ARO Seminar Ankara

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? The handling of the proceeds of predicate crimes (drug dealing, theft, smuggling, trading counterfeit goods)

Tackling crime Crime Proceeds of Crime Money Laundering

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

Speakers 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

Speakers Cedric Woodhall Senior Officer UK Customs Head of Set up UK Asset Recovery Office

Speakers Lawrie Day Scotland Yard Detective Accredited Financial Investigator International AML adviser (Kosovo, Croatia, Albania, northern Cyprus)

Speakers Jill Thomas Europol AML specialist Secretary of CARIN Secretary of ARO Platform

Speakers Nottenboom Netherlands specialist prosecutor Founder of ARO

ARO Seminar Ankara

ARO Seminar Ankara UK experience

UK Value

UK Value

Volume of POC

Key tools Find bank accounts Access to SARs Seize cash Freeze accounts & assets Incentive money for agencies

50% to Ministry of Interior 18.75% Police 18.75% Prosecution 12.5% Courts administration

Incentive 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 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 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 date

Financial investigators Agency Financial Investigators Police 1417 London Police 496 SOCA 246 Tax & Customs 270 Local Gov 105 Social Welfare 24 Serious Fraud 16 Financial Services 11 Other Gov37 Total 2622 UK only

Training History Fraud Training Fraud and Confiscation Training Confiscation Training Intelligence then Investigation then Confiscation Training

UK 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

Financial Investigator Enhanced Intelligence Cash Seizure Money Laundering F.I. Tutor Internet Research Managers’ Course

Course Format Pre-read 5 day course Allocation of Tutor Creation of Professional Development Portfolio Regular Continuous PD

Course style Interactive problem solving Main Courses follow one case

Key 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 & Proceeds of Crime (ML & POC)