Saudi Arabian Financial Intelligence - Assignment Example

Money Laundering and Terrorism Financing: Does the Saudi Arabian Financial Intelligence Unit comply with International Standards? Introduction a. General background to organised crime In legal terms, organised crime entails the following features: a permanent association or group of two or more people, established to execute criminal activities through application of means and techniques commonly agreed on. This is done with an aim to obtain a considerable income level and this therefore constitutes a severe threat to order and public security (Scherrer, 2009, p 83). The key activities of organised crime revolve around its traditional source of income. The income is drawn from provision of illicit substances and use of violence to procure money from legitimate businesses. A large portion of income for organised crime is derived from prostitution, narcotics distribution and loan sharking. Additional billions however are derived from theft rings, gambling, pornography, and other illegal ventures (Siegel, 2010, p 341). b. General background to money laundering and terrorism finance and how this links to organised crime – to set the scene Money laundering is the process applied by criminals to transfer, hide, and legitimise their criminal proceeds. Terrorism financing is the process of amassing funds with an aim of funding terrorism acts (Hopton, 2009, p 4). The key difference between the money laundering and terrorism financing is that whereas money laundering entails ill gotten money, terrorism financing entails both legitimate and illegitimate funds (Gori & Paparela, 2006, p 52). Organised criminals are either directly or indirectly driven by financial gains. Both terrorists and organised criminals have to ascertain ways of protecting their ill gotten income. To avoid detection and subsequent prosecution, there is an incentive for criminals to conceal these ill acquired gains (Leong, 2007, p 29-30). Money Laundering a. What is money laundering? Leong (2007, p 31) defines money laundering as an operation that links the gap between the world of criminals and the rest of the society. A more precise definition refers to money laundering as a process by which criminals conceal the ownership and source of proceeds arising from their criminal activities. One must not neglect the fact that the criminal proceeds do not actually have to be moved for the process to culminate to money laundering. There are other activities that constitute money laundering. A typical example would be that of tax evasion. A bank can launder funds without its knowledge when an account holder fails to declare a legitimate amount placed directly in his bank account on his tax returns (Hopton, 2009, p 2). b. History of money laundering – when did it start and by whom? The term money laundering is believed to have its source in the United States from Laundromats Mafia ownership. Gangsters there acquired humongous amounts of cash from gambling, prostitution, extortion, and bootleg liquor. Their aim was to show that the source of their funds was legitimate. Al Capone, Laundromats’ owner is deemed to have invented laundering. However, facts reveal otherwise: Lacey Lansky, referred to as the “mob’s accountant” is deemed to be one of the most influential money launderers. He used the Swiss bank accounts’ facilities to integrate the first actual laundering techniques. He applied the loan back concept which implied that illegitimate money could be concealed as loans provided by compliant banks from other countries. This is where actual laundering is deemed to have originated from (Duthel, 2008, p 20). c. Definitions i. Authoritative Definitions The International Monetary Fund defines money laundering as the process whereby one conceals the source of illegally acquired proceeds so that they come out as acquired from legitimate sources (International Monetary Fund, 2005, p 2) (Interpol, 2011). Money laundering according to the Interpol’s working definition is the attempted act to disguise or conceal the identity of proceeds obtained illegally to make them appear as if they have been obtained from legal sources The Financial Action Task Force describes money laundering as the process to disguise actual identity of proceeds emanating from criminal activities so as to cover up the illegitimate origin of the money (Financial Investigation Unit, 2011). According to the United Nations, money laundering is the process which conceals illegitimate earnings attributed to criminals. It is a three-stage dynamic process that involves: transferring funds from the direct source of crime; concealing the evidence trail with regards to the source of these funds; and availing the funds to the criminal with the geographic and occupational source concealed from suspicion (Kalin & Goldsmith, 2007, p 51). According to the World Bank, money laundering is constituted of three stages, placement, layering and integration. The three steps entail (1) separating funds from their original source and injecting the same into a financial system; (2) creating numerous transaction layers to further distinguish the funds from their original source; and (3) injecting the illegitimate funds in the economy. This ensures that the funds appear clean at the end of the process (World Bank, 2009, p 5) ii. Scholarly Definitions Money laundering is a