshold reporting obligation.

A third party cashed a large cheque for $100,000.00 from a business account.

The bank was advised that this was to pay off a loan that the business had taken from the third party.
Upon requesting identification documents it was noted that the third party has publicly known criminal activities.

70 71 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Commercial Banks Real Estate Agent 8.

9.

Customer is having business proceeds deposited in personal accounts plus multiple salary narration noting done from different companies.

Inflow of funds varies from KYC documents currently held in file.
Trust account principal made a complaint on unauthorized transfers from trust account to firm’s office account.

The matter is being investigated by police.

Money Remittance Service Providers 10.

Individual requesting to send funds to a Facebook friend in Nigeria, after being advised that this maybe a scam, the individual stated it was payment for items.

11.

Individual using staff to send funds to his family members abroad.

12.

Customer was sending funds using two different identities.
Finance Companies 13.

Large repayments to a loan account.

Members of the Public 14 A person stole funds from a foreign jurisdiction and brought the funds to Fiji to build a house.

15.

The person requesting for refund is different from the intended property owner and the original remitter of funds.

Law Firm 16.

Client’s account was hacked and an email was sent requesting that settlement of proceeds be transferred to a fraudsters account.

17.
17.

Four unrelated parties engaged in a real estate transaction.

The party in control of the transaction is not the party noted in the sale and purchase agreement, and the party who remitted the deposit is not the party noted to be reimbursed when the purchasing offer is declined by the sellers.

Insurance Companies and Superannuation Fund 18.

Large cash deposits with unclear source of funds.

Securities & Unit Trusts 19.

Frequent large cash deposits in a short period of time.
The above are extracts from actual STRs reported to the FIU in 2020.

Source: Fiji FIU 72 73 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 4 OUTCOMES – CASH TRANSACTION REPORTS Financial institutions are required under section 13(1) of the FTR Act and regulation 25 of the FTR Regulations to report to the FIU any cash transaction of $10,000 and above or its equivalent in foreign currency.
Cash includes coin or paper money, bank drafts, bank cheques, bearer bonds, travelers cheques, postal notes and money orders.

For ease of reporting, some financial institutions report all cheque transactions of $10,000 and above.

The FIU received 619,987 CTRs in 2020 or an average of around 51,666 CTRs per month.

This is a decrease of 22 percent compared to 794,044 CTRs received in 2019.
Cash Transactions Reported 2016-2020 Year 2016 2017 2018 2019 2020 Source: Fiji FIU Total CTRs Monthly Average CTRs 591,636 623,213 968,693 794,044 619,987 49,303 51,934 80,72413 66,170 51,666 Monthly Cash Transaction Reports No.

of CTRs 2017 2016 2018 2019 2020 90,000 85,000 80,000 75,000 70,000 65,000 60,000 55,000 50,000 45,000 40,000 35,000 30,000 25,000 20,000 CTRs Received by Sector The majority (99 percent) of the CTRs received during 2020 was reported by commercial banks.
Cash Transactions Reported by Sector Sector 2016 2017 2018 2019 2020 Commercial Banks Foreign Exchange Dealers and Money Remitters Finance Companies Insurance and Superannuation Fund Law Firms Securities/ Brokers/ Advisors Accountants Statutory Authority Real Estate Total Source: Fiji FIU CTRs by Direction of Cash Payment The CTRs received in 2020 consisted of 61 percent inward (IN) and 39 percent outward (OUT) CTRs.
Inward CTRs refer to cash transactions received by a financial institution.

Outward CTRs refer to cash transactions paid out by a financial institution.

CTRs by Direction of Cash Payment 2020 240,023 39% 379,964 61% J F M A M J J A S O N D Months Source: Fiji FIU Out In Source: Fiji FIU 72 73 13 In 2018 one reporting institution reported backdated CTRs totalling 249,114 in October 2018.

This is also not reflected in the Monthly Cash Transaction Reports graphs for 2018.
FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 CTRs by Value of Transactions The majority (42 percent) of CTRs received by the FIU in 2020 were for cash transactions between $10,001 and $20,000.

