Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697650178714.pdf (Bahamas)
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Management Team & Organisation Chart 3.

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9.1 Reporting Period General Findings 9.2 Detailed Statistics 9.3 9.3.1 9.3.2 9.3.3 9.3.4 9.3.5 9.3.6 9.3.7 FIU Overview 2008 Monthly Statistics of Incoming Reports Comparative Suspicious Transactions Reporting Disclosing Institutions Grounds for Suspicious Transaction Reports Type of Currency Nature of Offences – Disclosing Institutions’ Suspicion Nature of Offences – Financial Intelligence Unit’s Suspicion Nationality of Contract Partners Domicile of Contract Partners Nationality of Beneficial Owners Domicile of Beneficial Owners Suspicious Transaction Report - Trends Investigative Bodies Involved 9.3.9 9.3.10 9.3.11 9.3.12 9.3.13 9.3.14 9.3.15 Requests for Information Received 9.3.8 9.3.16 From Foreign Financial Intelligence Units Status of Requests for Information Received From Foreign Financial Intelligence Units 9.3.17 Requests for Information Sent to Foreign Financial Intelligence Units Status of Requests for Information Sent To Foreign Financial Intelligence Units Status of Requests for the Production of Information Other Statistics 9.3.18 9.3.19 9.3.20 Egmont Group 10. International 10.1 10.2 Memorandum of Understanding 10.3 Caribbean Financial Action Task Force (CFATF) 11.
Typology 12.

Short List of National Currencies 13.

Glossary of Terms Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 3 1.

MESSAGE FROM THE ACTING DIRECTOR This is the FIU’s eighth Annual Report, prepared in accordance with Section 10(1)(b) of the Financial Intelligence Act, 2000, under which the Financial Intelligence Unit (the FIU) was established.
A total of one hundred and twenty-nine (129) Suspicious Transactions Reports (STRs) were received by the FIU during 2008 compared to 125 in the previous year.

For the period under review, 37 or approximately 28% of Suspicious Transactions Reports received were forwarded to the Commissioner of Police for investigation.

As in previous years, the majority of reports received originated from the banking sector.
One hundred and eight (108) requests for assistance were received from Foreign Financial Intelligence Units (FFIUs).

These requests were processed in accordance with the FIU’s mandate.

The organization’s full time staff complement was increased to twenty (20) during the year 2008.

During the fourth quarter, the former Director, Anthony M. Johnson left the employ of the FIU.

Throughout the year, staff members participated in various seminars and courses, both locally and abroad.
On-going participation in these courses was intended to equip both technical and administrative staff with new skills in order to stay abreast of new developments in specific areas.

Licensed institutions in many areas of financial services continued to rely on the FIU for training in the prevention of money laundering and terrorism financing (AML/CFT).
In keeping with its mandate to assist the public in this regard, training was freely given by the FIU with appropriate Participation Certificates being distributed to participants.

A contract for development of the Electronic Document and Case Management System was signed on 27th December 2007 and work commenced on the same on 30th January 2008.

The system was subsequently accepted by the Financial Intelligence Unit on Thursday 19th February 2009.
The system provides for real time scanning, storage and retrieval of documents; in the process reducing the demand for storage space for physical files, as well the need to manually handle documents.
The National Strategy for the Prevention of Money Laundering and Terrorism Financing, which was developed by the FIU in conjunction with other local regulators for financial services and various other governmental departments and agencies, is now being reviewed by a Legal Sub-Committee of the Group of Financial Services Regulators (GFSR) before submission by the GFSR to the Honourable Minister.
The FIU continued its active involvement in the one hundred and seven members Egmont Group of Financial Intelligence Units via its direct participation in two of the organization’s five Working Groups, namely the Outreach Working Group and the Information Technology Working Group, and in the Egmont Committee.

In May 2008, the Director, Deputy Director and Manager, Information Technology, attended the Seventeenth Egmont Group Heads of FIU’s Meeting and Plenary, held in Seoul, Korea.
Further, in May 2008, the Deputy Director was elected Co-Vice Chair of the Egmont Committee.

During the Seoul, Korea Plenary, the FIU executed Memoranda of Understanding with the Financial Intelligence Units of Brazil, Nigeria, and Peru.

The FIU also continued its active involvement in the thirty members Caribbean Financial Action Task Force (CFATF) via its active participation in the CFATF Bi-Annual Heads of FIUs Meeting, Plenary and annual Ministerial Meeting.
Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 4 Work continues on the registration of Money Laundering Reporting Officers (MLROs) and the signing of other Memoranda of Understanding (MOUs) with foreign counterparts.

The Unit continues to develop plans for the “on-line reporting” of STRs and the development and implementation of a Business Continuity Plan.

These initiatives are all designed to enhance the FIU’s continuity and operational efficiency.
I would like to express my appreciation for the support the FIU received during 2008 from its dedicated staff, its partners in the reporting entities, as well as industry organisations, law enforcement authorities, the regulatory agencies and foreign financial intelligence units.
Additionally, the staff of the Financial Intelligence Unit and I would like to express our profound thanks to former Director Anthony M. Johnson for his invaluable contribution to the growth and development of the Financial Intelligence Unit for the period 1st November 2005 through 31st October 2008 and extend best wishes in his future endeavours.
Edward R. Smith, CFE Acting Director Financial Intelligence Unit 1st April 2009 Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 5 2.
MANAGEMENT TEAM Acting Director: Deputy Director: Legal Counsel: Accountant: Head of Analysis: Head of Operations: Mr. Edward R. Smith Mr. Edward R. Smith Mrs. Sharmie Farrington-Austin Miss Utha Butler Mr. Randy A. Taylor Miss Willamae S. G. Kemp Manager, Information Technology: Mr. Derrington A. Rahming, II ORGANIZATION CHART Director Deputy Director Legal Counsel Accountant Head of Analysis Head of Operations Manager of Information Technology Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report 3.
INTRODUCTION Page 6 The Financial Intelligence Unit Act 2000, which established the Financial Intelligence Unit, provides an adequate legal framework for the Financial Intelligence Unit to be the national centre for receiving, requesting, analysing, and disseminating disclosures of STR and other relevant information concerning money laundering or financing of terrorism activities.
The Financial Intelligence Unit Act 2000, has trail blazed the pathway for many existing and emerging Financial Intelligence Units to obtain directly from reporting parties additional information needed to properly undertake its functions, including the analysis of STRs.
The Financial Intelligence Unit provides financial institutions and other reporting parties with guidance regarding the manner of reporting, including the specification of reporting forms, and the procedures that should be followed when reporting.