criminal activity attempting to disguise the illegality of criminal proceeds. Money laundering is a process whereby the source of dirty money is concealed to make it appear legal and subsequently become usable, negotiable, and transferable (He, 2010, p 1). Traditionally, money laundering is the process through which criminals disguise the origins of proceeds arising from criminal activities. Money laundering is thus deemed to be the process of converting dirty money to clean and concealing criminal money (Hopton, 2009, p 1). Duthel (2008, p 20) defines money laundering as what transpires when illegal money is put through a process of transactions so that it appears clean. The source of illegally acquired funds is concealed through a series of deals and transfers so that they appear legitimate. iii. Definitions on Money laundering according to Saudi Arabia perspective Money laundering within the Saudi Arabian context is defined as the transfer and camouflage of funds drawn from criminal deeds (Giraldo & Trinkunas, 2007, p 156). Saudi Arabian authorities state that no criminal investigation has been embarked on with regards to money laundering. However they believe the rate of that particular crime within the Kingdom is low hence the snail-paced approach. The authorities indicate that it is very difficult to evaluate the magnitude of money laundering in the Kingdom. The Saudi Arabian government has stiff penalties on drug abuse, drug trafficking, and related crimes. Consequently, the authorities are of the opinion that there is no money laundering issue as this problem arises from drug trafficking (FATF/GAFI, 2010, p 19). d. The Processes of Money Laundering Placement, layering, and integration are expressions applied by law enforcement to define the three stages through which proceeds attributed to criminal activates are laundered. Placement is the stage where the physical currency penetrates into the financial system and illegitimate monies are most likely to get detected. When illegitimate proceeds are deposited in monetary establishments, placement is considered to have taken place. In the layering stage, a launderer may carry out a sequence of financial transactions so as to develop a layer between the funds and their illegitimate source. This stage aims at concealing trails of evidence. In the integration stage, illegitimate funds are incorporated with funds from legitimate sources as they gain access to the mainstream economy. The illegitimate funds espouse the form of legitimacy (World Bank, 2009, p 5-6). e. The Adverse Implications of Money Laundering Economic Implications of Money Laundering There are four main economic implications attributed to money laundering: Economic distortion, risk in financial institutions’ integrity and reputation, government resources, and socioeconomic repercussions. Economic distortion occurs because money launderers are usually not concerned about generating profits. Their interest is protecting their proceeds and concealing their illegitimate origins. They may therefore invest their funds in ineffective activities which could culminate in high opportunity costs and impede economic growth. Money laundering also tarnishes financial institutions’ reputation. This may lead to job losses and culminate into criminal activities which impact economic development negatively. On government resources, money laundering makes it difficult for a government to collect taxes and consequently reduces revenue since most transactions occur in the underground economy. There are also socioeconomic repercussions in that if money laundering is not contained, it amplifies criminal activities, leading to greater social ills. This in turn increases explicit and implicit enforcement costs (Inter-American Development Bank, 2004, p 242-243). Political Implications of Money Laundering Money laundering facilitates and amplifies corruption. Corrupt officials are encouraged to siphon public funds as they are able to launder kick backs and bribes. Incidentally, money laundering leads to political instability in some countries as the laundered funds are used in procuring funds by criminals who are used by politicians to achieve political ends (Ashford and Duancey, 2006, p 170-171). Inducements and bribe payments by big multinational corporations are usually laundered due to political reasons. Money laundering also exists in governments and government circles where state funds are transferred to offshore jurisdictions. In the political world at the very top level, there is corruption and infiltration of politicians and weak public officials. This implies that in countries affected by money laundering institutions of democracy are eroded and legitimate authority of national governments is challenged through corrupt public officials (Lilley, 2006, p 4-7). Social Implications of Money Laundering Some of the key social effects attributed to money laundering include escalating incidences of crime, bribing, corruption, contamination of legitimate businesses through illegitimate activities, and dismantling the family unit (Masciandro et al, 2007, p 149). Incidentally, money laundering enables criminals to expand their activities. Consequently, this increases the government costs because of the need to beef up law enforcement units to contain the menace and increase expenses on health care. The economic power possessed by criminals due to money laundering is coupled with corruption that spills to virtually every element of the society. In extreme situations, this could culminate to total take over of a legitimate government (U.S. Department of State, 2001, p 8). 