Approximately 72 percent of CTRs reported are for cash transactions between $10,001 and $50,000.
CTRs by Value of Transactions 2020 320 0% 31,124 5% 73,309 12% 67,758 11% 189,204 30% 258,272 42% Less than $10,000 $20,001 to $50,000 Exactly $10,000 $50,001 to $100,000 $10,001 to $20,000 More than $100,000 Source: Fiji FIU 74 75 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 5 OUTCOMES – ELECTRONIC FUNDS TRANSFER REPORTS Commercial banks and money remittance service providers are required under section 13(2) of the FTR Act and regulation 26 of the FTR Regulations to report to the FIU all international electronic funds transfer transactions.
There is no monetary threshold for EFTRs.

Currently, 6 commercial banks, 10 MRSPs, and 2 mobile phone operators are subject to EFTR reporting.

The FIU received 1,866,197 EFTRs in 2020 or an average of around 155,516 EFTRs per month.

This is an increase of 23 percent compared to 1,515,681 EFTRs received in 2019.

The total EFTRs received in 2020 included 250,820 EFTRs in domestic remittances.
Electronic Funds Transfer Transactions Reported EFTRs Received by Sector Majority (74 percent) of EFTRs were received from the MRSPs.

There was a notable increase of 139 percent in the number of EFTRs received from the mobile phone money remittance sector in 2020.

Two major reasons for this increase were : i.

The impact of COVID-19 restrictions led to remittance channels being mobile phone increasingly used.
Safety, social distancing and lockdowns have impacted traditional money transfer operators/agents.

ii.

The removal of fees for inward remittances for two months in 2020 by one of the mobile phone money remitter was catalytic to the growth over the latter half of the year.
Year 2016 2017 2018 2019 2020 Source: Fiji FIU Total EFTRs Monthly Average EFTRs EFTRs Received by Sector 2020 329,965 18% 1,148,711 1,220,602 1,357,246 1,515,681 1,866,197 95,726 101,717 113,104 126,307 155,516 159,937 8% Monthly Electronic Funds Transfer Reports 1,376,295 74% No.
of EFTRs 200,000 190,000 180,000 170,000 160,000 150,000 140,000 130,000 120,000 110,000 100,000 90,000 80,000 70,000 60,000 50,000 2016 2017 2018 2019 2020 J F M A M J J A S O N D Months Source: Fiji FIU Money Remittance Service Providers Commercial Banks Mobile Phone Money Remitters Source: Fiji FIU EFTRs Received by Sector Sector 2016 2017 2018 2019 2020 Money Remittance Service Providers Commercial Banks Mobile Phone Money Remitters 793,837 869,363 968,016 1,088,292 1,376,295 333,746 319,640 346,282 360,595 329,965 21,128 31,599 42,948 66,794 159,937 Total 1,148,711 1,220,602 1,357,246 1,515,681 1,866,197 Source: Fiji FIU 74 75 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 EFTRs by Direction of Remittances EFTRs may involve remittances into Fiji (inward) or remittances out of Fiji (outward).
Majority (85 percent) of EFTRs received during 2020 were for inward remittances compared to 79 percent of inward remittances in 2019.

EFTRs by Sending and Receiving Country Inward international remittance transactions reported to the FIU were conducted from the following ten major countries: Australia, United States of America, New Zealand, United Kingdom, Canada, Vanuatu, Solomon Islands, Tonga, Cook Islands and Tuvalu.
The increase in total EFTRs received in 2020, particularly in the number of EFTRs relating to inward remittances corresponds to data released by the RBF on the value of remittances into Fiji in 2020.