The Financial Intelligence Unit’s “Suspicious Transactions Guidelines Relating to the Prevention of Money Laundering and Financing of Terrorism”, which was issued in 2007, was hailed internationally as a “must read” document by “Compliance Professionals”.
Pursuant to Section 10(2)(b) of the Financial Intelligence Unit Act 2000, the Financial Intelligence Unit prepares and submits to the Minister annually, a report which reviews its activities.

A copy of the report is laid on the table of both Houses of Parliament by the Minister and the report is made available to the public.
In preparing the annual report, the Financial Intelligence Unit takes into consideration, the international standards and requirements, and includes information in the report relating to statistics, typologies, trends and other information relating to its activities.
The activities and results reported upon in the 2008 Annual Report demonstrates that the Financial Intelligence Unit is very visible locally, regionally and internationally, and contributes to the global fight against money laundering and the financing of terrorism.

The Financial Intelligence Unit has forged an invaluable working relationship with the financial services industry in The Bahamas and continues to provide relevant AML/CFT Training without charge to participants in the industry.
The Financial Intelligence Unit is committed to its mission and mandate.

The global fight against money laundering and financing of terrorism continues, and the Financial Intelligence Unit is a very active participant in this arena.

Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 7 4.

FUNCTIONS OF THE FINANCIAL INTELLIGENCE UNIT, SECTION 4, FINANCIAL INTELLIGENCE UNIT ACT 2000 Section 4.
(1) In the exercise of its functions under subsection (2), the Financial Intelligence Unit shall act as the agency responsible for receiving, analysing, obtaining and disseminating information, which relates to or may relate to the proceeds of the offences specified in the Second Schedule.
(2) Without limiting the foregoing and notwithstanding any other law to the contrary the Financial Intelligence Unit- (a) shall receive all disclosures of information such as are required to be made pursuant to the Proceeds of Crime Act, 2000 which are relevant to its functions, including information from any Foreign Financial Intelligence Unit; (b) may upon receipt of such disclosures as are referred to in paragraph (a) order in writing any person to refrain from completing any transaction for a period not exceeding seventy-two hours; (c) may upon receipt of a request from a Foreign Financial Intelligence Unit or law enforcement authority including the Commissioner of Police of The Bahamas order any person to freeze a person’s bank account for a period not exceeding five days if satisfied that the request relates to the proceeds of any of the offences specified in the Second Schedule: Provided that an aggrieved person may apply to a judge in chambers to discharge the order of the Financial Intelligence Unit and shall serve notice on the Financial Intelligence Unit to join in the proceedings but such order shall remain in force and effect until the judge determines otherwise; (d) may require the production of such information excluding information subject to legal professional privilege that the Financial Intelligence Unit considers relevant to fulfill its functions; (e) shall retain a record of all information that it receives for a minimum of five years after the information is received; (f) shall provide information, subject to such conditions as may be determined by the Director, to the Commissioner of Police where the information may relate to the commission of an offence specified in the Second Schedule; (g) may provide information relating to the commission of an offence specified in the Second Schedule to any Foreign Financial Intelligence Unit, subject to any conditions as may be considered appropriate by the Director; (h) may enter into any agreement or arrangement, in writing, with a Foreign Financial Intelligence Unit which the Director considers necessary or desirable for the discharge or performance of the functions of the Financial Intelligence Unit; (i) shall inform the public and financial and business entities of their obligations under measures that have been or might be taken to detect, prevent and deter the commission of the offences specified in the Second Schedule.
Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 8 (3) Any person failing or refusing to provide such information as is required by paragraph (d) of subsection (2) is guilty of an offence and shall be liable on summary conviction to a fine not exceeding fifty thousand dollars or to imprisonment for a term not exceeding two years or to both such fine and imprisonment.
SECOND SCHEDULE OFFENCES Offences under the Proceeds of Crime Act, 2000 Offences under the Anti-Terrorism Act, 2004 Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 9 5.

MONEY LAUNDERING Money laundering is the practice of engaging in finance/financial transactions in order to conceal the identity, source, and/or destination of illegally gained money.
In practice, criminals are trying to disguise the origin of money obtained through illegal activities so that it looks like it was obtained from legal sources.

Otherwise, they can't use the money because it would connect them to the criminal activity, and law-enforcement officials would seize it.

Money laundering is also a crucial step in the success of drug trafficking, terrorist activities, white collar crime and other forms of criminal conduct.

The basic money laundering process has three steps: I.
Placement: At this stage, the launderer inserts the dirty money into a legitimate financial institution.

This is often in the form of cash deposits.

This is the riskiest stage of the laundering process for the launderer because large amounts of cash are pretty conspicuous, and financial institutions are required to report high-value transactions.

II.

Layering: Layering involves sending the money through various financial transactions to change its form and make it difficult to follow.
Layering may consist of several bank-to-bank transfers, wire transfers between different accounts in different names in different countries, making deposits and withdrawals to continually vary the amount of money in the accounts, changing the money's currency, and purchasing high-value items (boats, houses, cars) to change the form of the money.

This is the most complex step in any laundering scheme, and it's all about making the original dirty money as hard to trace as possible.

III.
III.

Integration: At the integration stage, the money re-enters the mainstream economy in legitimate-looking form -- it appears to come from a legal transaction arranging for the source of funds to appear legitimate without suspicion of their initial criminal source.

It is important to note that the primary purpose of organized crime is to make profits.

Like any business, the purposes of profit are to enjoy it and re-invest it in future activity.
For the organized criminal, however, profit close to the source of the crime represents a particular vulnerability and unless the criminal can effectively distance himself or herself from the crime, which is the source of the profit, they remain susceptible to detection and prosecution.

With this in mind, the aforementioned process has devastating social consequences.
For one thing, if done successfully, it allows the criminals to maintain control over their proceeds and ultimately to provide a legitimate cover for their source of income.

Money laundering plays a fundamental role in facilitating the ambitions of the drug trafficker, the terrorist, the organized criminal, the insider dealer as well as the many others who need to avoid the kind of attention from the authorities that sudden wealth brings from illegal activities.
By engaging in this type of activity it is hoped to place the proceeds beyond the reach of any asset forfeiture laws.
Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 10 FIGHTING MONEY LAUNDERING Preventative measures aimed at denying criminals the access to the financial system tend to rely heavily on the private sector’s coopeartion.With this in mind, the prime method of anti-money laundering is the requirement on financial institutions to know their customers - usually termed KYC (Know Your Customer) requirements.
With good knowledge of their customers, financial institutions will often be able to identify unusual or suspicious behaviour, including false identities, unusual transactions, changing behaviour, or other indicators that money laundering may be occurring.