3. Terrorism Financing a. What is terrorism finance? Many terrorist gangs usually secure their funds through criminal activities even though their ultimate goal is not economic gain. A terrorism organisation’s key objective is to coerce a population or a government to carry out or refrain from carrying out a particular deed or action. To achieve their ends, terrorism groups need financial support (Leong, 2007 p 44). Terrorism financing refers to anybody who knowingly collects or provides money or any other form of property directly, indirectly, or by any means, with the illegitimate intention that they be used for purposes of terrorism. It is not the criminal source of terrorist finances that taints them; it is their intended or actual use to fund acts of terrorism (Gilmore, 2004, p 119; Hopton, 2009, p 4). b. Definitions i. Authoritative Definitions According to article 2.1 of the International Convention for the Suppression of the Financing of Terrorism, terrorism funding takes many forms and thus if a person, through any means, indirectly or directly, wilfully and illegally, gives or gathers funds with the knowledge that or with an aim that they should be used partly or wholly to execute terrorism deeds this constitutes terrorism funding (Minister of Public Works and Government Services, 2010, p. 11). The FATF broadens the above definition on terrorism financing as follows: “Every State shall make it a criminal offense to wilfully collect or provide, through any means, indirectly or directly, of funds by their citizens or within their territories with the knowledge that the funds are to be used, or with an aim that they will be used to execute terrorism deeds” (Council on Foreign Relations, 2003, p 14). The International Monetary Fund defines terrorism financing as the process through which a person attempts to provide or collects funds with the aim that they should be applied in executing terrorist deeds by a terrorist organisation or a terrorist as outlined in the International Convention for the containment of Terrorism Financing as well as within each single treaty outlined in the annex to that conference (International Monetary Fund, 2005, p 2). The World Bank defines terrorism financing as any form of financial support towards terrorism, or those who conspire, participate, and encourage the execution of terrorism deeds. The definition of terrorism with reference to the World Bank’s perspective is the deliberate use of aggression against innocent civilians with an aim of instilling fear for some political purpose, goal or objective (Biersteker & Eckert, 2008, p 6). Following an organised group’s resolution in violent acts and explosive substances, Interpol passed a resolution regarding the same. In 1999, a resolution was passed by the Interpol aimed at terrorism funding in particular. Interpol pays more attention to terrorist funding activities since it is believed that the gravity and frequency of terrorist attacks is attributed to the amounts of funding that terrorists receive. Within this context terrorism funding according to the Interpol is interpreted as the provision of funds for purposes of committing terrorism crimes (Kaya & Erdemir, 2008, p 122-123). ii. Scholarly Definition of Terrorism Financing The term terrorist financing is applicable to two connected but distinct forms of activity. It may refer to the constant fundraising efforts by which a terrorist organisation supports its overall activities. This initial stage of collecting funds in relatively large quantities is referred to as type 1 terrorist financing. Type 2 terrorism financing refers to the funds specifically directed at funding a particular terrorism activity (Parkman & Peeling, 2007, p 23-24). Yager (2006, p 6) defines terrorism financing as the financial support of any form of terrorism, or of those who conspire, participate, or plan execution of terrorism deeds. Terrorism financing according to Kostadinides and Eckes (2011, p 82) is the collection or provision of funds by any means, with an aim that they be applied fully or partly to execute terrorism deeds. iv. Definition of Terrorism Financing According to the Saudi Arabian Perspective According to the United States Department of the Treasury, security forces in Saudi Arabia have killed a significant proportion of Al Qaeda financiers, who reportedly were the main facilitators of finance to assist terrorist operatives. The report continues to state that Saudi Arabia has taken major strides in administering reforms in an attempt to deter terrorism financing. Within this context, the definition of terrorism financing from the Saudi Arabian perspective is the provision of funds by individuals or organisations towards terrorists or terrorist organisations to facilitate execution of terrorist acts (Blanchard, 2010, p 25-26). In July 2009, the Saudi government convicted 330 suspects charged with acts of terrorism which entailed facilitating and funding terrorism (Merritt, 2010, p 32). This statement supports the aforementioned definition of terrorism finance from a Saudi Arabian perspective. c. Link between money laundering and terrorism financing (Academic / Scholarly perspective) The techniques applied in money laundering are basically synonymous to those applied in disguising the origins and uses of terrorist funds. Monies applied in funding terrorism may either be generated from criminal activities, legal sources, or both. However, it is necessary to conceal the origins of terrorism funding irrespective of whether the sources are legitimate or not. The implication is that if the source of funds can be disguised, then it would be difficult to project of any potential execution of terrorism acts. Additionally, it is imperative that terrorists and terrorism organisations disguise the origin of their funds so that the funding continues without being detected (Schott, World Bank, IMF, 2006, p 5). Experts on terrorism financing and money laundering are of the view that similarities attributed to terrorism financing and money laundering are many. These experts argue that the similarities lie in the procedures, tactics, and techniques applied by both forms of organisations to disguise and transfer funds across the globe. Three of those similarities are the layering of the finances to disguise their origins, the need for a cover up of their actions from law enforcement agencies, and identifying countries with weak legislations in order to take advantage of the same (Wesley & Anderson, 2010 p 25). It is impetrative for an effective terrorist organisation to develop and maintain a concrete financial infrastructure. To this end, the terrorist organisation must create various sources of funding their plan and the means of laundering these finances to facilitate their actions. 4. The international standards of combating money laundering and financing terrorism a. UN Conventions & Special Resolutions i. Against Illicit Traffic in Narcotic Drugs and Psychotropic Substances. With reference to the political declaration and action plan on global cooperation towards a balanced and integrated strategy to contain the drug problem, the United Nation’s Commission on Narcotic Drugs stated that the drug menace was still an issue despite the numerous steps taken to combat the same. The political declaration and action plan set 2019 as the ultimatum for significantly reducing or eliminating the illicit cultivation of bush, coca, cannabis, and opium poppy. Incidentally, the commission aimed at significantly reducing trafficking in drugs and diversion of substances popularly used in the illicit manufacture of psychotropic substances and narcotic drugs. It so worth pointing out the United Nation resolution urging member states to amplify global and regional cooperation to counter the illicit manufacture and trafficking in drugs (United Nations, 2010, p 38). ii. Against Trans-national Organized Crime Recognising that organised crime is a grave and escalating problem for all nations, the United Nations Convention against Trans-national Organised Crime aims at enhancing global cooperation to deter and contain trans-national organised crime. As the first all-inclusive multilateral legal mechanism in the fight to combat organised crime, the convention offers law enforcement units and judicial authorities unique instruments to counter the problem. The convention is also aimed at providing greater coordination of administrative, enforcement, national policy and legislative approaches. The convention standardises concepts and terminology, developing a common basis for national crime control structure. Such concepts entail the definition of an organised criminal group which for the first time was agreed on from an international level (United Nations, 2004, p 72). iii. For the Suppression of the Financing of Terrorism. The United Nations International Convention for Suppression of the Financing of Terrorism indicates that all nations must implement a range of measures against terrorism such as suppressing and preventing the funding of terrorist deeds. This also includes freezing terrorists’ financial assets and conducting investigations on movement of funds attributed to the execution of terrorism offences. This is in conformity to the United Nation Security Council Resolution 1373 (Council of Europe, 2007, p 84). The United Nations Convention for Suppression of the Financing of Terrorism requires terrorism funding to be criminalised (International Monetary Fund Legal Department, et al, 2004, p 20). Incidentally, the convention provides that member states should offer mutual help to each other in the investigation of and in the legal processes related to terrorism financing (Council of Europe, 2005, p 58). iv. Any Other At the end of 2001, the IMF’s executive board considered how the institution might amplify their contributions on international efforts to combat money laundering and terrorism financing. This entailed creating a methodology that would support the evaluation of financial standards relevant for fighting money laundering; working closely with the key global anti-money laundering institutions and amplifying the provision of technical support in this area; and emphasizing the importance of countries cushioning themselves money laundering through awareness campaigns. Incidentally, some of the directors suggested that the methodology document should encompass all the recommendations by the FATF. Further, the directors agreed that a key factor in fighting money laundering and terrorism financing