Remittance inflows into Fiji have generally increased after May 2020 as Fijians living abroad remitted funds to Fiji to assist their family who lost jobs due to COVID-19 pandemic.
remittances have “Since May 2020, monthly gradually increased, reaching record highs in July and again in October when $69 million was received.
Cumulative to November, total remittances were $572.9 million”.14 EFTRs by Direction of Remittances 2020 278,595 15% EFTRs: Top 10 Countries Conducting Inward Remittances to Fiji 80,923 5% 529,060 36% 9,130 1% 9,568 1% 10,417 1% 9,129 1% 12,135 1% 57,309 4% 105,705 7% 293,351 20% 333,378 23% Australia United Kingdom Tonga United States of America Canada Vanuatu New Zealand Solomon Islands Cook Islands Tuvalu Others15 Source: Fiji FIU remittance international Outward transactions reported to the FIU were made to the following ten major countries: Australia, New Zealand, United States of America, India, Philippines, Solomon Islands, China, Vanuatu, Hong Kong and Singapore.
1,587,602 85% EFTRs: Top 10 Countries Involved in Outward Remittances from Fiji 37,411 23% 38,186 23% Out In Source: Fiji FIU EFTRs by Direction of Remittances Direction 2016 2017 2018 2019 2020 Inwards 879,644 958,090 1,053,266 1,198,905 1,587,602 Outwards 269,067 262,512 303,980 316,776 278,595 Total 1,148,711 1,220,602 1,357,246 1,515,681 1,866,197 Source: Fiji FIU 14 Extract from International Remittances and Fiji’s Unsung Heroes Abroad 24 December 2020 Article, Paragraph 9 on International Remittances and Fiji’s Unsung Heroes Abroad 24 December 2020 - Reserve Bank of Fiji (rbf.gov.fj).
15 Excludes 137,497 EFTRs in domestic remittances.

16 Excludes 113,323 EFTRs in domestic remittances.
76 2,965 2% 3,747 2% 3,796 2% 6,802 4% 7,866 5% 31,674 19% 7,998 5% 11,891 7% India 12,936 8% Vanuatu Australia New Zealand Philippines Hong Kong United States of America Solomon Islands Singapore China Others16 Source: Fiji FIU 77 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 6 OUTCOMES – BORDER CURRENCY REPORTS All travellers coming into Fiji or going out of Fiji are required to declare if they are carrying currency or negotiable bearer instruments of $10,000 or more (or its equivalent in foreign currency).
Travellers are required to make a declaration in the first instance on the arrival or departure cards and then fill out a BCR form which is available at all ports of entry and exit in Fiji.

The completed BCRs are collected by Customs FRCS officials at the ports and submitted to the FIU for central recording, analysis and for its intelligence purpose.

In 2020, 266 BCRs were submitted to the FIU.

This is a decrease of 76 percent compared to 1,102 BCRs received in 2019.
The decrease in BCRs is due to COVID-19 travel restrictions which drastically reduced the number of travellers into and out of Fiji.

BCRs by Direction of Travel There were more declarations made by outbound travellers compared to inbound travellers in 2020.

BCR Declarations by Direction of Travel Comparison of Declaration made by Travellers by Month No.
of BCR’s Into Fiji Out of Fiji 80 70 60 50 40 30 20 10 0 77 56 30 21 33 10 Months Source: Fiji FIU BCRs by Reason for Travel Majority (35 percent) of travellers stated their reason for travel both in and out of Fiji as “other” which includes traveling for migration, transit, medical purpose and sports.
BCR Declarations: Reason for Travel (inbound and outbound) 2020 45, 17% 52, 20% Persons Declaring Declarations made by inbound travellers Declarations made by outbound travellers Total Source: Fiji FIU 2016 2017 2018 2019 2020 13, 5% 265 375 434 436 81 282 417 535 666 185 93, 35% 547 792 969 1,102 266 1, 0% 62, 23% In 2020, 70 percent of declarations were made by outbound travellers while 30 percent of declarations were made by inbound travellers.
Business Other Convention/Conference Education/Training Holiday Visiting Friends/ Relatives Source: Fiji FIU 76 77 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 BCRs by Transaction Value All travellers coming into Fiji or going out of Fiji are required to declare if they are carrying currency or negotiable bearer instruments of $10,000 or more (or its equivalent in foreign currency).
Majority of BCRs declared by inbound and outbound travellers ranged in the value of $10,001 - $100,000.

BCRs by Transaction Values: Outbound 2020 11, 6% 4, 2% BCRs by Value of Currency Declared The total value of currency declared by travellers in the BCRs in 2020 was $15.9 million compared to $63.6 million in 2019.
Value of Border Currency Reports Received 2016-2020 Persons Declaring Travellers Arriving in Fiji Travelers Departing Fiji Value of Currency Declared ($million) 2016 2017 2018 2019 2020 13.1 21.4 22.6 19.3 5.4 17.1 28.5 40.1 44.3 10.5 Total 30.2 49.9 62.7 63.6 15.9 Source: FRCS & Fiji FIU Failure to Declare Currency Failure to declare currency at the border is an offence under the FTR Act.