But for institutions with millions of customers and thousands of customer-contact employees, traditional ways of knowing their customers must be supplemented by technology.
FINANCING OF TERRORISM Terrorist activities take money, and one way to combat terrorists is to cut off their access to funds.

Unfortunately, it is difficult to precisely define terrorist financing.

Terrorism can be conducted without large scale funding and terrorist financing does not always rely on the proceeds of crime or necessary involve money laundering.
Therefore, to understand terrorist financing, it is perhaps more useful to describe the ways funds are raised, moved and used in terrorist activity, rather than attempting to arrive at a specific definition.
Funding of terrorist organisations may be derived from crime or other lawful activities such as kidnapping and extortion, fraud, theft and narcotics trafficking, or charitable organizations, "legitimate" business fronts, such as travel agencies, convenience stores and cell phone distributors; international trade that converts cash into diamonds and gold, and the exploitation of unregulated financial markets.
A key difference between terrorist groups and traditional criminal organisations is that funding for terrorist groups may include income derived from legitimate sources (such as fundraising in the name of charitable or relief organisations) or from a combination of lawful and unlawful sources.

On 31st December 2004, the Anti Terrorism Act, 2004 was enacted within the Commonwealth of The Bahamas and the Royal Bahamas Police Force has since made counter-terrorism measures a priority.
During the year 2008, the Financial Intelligence Unit did not receive any STRs from financial institutions, which were suspected of being related to the financing of terrorism.

6.

IMPROVING THE QUALITY OF STR INFORMATION Suspicious Transaction Reports (STRs) are one of the main weapons in the fight against money laundering and other financial crimes, since these reports generate leads that law enforcement authorities use to initiate money laundering investigations.
Several key areas to note are as follow: ● It is critical that the Compliance Officer/MLRO provide the FIU with as much information as possible, highlighted by an in depth narrative outlining the series of events in relation to the suspicious activity.

Essentially, the Compliance Officer/MLRO must give a detailed narrative, which would identify the five basic elements of information – Who?

What?

When?

Where?

and Why?


Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 11 ● The reporting of suspicious transactions is not limited to cash transactions.

Transfers to and from the financial system are also under the umbrella of ‘reporting of suspicious transactions’ and this can provide useful information on the ‘layering’ stage of the money laundering process.
● The keeping of comprehensive transaction records (a requirement by law) by financial institutions provides a useful audit trail and gives useful information on persons and entities involved in laundering schemes once discovered.

● A financial institution’s compliance regime should contain ongoing compliance training, at least once a year, in order to keep staff and colleagues up to date.
Ultimately, identifying suspicious activity, and providing support to law enforcement, is critical to the FIU’s mission to safeguard the nation’s financial sector.

The ability to analyse data to identify issues, trends and patterns in STR reporting, and educate financial institutions and regulatory partners, is equally critical to our mission.

The information gained through STRs is pertinent to carrying out that mission.
Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 12 7.

TRAINING The Financial Intelligence Unit’s staff continued to take steps to ensure that training modules are available for each profession, addressing the issues of AML/CFT inherent in their various areas of activity.

Listed below are the training/presentations of the FIU for the financial sector during the year 2008.
DATES NAMES OF ORGANISATIONS February 19th 2008 March 26th 2008 April 10th 2008 April 10th 2008 April 15th 2008 May 27th 2008 May 28th 2008 June 4th 2008 June 18th 2008 July 1st 2008 July 2nd 2008 September 15th 2008 September 17th 2008 September 23rd 2008 September 25th 2008 October 1st 2008 October 2nd 2008 November 10th 2008 November 11th 2008 November 11th 2008 November 25th 2008 November 25th 2008 December 9th 2008 Bank of The Bahamas College of The Bahamas Bank of Baroda AJK Corporate Services Ltd. Providence Advisors Crystal Palace Resort & Casino Crystal Palace Resort & Casino State Bank of India Bahamas Association of Compliance Officers Crystal Palace Resort & Casino Crystal Palace Resort & Casino Credit Suisse Trust Limited Butterfield Private Bank (Bahamas) Limited Private Investment Bank Limited Grand Bahama Development Company Ltd.
The Private Trust Corporation Limited Butterfield Bank (Bahamas) Limited Julius Baer Bank & Trust (Bahamas) Limited Julius Baer Bank & Trust (Bahamas) Limited Royal Bank of Canada Wealth Management Butterfield Private Bank (Bahamas) Limited Credit Suisse (Bahamas) Limited Credit Suisse (Bahamas) Limited NUMBER OF PARTICIPANTS 21 35 1 4 6 68 70 6 90 50 50 19 34 10 40 33 35 13 13 60 9 150 30 Total number of persons trained: 847 Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 13 8.
TRAINING, SEMINARS, CONFERENCES AND MEETINGS ATTENDED BY STAFF MEMBERS OF FIU DATE INSTITUTION January 22nd – 25th 2008 Department of Public Personnel February 6th – 8th 2008 March 11th – 13th 2008 Multijurisdictional Counterdrug Task Force Egmont Group March 16th – 19th 2008 Money Laundering Alert March 31st – April 4th 2008 Commonwealth Office, Justice Training Institute April 22nd 2008 May 5th – 8th 2008 Bahamas Association of Compliance Officers & Central Bank of The Bahamas Caribbean Financial Action Task Force (CFATF) May 20th – 22nd 2008 Department of Public Personnel May 25th – 29th 2008 Egmont Group July 17th – 18th 2008 September 8th – 10th 2008 September 9th -11th 2008 Inter-America Drug Abuse Control Commission (CICAD) Association of Anti- Money Laundering Specialists (ACAMS) Multijurisdictional Counterdrug Task Force NATURE AND LOCATION 21st Century Service & Front Desk Reception Seminar Nassau, Bahamas Financial Investigative Techniques El Paso, Texas, USA Egmont Committee & Working Groups Meetings Santiago, Chile Conference & Exhibition Hollywood, Florida, USA Training of Trainers & Specialist Programme for Capacity Building in Combating Terrorism Kingston, Jamaica Risk Based Approach in KYC/CDD Nassau, Bahamas Plenary & Heads of FIU Meetings Port Au Prince, Haiti Basic Work Improvement Nassau, Bahamas 16th Egmont Plenary Seoul, Korea Capacity Building Workshop Nassau, Bahamas 7th Annual Conference & Exhibition Las Vegas, Nevada, USA International Money Laundering Investigation San Antonio, Texas, NUMBER OF PARTICIPANTS One (1) Two (2) Two (2) Three (3) One (1) Five (5) One (1) One (1) Three (3) One (1) One (1) One (1) Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 14 October 13th -17th 2008 United Nations Office on Drugs & Crime (UNODC) October 13th – 17th 2008 Multijurisdictional Counterdrug Task Force October 20th – 23rd 2008 Egmont Group October 21st – 23rd 2008 Department of Public Personnel October 27th -29th 2008 November 17th – 21st 2008 Caribbean Technical Assistance Centre (CARTAC ) & Caribbean Financial Action Task Force (CFATF) Caribbean Financial Action Task Force (CFATF) USA Workshop for Caribbean Countries on Countering Terrorism Financing St. John’s, Antigua & Barbuda International Money Laundering Investigation Course Mahwah, New Jersey, USA Egmont Committee & Working Groups Meetings Toronto, Canada Enhancing Your Professional Image Nassau, Bahamas Prevention of Money Laundering and Terrorist Financing at Casinos & Remote Gambling Venues Nassau, Bahamas Plenary, Ministerial & Heads of FIU Meetings Basseterre, St. Kitts & Nevis One (1) Two (2) Two (2) One (1) Three (3) One (1) Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 15 9.
ANNUAL STATISTICS OF THE FINANCIAL INTELLIGENCE UNIT 9.1 REPORTING PERIOD The reporting period has been defined as being the period 1st January to 31st December 2008.

