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TRANSCRIPT
What is financial crime?What is financial crime?
• The handling of the proceeds of crime (drug dealing, theft, smuggling, trading counterfeit goods)
• Market manipulation (insider trading)
• Tax evasion
• Fraud
What is money laundering?What is money laundering?
• The handling of the proceeds of predicate crimes (drug dealing, theft, smuggling, trading counterfeit goods)
Tackling crimeTackling crime
What is financial investigation?What is financial investigation?
• The covert mapping of criminals and their assets before arrest
• The intrusive use of financial intelligence, multiple databases, analysis, mixed with traditional surveillance, human sources and other field intelligence
SpeakersSpeakers
• Tristram Hicks, Detective Superintendent Scotland Yard
• Head of Financial Intelligence
• Recipient of all London STRs
• Head of London Asset Recovery Team
• Police rep on National Strategic Committees
SpeakersSpeakers
• Cedric Woodhall
• Senior Officer UK Customs
• Head of
• Set up UK Asset Recovery Office
SpeakersSpeakers
• Lawrie Day
• Scotland Yard Detective
• Accredited Financial Investigator
• International AML adviser (Kosovo, Croatia, Albania, northern Cyprus)
SpeakersSpeakers
• Jill Thomas
• Europol AML specialist
• Secretary of CARIN
• Secretary of ARO Platform
SpeakersSpeakers
• Nottenboom
• Netherlands specialist prosecutor
• Founder of ARO
UK Value 1970 - 2000UK Value 1970 - 2000
UK Value 1970 - 2010UK Value 1970 - 2010
Volume of POC 2002 - 2010Volume of POC 2002 - 2010
Key toolsKey tools
• Find bank accounts
• Access to SARs
• Seize cash
• Freeze accounts & assets
• Incentive money for agencies
Incentive money for agenciesIncentive money for agencies
• 50% to Ministry of Interior
• 18.75% Police
• 18.75% Prosecution
• 12.5% Courts administration
Incentive money for agenciesIncentive money for agencies
Pros
• Helps senior management
• Helps middle management
• Helps shop floor• Helps government
Cons
• Changes focus from good policing to revenue
• Perverted ‘cost/benefit analysis
• ‘Better, quicker, cheaper’ investigations ignored
• ‘Incentive’ time limited
Incentive money for agenciesIncentive money for agencies
• Perceptions
• Police allow drug dealers to carry on until car is worth seizing (moral hazard)
• Prosecutors change indictment/ bring case to get the money (Judicial disapproval)
• Police/prosecutors working for themselves not the public (public distrust)
Standard Intelligence UnitStandard Intelligence Unit
Researcher
Manager
F.I.O.Analyst
Operational Heads
Briefing
Officer
Suspicious activity
SARs
Financial sector
FIC
Intervention
Outcomes
Awareness
Trust
Feedback
Strategic Group
Receiving
Analysis
Dissemination
Feedback to Sectors
Acquis and FATF compliant
Increased State revenue
Deters & disables
organised crime
A Working AML Regime
Tax evasion
Local crime
Other crime
Police
Prosecutors
Customs
Tax
Social welfare
Outputs:
Prosecutions &
Confiscation
Financial Investigators 2000 to dateFinancial Investigators 2000 to date
Financial Financial investigatorsinvestigators
AgencyFinancial Investigators
Police 1417
London Police 496
SOCA 246
Tax & Customs 270
Local Gov 105
Social Welfare 24
Serious Fraud 16
Financial Services 11
Other Gov 37
Total 2622
UK only
Training HistoryTraining History
• Fraud Training
• Fraud and Confiscation Training
• Confiscation Training
• Intelligence then Investigation then Confiscation Training
UK training is EU recommendedUK training is EU recommended
• Council of the EU, Evaluation of Financial Crime and Financial Investigation, Report on the UK.
• UK powers and training systems should be presented to the EU, its Members and Agencies
Intelligence
Investigation
Confiscation
Managers’Course
Internet Research
F.I. Tutor
Money Laundering
Cash Seizure
EnhancedIntelligence
Financial Investigator
Course FormatCourse Format
• Pre-read
• 5 day course
• Allocation of Tutor
• Creation of Professional Development Portfolio
• Regular Continuous PD
Course styleCourse style
• Interactive problem solving
• Main Courses follow one case
Key lessons from UKKey lessons from UK
• Beware! Cultural resistance of senior police managers, prosecutors, judges
• Emphasise operational efficiency: better, quicker, cheaper investigations
• Seize and freeze first, ask questions later
• Importance of cash seizure
• Collect statistics now!
• Beware recycling the money to agencies
Money Laundering Money Laundering & Proceeds of & Proceeds of
Crime (ML & POC)Crime (ML & POC)[email protected]@npia.pnn.police.uk