If convicted, a person is liable to a fine of up to $60,000 or imprisonment of a maximum of 10 years or both.
170, 92% $10,001 - $100,000 $500,001 and above $100,001 - $500,000 Source: Fiji FIU In 2020, there were 8 reported cases of BCR non- declaration compared to 19 cases of persons failing to declare currency in 2019.

Most of the cases were detected at Nadi International Airport.
BCR by Transaction Values: Inbound 2020 9, 11% 1, 1% Managed Forfeited $69,000 141 current authorised users of the FIU’s online IT system 71, 88% $10,001 - $100,000 $500,001 and above $100,001 - $500,000 Source: Fiji FIU Non- Declaration of BCRs 8 78 79 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Failure to Declare Currency Cases in 2020 – Inbound and Outbound Travellers No.
Date of Detection Details Amount failed to declare FJD Equivalent Date of Admittance Judgement in Court 1.

12 January Passenger arrived from Sydney, Australia AUD 14,800 $22,013.17 13 January Warning letter issued Passenger arrived from Brisbane, Australia.

Currency was found when his baggage was searched after he was offloaded from departure flight bound for Vanuatu Passenger resides in Australia but arrived in Fiji from Narita, Japan.
Currency was found when his baggage was searched after he was offloaded from departure flight bound for Vanuatu Passenger arrived from Hong Kong Passenger arrived from Hong Kong in January and was returning to Japan via Auckland on Air New Zealand repatriation flight Passenger arrived from Narita, Japan in January and was returning to Italy via Auckland on Air New Zealand repatriation flight Passenger arrived from Narita, Japan in January and was returning to Italy via Auckland on Air NZ repatriation flight 2.
22 January 3.

22 January 4.

22 January 5.

23 January 6.

23 June 7.

23 June 8.
23 June Source: FRCS USD 7,109 JPY 43,000 CNY 700 VUV 130,000 AUD 505 CMD 20,000 USD 9,000 AUD 2,250 $25,270.00 FJD 945 USD 9,000 $21,204.59 22 January Currency to be forfeited to state as source of funds could not be established None - Held in Immigration custody before deportation to China by Chinese authorities Currency to be forfeited to state as source of funds could not be established VUV 196,000 $25,523.54 22 January Currency to be forfeited to state as source of funds could not be established FJD 430 USD 6,300 AUD 20 $13,363.00 29 January Passenger fined $1,000.00 USD 23,000.00 $49,892.75 Charge letter served through passenger’s solicitor Currency to be forfeited to state USD 9,000 $19,102.00 23 July USD 10,000 $21,225.00 23 July In the settlement process - Issuance of Notice for forfeiture of currency In the settlement process - Issuance of Notice for forfeiture of currency 78 79 In addition to the above, in 2020, FRCS pursued three undeclared currency forfeiture matters that were detected in 2018 and 2019.
FRCS successfully forfeited currency worth $69,091.91 under section 159 of the Customs Act.

This forfeiture included currencies such as NZD, USD, AUD, SGD, HKD, WST and FJD.

The funds were forfeited to the State and deposited into the Consolidated Fund Account.
FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 7 EMERGING AND CONTINUING MONEY LAUNDERING TRENDS Emerging Trend Utilization of Alternative Technology The FIU noted an increase in individuals using alternative technology and channels to transfer funds to other individuals.

This includes the use of Post Fiji telegraphic money orders (TMO) and Paypal.
In some instances it was noted that the use of these alternative technologies and channels was to deliberately avoid detection.

Continuing Trend The FIU observed a continued occurrence of individuals falling victim to various online scams in 2020.