9.2 GENERAL FINDINGS A total of one hundred and twenty-nine (129) Suspicious Transaction Reports were received by the FIU during the year under review.

[The status of the reports includes the FIU’s processing of the reports up to 31st March 2009.]
• Thirty-seven (37) of the reports were forwarded to the Commissioner of Police for investigation.

• Thirty-eight (38) of the reports were analyzed and closed by the FIU.

• Fifty-four (54) of the reports are pending.

There was an increase of approximately 3% in Suspicious Transaction Reports.

By comparison, a total of one hundred and twenty-five (125) Suspicious Transaction Reports were made to the Financial Intelligence Unit for the period 1st January to 31st December 2007.
For the period under review, approximately 28% of the Suspicious Transaction Reports were forwarded to the Commissioner of Police for investigation.
Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 16 9.3 DETAILED STATISTICS 9.3.1 OVERVIEW OF 2008 SUMMARY CALENDAR YEAR (1st January – 31st December 2008) NUMBER OF REPORTS Absolute Relative 2008 Total Received Passed onto the Police Closed Pending TYPE OF INSTITUTION Casino Domestic Banks Domestic/Offshore Banks Offshore Banks Real Estate Agent/Broker Trust Companies 129 37 38 54 1 16 52 51 1 8 100.00% 28.68% 29.46% 41.86% 0.78% 12.40% 40.31% 39.53% 0.78% 6.20% REPORTED VALUES IN BSD (Total Effective Assets At Time Of Report) Grand Total Total reports passed onto the Police Total reports closed Total reports pending $4,112,842,299.00 6,755,969.00 91,962,607.00 4,014,123,723.00 100.00% 0.16% 2.24% 97.60% Average value of report (total) Average value of reports passed onto Police Average value of reports closed Average value of reports pending $31,882,498.44 182,593.76 2,420,068.61 74,335,624.50 Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 17 9.3.2 MONTHLY STATISTICS OF INCOMING REPORTS WHAT DOES THE GRAPH REPRESENT?
The graph shows the monthly totals of Suspicious Transaction Reports for the year 2008.

WHAT DOES THE GRAPH INDICATE?

There was a total of one hundred and twenty-nine (129) Suspicious Transaction Reports received during 2008.

The number of reports fluctuated from month-to-month throughout the entire year averaging approximately ten (10) reports per month.

The majority of the reports were received during February, June, August, September and October.
STR's Received 2008 15 14 13 14 12 11 11 10 10 9 6 4 January February March April May June July August September October November December 16 14 12 10 8 6 4 2 0 Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 18 9.3.3 COMPARATIVE SUSPICIOUS TRANSACTIONS REPORTING WHAT DOES THE GRAPH REPRESENT?

The graph shows a comparison of the monthly totals of Suspicious Transaction Reports for the years 2006 through 2008.

WHAT DOES THE GRAPH INDICATE?


The number of reports fluctuated from month-to-month throughout the years 2006-2008.
Comparative STR Reporting 2006 ‐ January February March April May June July August September October November December Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 19 9.3.4 DISCLOSING INSTITUTIONS WHAT DOES THE GRAPH REPRESENT?

The graph gives a breakdown of the Suspicious Transaction Reports filed by financial institutions.
WHAT DOES THE GRAPH INDICATE?

The Banks submitted the greatest number of the reports (92.25%), and the remainder was received from other financial institutions.

Type of Disclosing Institutions 1 1 8 119 BANK CASINO REAL ESTATE AGENT/BROKER TRUST COMPANY Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 20 9.3.5 GROUNDS FOR SUSPICIOUS TRANSACTION REPORTS WHAT DOES THE GRAPH REPRESENT?
The graph shows the reasons that prompted the financial institution to file Suspicious Transaction Reports.

WHAT DOES THE GRAPH INDICATE?

As in previous years, during the year 2008, the industry saw the continued application of enhanced due diligence policies.

The Financial Intelligence Unit’s Anti-Money Laundering and Suspicious Transaction Guidelines provided financial institutions with a wide category of grounds for disclosure of Suspicious Transaction Reports.
Grounds for Disclosure 32 16 10 5 2 2 2 1 26 24 9 35 30 25 20 15 10 5 0 ACCOUNT ACTIVITY NOT IN KEEPING WITH KYC CASH TRANSACTIONS EVIDENCE OF FORGED DOCUMENTS FAILURE TO COMPLY WITH DUE DILLIGENCE CHECKS GROUP INFORMATION INTERNET SEARCH MEDIA/PUBLICITY OTHER GROUNDS POLICE INQUIRY SERVICE OF INVESTIGATION OF FRAUD ORDER SERVICE OF PRODUCTION ORDER Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 21 9.3.6 TYPE OF CURRENCY WHAT DOES THE GRAPH REPRESENT?
The graph provides a breakdown of the various currencies, which were utilised in facilities, the subject of the Suspicious Transaction Reports.

WHAT DOES THE GRAPH INDICATE?

The BSD and USD were utilized in 42.64 % and 39.58 % respectively, of the facilities subject of the reports and the remainder was a mixture of several other currencies.
Type of Currency 55 51 8 9 2 2 2 60 50 40 30 20 10 0 BAHAMIAN DOLLAR CANADIAN DOLLAR SWISS FRANCS EURO BRITISH POUND STERLING NOT APPLICABLE/ NO CURRENCY INVOLVED UNITED STATES DOLLAR Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 22 9.3.7 NATURE OF OFFENCES – DISCLOSING INSTITUTIONS’ SUSPICION WHAT DOES THE GRAPH REPRESENT?
The graph shows the offences suspected by the financial institution of having been committed at the time the reports were submitted to the Financial Intelligence Unit.