was through effective cooperation among different government authorities (International Monetary Fund, 2002, p 36-37). b. Financial Action Task Force (FATF) i. Introduction / background on FATF The FATF is an inter-governmental body that aims at creating and enhancing policies at both national and global levels to counter money laundering. The FATF has its secretariat housed in the OECD headquarters in Paris. However, the FATF is a distinct global organisation separate from the OECD. G-7 ministers in 1989 issued an Economic Declaration addressing various issues regarding international monetary developments. In conjunction with this declaration the leaders collectively approved the formation of a Financial Action Task Force on money laundering. This institution is charged with the responsibility of coordinating various measures developed with an aim to counter money laundering both from a local and global platform. The Financial Action Task Force is made up of 34 members. At the convention of G-8 finance ministers in 1999 they came up with the term gatekeeper in their announcement calling for nations to consider different ways to combat money laundering. They deemed this would be possible through efforts of professional gatekeepers of the global monetary system. Professional gatekeepers included company formation agents, accountants, notaries, lawyers, and others. This they termed the “Gatekeeper Initiative” (Masciandaro, 2004, p 9; Chatain and World Bank, 2008, p 69). Since its inception, the FATF has worked to ensure that its recommendations are globally recognised as the global standards of anti money laundering (AML) and combating terrorist financing (CFT). The work of FATF covering over 170 territories has had a major impact on global detection and deterrence of money laundering and terrorist financing (World Bank, 2009, p 46). ii. Introduction of the 49 recommendations The FATF in 1990 issued the forty recommendations to offer a set of combative measures against money laundering. The recommendations addressed a broad range of topics including an efficient criminal judicial system and a country’s regulation framework with regards to its financial system and global cooperation. These recommendations are general in nature. They were arrived at with an aim to offer nations some flexibility to implement their regulations in tandem with specific circumstances. The recommendations are not a binding global invention. However, several countries have devoted to apply them to counter money laundering. Following the September 11 attacks in the United States, the FATF broadened its scope to include provisions against terrorism financing. These provisions are subject to an extra nine special recommendations, in addition to the 40 they collectively make up 49 recommendations which are commonly referred to as the FATF recommendations (Odeh, 2010, p 212). Incidentally, the FATF issued guidance on the recommendations, together with its recommendations to apply regulations on money laundering to non-financial enterprises and professions like lawyers. An FATF consultation paper in 2002 outlined assorted options for stimulating national anti money laundering measures. The paper proposed that some anti money laundering measures be extended to lawyers. The recommendations attributed to the FATF encourage governments to create a risk based approach to counter money laundering and terrorist financing. This approach projects that limited resources will be applied to tackle the greatest risks (McCann, 2006, pp 288-300). iii. Recommendation number 26 - to establish FIU The creation of a centralised unit for the purposes of amassing, assessment, and dissemination of suspicious transactions and intelligence to investigative units is a significant measure in combating money laundering. This is because it has come to be deemed as a critical element of the anti money laundering system (Commonwealth Secretariat, 2006, p 103). Recommendation number 26 of the FATF states that Financial Intelligence Units (FIUs) should be established by all countries to serve as a national centre for gathering, assessment, and circulation of STR (Suspicious Transaction Reports). The FIU should have both direct and indirect access on a timely fashion, to the administrative, financial, and law enforcement information that it needs to properly carry out its functions including STR assessment (Commonwealth Secretariat, 2006, p 103). Reference in this recommendation to countries should be espoused to equally apply to jurisdictions and territories. Incidentally, subsequent to FIU creation by a country, the country should consider a membership application in the Egmont Group. Countries should oblige to the Egmont Group Statement of Purpose and its principles for exchange of information between FIUs for cases related to money laundering. These documents outline a significant guidance concerning the tasks and responsibilities of FIUs (FATF, 2004, p 1-2). It is worth pointing out that global cooperation between FIUs is critical, hence the Egmont Group. The global coordinator of the FIUs is the Egmont group, hence the need for countries to register with it (Great Britain: Parliament: House of Lords: European Union Committee, 2009, p 22). Financial Intelligence Unit The Egmont Group of Financial Intelligence Units defines Financial Intelligence Units as: A central, national