Cybercriminals have taken advantage of the current global Covid-19 situation and have offered fake loans, packages, and relationships to vulnerable sectors of the community that remitted hundreds of thousands of dollars to these cybercriminals.
Online Loan Scam (December 2019 – April 2020) Conducted through Taveuni Island 73 local individuals conducted 163 remittance transactions *73 local individuals residing in Taveuni Remittance transactions totalled $98,658 Funds were remitted to 41 individuals in Benin CHARACTERISTICS of Money Mules17 and Victims: • Unemployed • Tertiary/University students • Low income earners • Single mothers • Elderly How to COMBAT a Loan Scammer?
• Compile documentation of the scam to submit to the FIU and/or FPF • File complaints with the FIU and/or FPF • Warn your families and friends • Keep an eye out for common red flags • Completely discontinue communication with the scammer !
Loan Scam RED Flags • Lender does not perform any credit check • Lender requires upfront fees to be paid or loan collateral to be provided • Lender guarantees loan approval • Lender’s physical address cannot be found and a secure website does not exist 17 “Money mules” are people who are used to transport and launder illegally obtained money through a courier service, or electronically, on behalf of others.
Individuals being used as money mules may be willing participants; however, many money mules are not aware that they are being used to commit fraud.

Typically, the mule is paid for services with a small part of the money transferred.

The individuals being used as money mules are not the only victims; the larger scheme is designed to extract money from an organization or from other people.
80 81 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 8 CASE STUDIES Case Study 1: Cash, Drugs and Escape Person X, a foreign national of Country Y, was brought to the attention of Fiji FIU for failure to pay office related expenses and employee salaries totalling approximately $70,000.00 before departing Fiji for Country Y.
Case Study 2: Tax Evasion and Accumulation of Unexplained Wealth The Fiji FIU received a report on Person A for misuse of his personal account for business related transactions, conducting large deposits and a possibly evading tax.

Fiji FIU analysis revealed that Person X established Company S and Company T without obtaining necessary approvals from statutory bodies as part of the conditions of his investor’s permit.
For the period 2015 to 2020, Person X received remittances totalling approximately $65,701.00 from various individuals in Country Y and remitted approximately $87,743.00 to individuals in Country Y, Country B and Fiji from 2014 to 2019.

Further analysis also revealed that Person X conducted large cash deposits in December 2017 totalling approximately $137,566.00 into Company T’s local bank account followed by withdrawals totalling $115,512.00.
The Fiji FIU also established that Person X was charged for drug related offences in Country Y.

Further profiling revealed that Person X departed Fiji for Country Y on 9 November 2019.

A case dissemination report was provided to FPF for further profiling and monitoring of Person X.

Checks by the Fiji FIU revealed that Person A was a director of a company and had a sole proprietor business.
The nature of business for the company and the sole proprietorship was provision of freight services and both business entities had incurred accumulative losses for the past 4 years.

We established that in four years, Person A received large sums of “salary” amounting to more than $450,000.00 from the company despite declaring losses for both business entities.

Further analysis also revealed that Person A opened a term deposit of $130,000.00 subsequent to declaring the losses.
A case dissemination report was provided to FRCS.
Indicators: • Depositing business funds into personal account • Related businesses are incurring losses • Individual accumulated unexplained wealth Indicators Possible Offence: • Possible tax related offence/tax evasion • Possession of unexplained wealth • Business established without proper regulatory permit • Consecutive large cash deposits and withdrawals • Alleged involvement in drugs • Urgency to leave Fiji without paying office related expenses Offence • Money laundering • Possible drug related activities 80 81 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Case Study 3: Corruption, Bribery, Kickbacks and Unexplained Wealth Person R, employed by a local statutory body, was brought to the attention of Fiji FIU for a possible case of bribery, corruption and unexplained wealth.
Analysis revealed that Person R received deposits totalling approximately $28,804.00 into his bank account between July 2018 and September 2020 from various individuals in Country V and Fiji.

It was also noted that Person R, his unemployed spouse (Person Y), and their children frequently travelled to Country V. In August 2019, Person R acquired a taxi permit, however, there was no corresponding transaction showing that Person R had paid for the taxi permit.
Person R and Y collectively own 4 high value vehicles that were purchased without any financing.

Further analysis revealed that Person R acquired a freehold property in the central division and made significant improvements to the property in the last few years.