WHAT DOES THE GRAPH INDICATE?

In approximately 44.19% of cases, the financial institution at the time it submitted the Suspicious Transaction Report, did not know the nature of the offence.

Thus, other suspicious circumstances led to the filing of the reports.
Fraud and Drugs were suspected in 30.23% and 14.73% respectively of the reports received.

It should be noted that the suspicions of a financial institution at the time of submission of the reports to the Financial Intelligence Unit, might differ from those of the Financial Intelligence Unit during analysis of the said reports.
Criminality Suspected by Disclosing Institutions 57 4 19 9 1 39 CORRUPTION DRUGS FRAUD HUMAN TRAFFICKING OTHER UNKNOWN/UNDETERMINED Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 23 9.3.8 NATURE OF OFFENCES – FINANCIAL INTELLIGENCE UNIT’S SUSPICION WHAT DOES THE GRAPH REPRESENT?
The graph shows the offences suspected by the Financial Intelligence Unit of having been committed upon completion of analysis of the reports, or upon receipt of other financial or criminal intelligence.

WHAT DOES THE GRAPH INDICATE?

The Financial Intelligence Unit did not detect any criminal activity in 46.51% of the Suspicious Transactions Reports received.

Fraud and drugs were detected in 27.91% and 15.50% respectively of the reports received.
Criminality Suspected by FIU 4 20 60 CORRUPTION DRUGS FRAUD HUMAN TRAFFICKING OTHER OFFENCES UNKNOWN/UNDETERMINED 36 8 1 Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 24 9.3.9 NATIONALITY OF CONTRACT PARTNERS WHAT DOES THE GRAPH REPRESENT?

The graph shows the nationality of contract partners who were the subjects of the Suspicious Transaction Reports.

WHAT DOES THE GRAPH INDICATE?


Bahamians represented 55% of the contract partners, 20.93% were citizens from Canada and the USA, whereas the others were from various countries around the world.
Nationality of Contract Partners ANGUILLA BAHAMAS BELGIUM BELIZE CANADA CAYMAN ISLANDS COSTA RICA GERMANY GUATEMALA HAITI ITALY MEXICO NETHERLANDS ANTILLES PANAMA PERU SWITZERLAND TURKEY UNITED KINGDOM UNITED STATES OF AMERICA UNKNOWN VIRGIN ISLANDS, BRITISH Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 25 9.3.10 DOMICILE OF CONTRACT PARTNERS WHAT DOES THE GRAPH REPRESENT?
The graph shows the domicile of contract partners who were the subjects of the Suspicious Transaction Reports.

WHAT DOES THE GRAPH INDICATE?

Residents of The Bahamas represented 58.91% of the contract partners, 20.93% were residents of Canada and the USA, whereas the others were from various countries around the world.
Domicile of Contract Partners 76 18 9 1 1 2 1 1 1 1 3 3 3 2 4 2 1 80 70 60 50 40 30 20 10 0 ANGUILLA BAHAMAS BELIZE CANADA CAYMAN ISLANDS COSTA RICA GUATEMALA HAITI ITALY NETHERLANDS ANTILLES PANAMA PERU SWITZERLAND UNITED STATES OF AMERICA UNKNOWN VENEZUELA VIRGIN ISLANDS, BRITISH Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 26 9.3.11 NATIONALITY OF BENEFICIAL OWNERS WHAT DOES THE GRAPH REPRESENT?
The graph shows the nationality of beneficial owners who were the subjects of the Suspicious Transaction Reports.

WHAT DOES THE GRAPH INDICATE?

Bahamians represented 41.86% of the beneficial owners, 27.91% were citizens of Canada and the USA, whereas the others were from various countries around the world.
Nationality of Beneficial Owners ANGUILLA ARGENTINA BAHAMAS BELGIUM BERMUDA BRAZIL CANADA COSTA RICA GERMANY GUATEMALA HAITI HONG KONG ITALY MEXICO NETHERLANDS PERU SWITZERLAND TURKEY UNITED KINGDOM UNITED STATES OF AMERICA UNKNOWN VENEZUELA VIRGIN ISLANDS, BRITISH Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 27 9.3.12 DOMICILE OF BENEFICIAL OWNERS WHAT DOES THE GRAPH REPRESENT?
The graph shows the domicile of beneficial owners who were the subjects of the Suspicious Transaction Reports.

WHAT DOES THE GRAPH INDICATE?

Residents of The Bahamas represented 49.61% of the beneficial owners, 27.13% were residents of Canada and the USA, whereas the others were from various countries around the world.
Domicile of Beneficial Owners 64 ANGUILLA ARGENTINA BAHAMAS BRAZIL CANADA COSTA RICA GERMANY GUATEMALA HAITI HONG KONG ITALY MONACO PANAMA PERU 17 18 SWITZERLAND UNITED KINGDOM UNITED STATES OF AMERICA UNKNOWN VENEZUELA 5 VIRGIN ISLANDS, BRITISH 1 1 2 3 1 1 1 1 2 1 1 3 3 1 2 1 70 60 50 40 30 20 10 0 Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 28 9.3.13 SUSPICIOUS TRANSACTION REPORTS - TRENDS WHAT DOES THE GRAPH REPRESENT?
The graph shows the status of the customers of the financial institutions who were the subjects of the Suspicious Transaction Reports.

WHAT DOES THE GRAPH INDICATE?

Long-standing customers of the disclosing institutions accounted for 52.71% of the reports received, whereas new customers accounted for 34.88% of the reports.
Type of Trends 68 45 1 2 8 5 70 60 50 40 30 20 10 0 ELECTRONIC BANKING INVOLVING AT LEAST ONE INTERMEDIARY LONG STANDING CUSTOMER NEW CUSTOMER NO RELATIONSHIP PROPOSED CUSTOMER Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 29 9.3.14 INVESTIGATIVE BODIES INVOLVED The Royal Bahamas Police Force is the sole agency in The Commonwealth of The Bahamas charged with the responsibility of investigating criminal offences under the Proceeds of Crime Act, 2000 and the Anti Terrorist Act, 2004.
Two specialist bodies exist within the agency, mandated to investigate financial crimes: the the Tracing and Commercial Crime Section of Forfeiture/Money Laundering Investigation Section of the Drug Enforcement Unit.

the Central Detective Unit, and A total of thirty-seven (37) Suspicious Transaction Reports were forwarded by the Financial Intelligence Unit to the Police for investigation.
STRs Forwarded to Police 2006 ‐ 2008 (Updated) 46 35 37 2006 2007 2008 50 45 40 35 30 25 20 15 10 5 0 Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 30 9.3.15 NUMBER OF REQUESTS FOR INFORMATION RECEIVED FROM FOREIGN FINANCIAL INTELLIGENCE UNITS WHAT DOES THE GRAPH REPRESENT?