bureau charged with the responsibility of collecting/receiving, assessing, and circulating Financial Intelligence disclosures to proficient authorities. This definition was also espoused by the United Nations Convention against Transnational Organized Crime. It stated that every party state, shall consider developing a Financial Intelligence Unit to act as a national centre to gather, evaluate and disseminate financial intelligence. The FATF expanded this definition further; that the FIU shall be charged with the responsibility of repository of information reported, evaluation, and sharing financial intelligence. The FATF also has an overall requirement that every national authority should trade information and collaborate with their local and global counterparts (Schott, World Bank, IMF, 2006, p 31-32; United States Department of States, 2004, p 12ejournal). Types or Models of FIUs The administrative type of FIU is normally under the supervision of an agency or administration other than a law enforcement unit. The administrative FIU model sometimes constitutes a detached agency either placed under some form of supervision or entirely independent from any form of supervision. Under the law enforcement model, the FIU closely operates with law enforcement agencies, like a financial crime agency. Subsequently the FIU draws benefits from their information sources and expertise. The judicial model of FIU is generally created within the country’s judicial branch and usually under jurisdiction of the prosecutor. The hybrid FIU entails different arrangement combinations, defined in the above model categories. This form of arrangement aims at drawing benefits from the other models and combining them in one organization (Forget et al, 2004, pp 9-17). Core functions of FIU The key functions of FIUs are to gather, evaluate, and circulate financial intelligence to counter money laundering terrorist financing. Who must report? Financial Institutions Financial institutions are obligated to report to their respective country’s FIU on any suspicious looking reports and the necessary disclosures required by the unit. The repository function centralisation, assigning FIU to be the recipient of relevant financial disclosures is mandatory for local and global framework on preventing money laundering to be effective. The application of a centralised repository for the purposes of reporting information and disclosures facilitates information processing on a constant basis. Incidentally, amassing information becomes efficient due to centralisation (Kapila, 2006, p 82). Non-financial Institutions There are some countries that may designate functions of their respective FIUS particularly investigative function to other law enforcement units. In such situations, the FIU is required to report or share information with investigative organs upon demand. These powers may include the execution of excessive powers beyond the normal jurisdiction to gain any information of interest. Such powers may entail authority to enable the FIU to request for extra information from financial establishments. They may also conduct investigations which could include classification of potential assets to be seized, frozen, or confiscated (International Monetary Funds, 2009, p 53). Countries could also delegate authority to their respective FIUs to espouse provisional standards to effectively deal with cases where urgent steps are required. Since an FIU is a decisive government point for highlighting suspicious transactions, it is reasonable for the government to delegate it provisional powers to hold assets that might later be confiscated. Such measures could entail freezing assets temporarily as well as any other measures like refraining an individual whom, or an organisation which these assets attribute to from legitimate disposition of the same However, such provisional powers require that the FIU be able to investigate and classify any assets likely to be seized within the laws against money laundering and terrorist financing. In so doing, sufficient resources ought to be made available to the FIU to facilitate efficiency in executing their operations. Subsequent to receiving and investigating information from suspicious transactions, FIUs are obligated to report to or share the information with their local and/or global counterparts. Additionally, the FIU is in a distinctive position to offer research to its respective government. This is on the basis of its experience in gathering, evaluating, and disseminating financial intelligence with regards to money laundering and terrorist financing (Schott, World Bank & IMF, 2006 p 45-46). Others The hybrid FIU model integrates different combinations of the other FIU models. This form of arrangement pools the benefits emanating from other FIUs into a single organisation. Of importance and much relevance within this context is that in some FIUs, staff from different law enforcement and regulatory units are deployed to work with the FIU. This they do while continuing to execute their original agencies’ powers. In this case, the diverse staff drawn from various agencies report to the FIU (Kalin & Goldsmith, 2007, p 86). Reference List Siegel, L. 2010, Criminology. Cengage Learning. Belmont, CA Scherrer, A. 2009, G8 against transnational organized crime. Ashgate Publishing. 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