Further analysis also revealed that patterns in Person R’s transactions and accumulation of wealth were not consistent with the annual income declared.
It was also established that Person R and his family frequently travelled abroad, however, funding for tickets and travel expenses could not be traced to credit card or bank account transactions.

A case dissemination report was provided to FICAC to examine the case for possible unexplained wealth as a result of corruption and bribery.
Indicators: • Frequent overseas trips without the apparent means to support those travel • Cash deposits apart from salary • Luxurious lifestyle • High value vehicles/house Offence: • Unexplained wealth • Corruption • Bribery • Possible tax related offence/tax evasion Person X Person Y Bought $16,000.00 taxi permit Married n e r d l i h C No loans or financial interest noted Bought for $64,000.00 Individuals in Country V Country V Credit Card expense in Country V $27,327.09 $10,000 Limit No loans or financial interest noted $28,804.00 Owns $460,000.00 worth house Person R’s Credit Card Person R’s Bank Person Y’s Bank Dec 2019 - Auckland Aug 2019 - Auckland Feb 2019 - Auckland Dec 2018 - Sydney Jul 2018 - Singapore Dec 2017 - Auckland Jul 2017 - Auckland Jan 2017 - Auckland Apr 2014 - Auckland May 2013 - Auckland Overseas trips Bought for $79,890.00 82 83 July and August 2020, Person Y transfers $15,000.00 into Person R’s bank account FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Case Study 4: Offshore Profit Shifting and Tax Evasion Person B, a dual citizen of Fiji and Country X was reported for claiming a false VAT refund from the local taxation authority on the pretext of a legitimate business expense.
Checks by the Fiji FIU revealed that Person B started a sole proprietor business in Fiji with a trading activity of real estate and is a director of two other companies in Fiji.

Both companies were related to the construction industry.

However, it was established that there was no corresponding trading activity in relation to the VAT claim since one of his companies had no significant trading activities while the other company was incurring losses for the same period.
The Fiji FIU established that more than $110,000.00 was claimed and refunded as VAT from the taxation authority by Person B. within 5 years.

The remitted funds were used to acquire three properties in Fiji with a total value of more than $1.8m which were partly financed by a loan.

A case dissemination report was provided to FRCS and the relevant FIU in Country X.
Indicators: • Large remittances from offshore • Large refund claims from taxation authority without corresponding trading activity • Shell companies which are incurring losses or not operating Possible Offence: • Tax related offence/tax evasion in Fiji and Country Person B also sent large remittances from Country X to himself, his companies and Person C, his associate amounting to more than $750,000.00 X • Money laundering Claimed refund of more than $110,000 FRCS Property/wealth - $1.8m Associate in Fiji Director Person C Business interests in Fiji Sole proprietor for real estate business Two Companies - related to construction industry.
No significant business activity and making losses Person B Person B resides in Country X Country X Remittances totalling more than $750,000 from 2015 to 2020 by Person B ?
Possible links to other businesses in Country X 82 83 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Case Study 5: Convicted Minds Person W, a finance clerk for Company A was reported in two STRs for attempting to conduct large cash deposits into Company A’s bank account and for unusual account activity in her personal bank account.
In June 2019, Person W attempted to deposit $150,000.00 into Company A’s bank account and upon interview with the bank officer, Person W stated that she was unaware of the source of funds.

The transaction was declined by the bank.

bank accounts within three months from various mining companies.

These deposits were followed by subsequent withdrawals totalling $3.9 million.

The Fiji FIU established that Company A and Person Z were unrelated and the reason for the large transfers remain unknown.
A case dissemination report was provided to the FPF for further profiling.

Indicators: In January 2020, Person W deposited $6,747.97 into her personal bank account and stated that the money was allegedly given by a friend to pay for her university fees.
• Large unexplained cash transactions • Unusual account activity by Person W who attempted to deposit a large amount of cash into Company A’s account Subsequently, Company A, which is involved in the mining industry, was also brought to the attention of the Fiji FIU for issuing bank drafts to Person Z. Profiling for Person Z revealed that he was previously convicted of money laundering.
Further analysis revealed that multiple deposits totalling $2.7 million were made into Company A’s • Person Z and Company A are unrelated • Previous convictions noted for Person Z Possible offence: • Money laundering • Tax related offences/tax evasion Person W Finance Clerk $150,000.00 $6,717.97 Person W’s bank account CONVICTED Person Z Director $3.9m ?
Mining companies Company A Employer Bank Drafts $2.7m Company A’s bank account 84 85 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Case study 6: Evasion and elusion Company F was reported for making advance payments to overseas suppliers and failing to produce customs entries on a timely basis to its bank.
Fiji FIU analysis showed movement of funds from the company loan bank account to the daily administration bank account of Company F. Profiling revealed that Company F stopped importing in 2016 and began trading as Company B since 2015.