The graph shows the countries from which the FIU received requests.

WHAT DOES THE GRAPH INDICATE?

There were one hundred and eight (108) requests.


(AMLD), the FIU of Taiwan, followed by the Financial Intelligence Units of the USA (FinCEN), Canada (FINTRAC), Turks & Caicos Islands (FCU), Argentina (UIF), Belgium (CTIF-CFI) and Jersey (FCU) submitted 63.89% of requests.
Requests Received from Foreign FIUs 33 14 35 30 25 20 15 10 5 0 ALBANIA ANGUILLA ARGENTINA AUSTRALIA AUSTRIA BELGIUM BELIZE BERMUDA BULGARIA CANADA CHILE COLOMBIA DENMARK FINLAND GEORGIA GUATEMALA HUNGARY INDIA ISLE OF MAN ISRAEL ITALY JERSEY LEBANON LIECHTENSTEIN NIGERIA PORTUGAL QATAR RUSSIA ST. VINCENT & THE GRENADINES SERBIA SPAIN SWITZERLAND TAIWAN TURKS & CAICOS ISLANDS UKRAINE UNITED KINGDOM UNITED STATES OF AMERICA VENEZUELA MONTENEGRO Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 31 9.3.16 STATUS OF REQUEST FOR INFORMATION RECEIVED FROM FOREIGN FINANCIAL INTELLIGENCE UNITS WHAT DOES THE GRAPH REPRESENT?
The graph gives a breakdown of the status of the requests received.

WHAT DOES THE GRAPH INDICATE?

The financial intelligence unit provided assistance in 87.96% of the requests, which were received.

9.26% of the requests were denied and 2.78 % of the requests were withdrawn.
Status of Requests Received from Foreign FIUs 10 3 95 GRANTED DENIED WITHDRAWN Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 32 9.3.17 REQUEST FOR INFORMAITON SENT TO FOREIGN FINANCIAL INTELLIGENCE UNITS WHAT DOES THE GRAPH REPRESENT?

The graph shows the countries to which the FIU submitted requests.

WHAT DOES THE GRAPH INDICATE?

There were fifteen (15) requests.

FinCEN, the FIU of the USA was the recipient of the majority of the requests.
Requests Made to Foreign FIUs 6 6 5 4 3 2 1 0 1 1 1 1 1 1 1 1 1 BRAZIL CANADA COSTA RICA GERMANY ITALY PANAMA SWITZERLAND TURKEY UNITED KINGDOM UNITED STATES OF AMERICA Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 33 9.3.18 STATUS OF REQUESTS FOR INFORMATION SENT TO FOREIGN FINANCIAL INTELLIGENCE UNITS WHAT DOES THE GRAPH REPRESENT?

The graph gives a breakdown of status of the requests submitted.

WHAT DOES THE GRAPH INDICATE?


The financial intelligence unit received assistance in 93.33% of the requests, which were submitted.

One (1) of the requests was denied.

Status of Requests Made to Foreign FIUs 1 14 GRANTED DENIED Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 34 9.3.19 STATUS OF REQUESTS FOR THE PRODUCTION OF INFORMATION WHAT DOES THE GRAPH REPRESENT?

The graph shows that a total of two hundred and seven (207) requests were made.
WHAT DOES THE GRAPH INDICATE?

Responses, which provide relevant information, were received in respect to 99.52% of the requests, while one (1) request was withdrawn by the FIU.

Status of Request for Production of Information 250 200 150 100 50 0 206 1 GRANTED WITHDRAWN Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 35 9.3.20 OTHER STATISTICS During the year under review, a total of twenty-two (22) Requests for Assistance were received from the Royal Bahamas Police Force.
Assistance was granted in nineteen (19) of the Requests and three (3) Requests were denied.

A total of two (2) Seventy-two hours Restraint and one (1) Five days freeze were issued to financial institutions by the Financial Intelligence Unit, which related to assets amounting to BSD 24,195,918.03, which resulted in one Restraint Order being requested of and issued by the Supreme Court of The Bahamas, relating to assets in the amount of BSD 19,992,722.00.
Further, two (2) Spontaneous Disclosures were made to Foreign Financial Intelligence Units by the Financial Intelligence Unit.

Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 36 10. INTERNATIONAL 10.1 EGMONT GROUP The Financial Intelligence Unit of The Bahamas is an active participant in the Egmont “Outreach” and “Information Technology” Working Groups and the Egmont Committee.
The FIU continues to co-monitor and co-sponsor with the FIU of BVI (FIA), the FIUs of Guyana, Montserrat, St. Lucia, and Trinidad & Tobago, with the FIU of the USA (FinCEN), the FIU of Dominican Republic, and with the FIU of Canada (FINTRAC) the FIU of Haiti and Jamaica for membership in the Egmont Group.

Additionally, the FIU and the FIU of Canada (FINTRAC) successfully sponsored the FIU of Turks & Caicos Islands (FCU) for membership in the Egmont Group during the year 2008.
The FIU was elected to serve in the following positions within the Egmont Group: - Vice Chair, Outreach Working Group, 2004-Present - Co-Regional Representative for the Americas Region, 2005-Present - Co-Vice Chair of the Egmont Committee, 2008-Present 10.2.

MEMORANDUM OF UNDERSTANDING During the Egmont Plenary, held in Seoul, Korea in May 2008, the FIU signed Memoranda of Understanding for the sharing of information with the financial intelligence units of Brazil, Nigeria and Peru.
Negotiations with other Units with a view to signing Memoranda of Understanding for the sharing of information are ongoing.

10.3.

CARIBBEAN FINANCIAL ACTION TASK FORCE (CFATF) The CFATF is comprised of thirty member countries whose goal is to develop and promote strategies in the fight against Money Laundering and the Financing of Terrorism at national, regional and international levels.

The Bahamas is an active member of CFATF.


The Bahamas’ FIU participates in the Plenary, Typology and Heads of FIUs Meetings of CFATF.

Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 37 11.

TYPOLOGY 1.

FRAUD A financial institution in country ‘A’ was approached by subjects ‘X’ and ‘Y’ who expressed a desire to establish a relationship with the financial institution.
Subject ‘X’ purported to be an attorney-at-law, practicing in country ‘B’, and advised that subject ‘Y’ was a client.