It was further established that Company B was classified as a hotelier and that Service Turnover Tax (STT) and Environment & Climate Adaptation Levy (ECAL) was now applicable to Company B.
The Fiji FIU established that Company B did not lodge its STT and ECAL since 2015-2019.

A case dissemination report was sent to the local taxation authority for further investigation.

Indicators: Case Study 7: Unusual Account Activity The Fiji FIU received a STR that highlighted bank account transactions which seemed suspicious in nature.

It was reported that Person J, a pilot by profession, was conducting online telegraphic payments on the same day that deposits were made to Person J’s bank account.
Deposits were being made by Person K, who is the spouse of Person J.

The couple had four joint home loan accounts which were paid off within 18 to 36 months of account opening.

Each home loan amount averaged approximately $175,000.00.

Further perusal of Person K’s bank accounts showed substantial unexplained cash deposits since 2012.

It was noted that approximately $380,000.00 deposited in Person K’s personal bank accounts from 2018 till 2020.
The Fiji FIU established that Person K was registered as a Lodgement Not Necessary type taxpayer indicating that she was unemployed.

Additionally it was also established that Person J’s income tax lodgements were due since 2018.

A case dissemination report was provided to FRCS for further profiling.
• Failure to produce customs entries • No lodgement made to tax authority Indicators: Possible offence: • Tax related offence/tax evasion • Trade-based money laundering • Unusual pattern of account activity • Frequent and unusual deposits which is not commensurate with customer profile • Quick turnarounds substantial amounts for loan repayments of Possible Offence: • Possible tax related offence/tax evasion • Money laundering • Unexplained wealth 84 85 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Case Study 8: Cash and Collusion law Person M, employed as an officer with enforcement was brought to the attention of the Fiji FIU in two STRs for receiving several deposits into her personal bank account through a local Post Office.
Person M maintained two bank accounts with Bank C and it was noted that deposits made into her operating account were immediately transferred to her savings account.

Person T, the Town Q post master reportedly advised Bank C that Person M was transferring cash from her Bank F account with the intention of closing the account as Bank F reportedly had no service in Town Q.
Bank statement analysis of Person M’s bank accounts did not corroborate with the claim since there were no transfers of similar amounts being made from her Bank F account to her Bank C account.

We established that Person M received funds totalling approximately $53,000.00 from January 2019 to May 2020 into her Bank C account through deposits being made by the Town Q Post Office and internet banking transfers which were not her normal salary deposits.
Furthermore, the Fiji FIU established that her total declared income for 2019 was approximately $24,000.00.

It appeared that the Person M and Person T were colluding in the criminal activity.

A case dissemination report was provided to the FPF for their profiling and investigation.
Indicators: • Unusual pattern of account activity • Substantial unexplained deposits which were not salary or wages • Tax lodgement amounts were much lower than what was being received into bank accounts Possible Offence: • Money laundering • Unexplained wealth • Obtaining financial advantage via deception • Corruption, bribery owns Colluding Town Q Post Office Person T Person M Bank C account Bank F account $53,000.00 from January 2019 to May 2020 No evidence of transfers between accounts 86 87 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Case Study 8: Money Laundering through Real Estate Transactions Persons A, B, Y and Z, who are foreign nationals, were reported to the Fiji FIU in a STR for a possible case of money laundering involving a real estate transaction of over $2.8 million.
Person A attempted to purchase a property for $12.5 million.

Person A and another unknown individual met with the real estate agent regarding the property deal.

Further checks with national and international law enforcement agencies revealed that Person A allegedly worked with an organised crime syndicate involved in illicit importations of drugs in Country Y, and that Person B and Person Z are Country Q nationals issued with Country E citizenship.
Additionally, it was established that Person B was a red notice fugitive in Country Q, who was using fake identification documents in Fiji.

Person B was deported to Country Q in January 2020.

In January 2020, Person A arranged funding through Person Y in Country Q, who remitted over $2.8 million directly into the real estate agency’s trust account as the deposit payment.
Person A stated that Person B, who was his business partner in Country E, would be listed as the owner of the property in the sale and purchase (S&P) agreement.
When the offer by Person A was not accepted by the vendors of the property, he instructed the real estate agency to refund the deposit amount to another individual, Person Z in Country Q. Fiji FIU analysis revealed that Person A was the only party communicating with the real estate agency through email and instant messaging applications, which did not include Persons B, Y and Z.

It appeared that Person A was the main party in control of the real estate transaction.
Interestingly, Persons A and B had never travelled to Fiji.
Indicators: • Unrelated parties engaged financially in the real estate investment • Party liaising with realtor is not the purchaser on the S&P agreement • Communication is between one party and the real estate agency, and excludes the other parties engaged in the real estate investment • High value real estate transaction conducted by the purchaser is not facilitated through a legal representative • Fake identification documents and use of aliases Possible offence: • Money laundering Fiji Country I Country Q Country E Real Estate Agent Person A Person Y Person B Over $2.8 million Proposed Title Holder Over $2.8 million Person Z Real estate selling for $12.5 million 86 87 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 9 GLOSSARY AFI Alliance for Financial Inclusion FIU Financial Intelligence Unit AML Anti-Money Laundering FNIC Fijian National Identity Card AMS Alert and Monitoring System FRCS Fiji Revenue and Customs Service APG Asia/Pacific Group on Money Laundering FUR Follow-Up Report APIFIU Association of Pacific Islands FIUs FPF Fiji Police Force AUSTRAC Australian Transaction Reports and Analysis Centre FTR Financial Transactions Reporting BCR Border Currency Report GSPWG Global Standards Proportionality Working Group CDR Case Dissemination Report IMF International Monetary Fund CFT Combating the Financing of Terrorism MER Mutual Evaluation Report CTOG Counter Terrorism Officials Working Group ML / TF Money Laundering and Terrorist Financing CTR Cash Transaction Report MOA Memorandum of Agreement DNFBP Designated Non-Financial Businesses and Professions MRSP Money Remittance Service Provider EFTR Electronic Funds Transfer Report NCLASA National Combined Law and Security Agencies ESW Egmont Secure Web NRA National Risk Assessment FATF Financial Action Task Force ODPP Office of the Director of Public Prosecutions FFIMSO Fiji FIU Information Management System Online RBF Reserve Bank of Fiji FICAC Fiji Independent Commission Against Corruption STR Suspicious Transaction Report 88 89 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 www.fijifiu.gov.fj FINANCIAL INTELLIGENCE UNIT STRATEGIC PLAN 2020-2024 Our Vision: Protecting Fiji from Money Laundering Our Strategic Pillars: Financial Intelligence Preventive Measures Technology Driven Processes Partnerships Our People 1.
Develop and disseminate intelligence Our Key Strategies: 2.

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Maximise use of our intelligence Create more awareness on money laundering Implement risk based preventive measures Enhance financial institutions understanding of their obligations Effective supervision of financial institutions Effective data reporting Innovative data analytics Improve data quality and information security Enhance information sharing Strengthen partnerships Support international AML/CFT initiatives Cultivate a skilled, motivated and high performing team Corporate governance Tower Level 5, RBF Building, Private Mail Bag Pratt Street, Suva, Fiji Phone: 322 3333 Fax: 331 6454 Email: info@fijifiu.gov.fj 88 89 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 90 91 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 Contact Information Fiji Financial Intelligence Unit Tower Level 5, RBF Building Private Mail Bag Pratt Street, Suva, Fiji Telephone: (679) 322 3333 Facsimile: (679) 331 6454 Email: info@fijifiu.gov.fj Website: www.fijifiu.gov.fj 90 91 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020 www.fijifiu.gov.fj 92 PB FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2020