The subjects indicated that they were interested in establishing corporate accounts in the names of companies ‘AA’ and ‘BB’, which were alleged to be domiciled in country ‘B’.

The subjects presented documents relating to USD $20 billion and advised that the funds were to be placed into accounts in the names of companies ‘AA’ and “BB’.
The said funds were alleged to have been deposited in cheques at a major financial institution in country ‘B’.

Subject ‘Y’ advised the financial institution that subject ‘Z’ was a partner in the relationship.

The subjects were requested to complete and return the documentation requested by the financial institution to establish the relationship.
The financial institution became suspicious of the documentation relating to the USD $20 billion and reported the matter to the national financial intelligence unit.

In the interim, the subjects never completed and returned the documentation, which was requested by the financial institution.
An analysis of the report by the national financial intelligence unit revealed the following: - During the year 2003, the central bank in country ‘C’ warned of a scam relating to the counterfeiting of its government’s bonds.

- The warning also advised that subject ‘Z’ and others were involved in the scam.

- As a result of the subjects’ worldwide scam, the authorities in countries ‘B’ and ‘D’ also issued warnings relating to the scam.
- The signatures of various officials in countries ‘B’ and ‘C’ were discovered to have been forged and affixed to the fraudulent documents.

The financial institution in country ‘A’ declined the relationship proposed by the subjects and the national financial intelligence unit submitted the report to law enforcement authorities for investigation.

Law enforcement authorities in country ‘A’ continue to collaborate with its international counterparts in an effort to apprehend the culprits.
CONCLUSION: The actions of the financial institution prohibited the subjects from perpetrating a fraud on the financial institution and others.

2.

SUSPICIOUS CASH TRANSACTIONS Subject ‘X’, is the holder of several accounts in a financial institution in country ‘A’.

In exercising its KYC and CDD procedures on subject “X’, the financial institution was satisfied with the declared source of funds to be deposited to the accounts.
However, subsequent to the establishment of the relationship with the financial institution, subject ‘X’ approached the Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 38 financial institution and attempted to deposit $30,000.00 in cash to one of the accounts.

This led the financial institution to question the source of funds, to which the subject became uncooperative.

As a result the financial institution declined the deposit of $30,000.00.
Subsequently, the subject went to another branch of the financial institution and deposited the sum of $30,000.00 in tranches of $10,000.00 each over a period of three consecutive days.

The subject during the latter period declared the source of funds as being from an ASUE (Informal Group Savings) and provided a contract as supporting document for the source of funds.
A review of the subject’s accounts by the financial institution revealed that based upon the subject’s known income, the deposit of $30,000.00 and the behaviour of the subject; the cash deposit was highly suspicious.

Thus, the financial institution reported the matter to the national financial intelligence unit.

An analysis of the report by the national financial intelligence unit revealed that the subject had deposited more than $45,000.00 to the account during a one-month period.
Further, that the subject’s known income could not account for the volume of financial activity being transacted by the subject with the financial institution.

Thus, the national financial intelligence unit submitted the report to the law enforcement authorities for investigation.

Law enforcement authorities’ investigation is ongoing.

CONCLUSION: The actions of the financial institution were appropriate in that a substantial cash transaction was being attempted.
When questioned about the source of funds, the subject became very uncooperative.

The subject subsequently approached another branch of the financial institution with an ASUE (Informal Group Savings) Contract, which was questionable and structured the deposits in tranches of $10,000.00 over a three-day period.

Why didn’t the subject produce or provide information about the contract at the time of the attempt to deposit $30,000.00 cash?

What was the source of the $30,000.00 cash?


These are matters and questions to be considered by law enforcement authorities.

3.

FRAUD Subject ‘Z’ is a long standing customer of a financial institution in country ‘C’.

The local media in country ‘C’ reported on the arrest of the subject and others, who were charged before the local court with offences relating to conspiracy to commit fraud.
It was reported that the subject and four (4) other persons attempted to defraud a local merchant of goods in the amount of $311,500.00.

The means of payment was a purported Manager’s Cheque, allegedly issued by a branch of the financial institution and made payable to the merchant.

The cheque was found to be a bogus item, thus, the financial institution made a report to the national financial intelligence unit.

An analysis of the report revealed the Manager’s Cheque to be a bogus instrument.
The subject and others pleaded not guilty during their arraignment in court and were subsequently released on bail pending trail.

The trial is still pending before the court.

CONCLUSION: The actions of the merchant in this matter are commendable.

Suspicion was aroused due to the nature of the purchase and payment method.
The Manager’s Cheque was scrutinized by the merchant, who asked additional questions of the subject, which led to the merchant contacting the police who apprehended the subject and others.

Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 39 4.

FRAUD Subject ‘Y’ was a customer of good standing in a financial institution in country ‘A’.

Subject ‘Y’ received a modest income, which was deposited regularly into an account maintained by the subject at a financial institution.
The income was always from the same reliable and trusted source.

Therefore, when the subject suddenly deposited a cheque in the amount of USD $25,000.00, allegedly drawn on a financial institution in country ‘B’, the financial institution’s suspicion was aroused.

Shortly after the deposit of the aforementioned cheque, the subject approached the financial institution and attempted to cash twenty-four (24) American Express Travellers Cheques payable to the subject, each in the amount of USD $500.00.
The subject’s actions further heightened the financial institution’s suspicions.

The financial institution made inquiries in respect to the travellers cheques and discovered that the cheques were fraudulent.

As a result, the financial institution made a report to the national financial intelligence unit.
An analysis of the report was conducted by the national financial intelligence unit and it was discovered that the subject had also deposited three (3) Money Gram Money Orders, payable to the subject in the amount of USD $915.00 each to the said account just prior to the deposit of the USD cheque in the amount of $25,000.00.

All of the instruments were deemed to be fraudulent.
The national financial intelligence unit submitted the report to the law enforcement authorities for investigation and the investigation is ongoing.

CONCLUSION: The report by the financial institution brought to light a known method of smurfing, which is used by money launderers.

However, in this case the purported monetary instruments were bogus.

Thus, this leads to questions about the subject’s possible involvement with others in a conspiracy to commit fraud.
Law enforcement authorities ought to find it not very difficult to conclude their investigation into this matter.

5.

DRUG TRAFFICKING ‘X’, who is a national of country ‘A’ and resided in country ‘B’, was indicted in country ‘C’ for drug trafficking offences.

The indictment alleged that ‘X’ was one of the main suppliers of cocaine to country “C’ during the 1990’s and further alleged that ‘X’ had a history of violence, money laundering and committing murder.
After being indicted in country ‘C’, ‘X’ fled from country ‘B’ and became a fugitive.

While a fugitive, ‘X’ assumed a second name and nationality and purported to be a national of country ‘B’.

During that time ‘X’ approached several financial institutions in country ‘D’ and established financial facilities using the assumed name and identification.

With the use of the assumed name, ‘X’ went undetected and the financial institutions’ KYC and CDD revealed nothing of an adverse nature in respect to ‘X’.
Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 40 During the latter part of the year 2008, ‘X’ was apprehended in country ‘E’ by the authorities acting in concert with the authorities of country ‘C’ and it was discovered that ‘X’ had assumed a false name and nationality.

As a result, the global media reported on the arrest of ‘X’.
Subsequent to the global media’s report, a number of financial institutions in country ‘D’ made reports to the national financial intelligence unit relating to their relationship with ‘X’ under the assumed name.

The following was revealed: ‘X’ during the time while being a fugitive and with the use of the assumed name had incorporated four companies in country ‘F’, namely companies numbers One, Two, Three and Four.
- Financial institution ‘AA’: The financial institution was approached by ‘X’ and asked to establish corporate accounts for companies numbers One and Two.

An analysis of the financial records revealed that ‘X’ had moved the sum of USD $3.7 million through the said accounts.

At the time of the report, USD $2.5 million in assets remained in the accounts.

- Financial Institution ‘BB’: The financial institution was approached and asked to establish corporate accounts for companies numbers Two and Three.
An analysis of the financial records revealed that ‘X’ had moved the sum of USD $5.2 million through the said accounts.

At the time of the report, a miniscule amount of the assets remained in the accounts.

- Financial Institution ‘CC’: The financial institution was approached and asked to establish a corporate account for company number Four.

An analysis of the financial records revealed that ‘X’ had moved the sum of USD $16.3 million through the said account.
At the time of the report, a miniscule amount of the assets remained in the account.

During this relationship, it was revealed that ‘X’ was associated with subjects ‘Y’ and ‘Z’ who were noted among the account’s documentation as being officials of company number Four.

- Financial Institution: ‘DD’: The financial institution was approached and asked to establish corporate accounts for companies numbers One and Two.
An analysis of the financial records revealed that ‘X’ had moved the sum of USD $9.7 million through the said accounts.

At the time of the report, USD $579,000.00 of the assets remained in the accounts.

During the analysis of the reports it was revealed that ‘X’ was the owner of ‘ABC’ company in country ‘B’.

This company was purported to be involved in businesses associated with the airline industry.
It was discovered that a number of professionals were retained by ‘X’ to manage the assets of ‘ABC’ company.

It is suspected that the assets of ‘ABC’ company were purchased with the proceeds of ‘X’s’ criminal conduct.

Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 41 Subsequently, when companies One, Two, Three and Four were established by ‘X’ in country ‘F’, a number of professionals in country ‘F’ were engaged to manage the assets.
The assets pledged were said to be owned by ‘X’ through the activities of ‘ABC’ company.

The national financial intelligence unit submitted the reports, which were received to the law enforcement authorities who commenced an investigation into the matter.

At the time of writing, law enforcement authorities from country ‘C’ had approached the law enforcement authorities in country ‘D’ and had requested a restraint of the assets with a view to forfeit the same.
Country ‘C’ continues to seek the extradition of ‘X’ from country ‘E’.

Investigations are ongoing by law enforcement authorities in countries ‘C’, ‘D’ and ‘E’.

CONCLUSION: The media’s coverage of the arrest of subject ‘X’ played a significant role in alerting financial institutions in country ‘D’ that the subject had acquired an assumed name, but was in fact a notorious leader of a drug trafficking cartel, who was a fugitive being sought by law enforcement authorities in country “C”.
The use of businesses and financial vehicles in multiple jurisdictions to conceal the true origin of the funds demonstrates the extent to which criminals are prepared to go to conceal their proceeds of criminal conduct to present an image of legitimacy.

In these cases the three stages of money laundering occurred.
The use of six (6) jurisdictions in this case further demonstrates the complex nature of money laundering and the web of financial transactions, which were created by ‘X’ in layering the proceeds of criminal conduct.

This case also revealed that the client of the financial institutions and others in the various jurisdictions was not whom he/she purported to be.
The acquisition and use of effective AML/CFT monitoring for KYC & CDD by financial institutions assisted in the identification and filing of suspicious transaction reports with the national financial intelligence unit.

Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 42 12.
SHORT LIST OF NATIONAL CURRENCIES Country Anguilla Antigua & Barbuda Argentina Aruba Australia Austria Bahamas Bermuda Brazil Canada Cayman Islands Peoples Republic of China Colombia Czech Republic France Germany Guatemala Guernsey Hong Kong Hungary India Iran Iraq Italy Japan State of Jersey Liechtenstein Panama Peru Russia Singapore Switzerland United Kingdom United States of America Venezuela Currency Dollar Dollar Peso Guilder Dollar Euro Dollar Dollar Real Dollar Dollar Yuan Renminbi Peso Koruna Euro Euro Quetzal Pound Dollar Forint Rupee Rial Dinar Euro Yen Pound Franc Balboa & U.S. Dollar New Sol Ruble Dollar Franc Pound Dollar Bolivar Symbol EC$ EC$ $ Afl.
A$ € B$ Bd$ R$ Can$ CI$ Y Col$ Kc € € Q £ HK$ Ft Rs Rls ID € ¥ £ SwF B & $ S/.

R S$ SwF £ $ Bs Financial Intelligence Unit Commonwealth of The Bahamas 2008 Annual Report Page 43 13.

GLOSSARY OF TERMS Terms Meanings of Terms Beneficial Owners……………..

Individuals who were disclosed as being the ones benefiting from the proceeds of the facility Closed………………………….
Analysis completed by FIU and report not forwarded to the Royal Bahamas Police Force for investigation Contract Partners……….………Corporate entities and/or individuals in whose name the facility was established with the financial institution Domestic……………………….

Banks conducting domestic banking only Offshore……………………….. Banks conducting offshore banking only Domestic/Offshore…………….

Banks conducting a combination of domestic and offshore banking D.I.

…………………………….
…………………………….

Disclosing institution MLRO ………………………... Money Laundering Reporting Officer MOU…………………………...

Memorandum of Understanding Pending………………………...Open with ongoing analysis by the FIU Police………………………….. Royal Bahamas Police Force STR…………………….……… Suspicious Transaction Report Financial Intelligence Unit Commonwealth of The Bahamas