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ANNUAL REPORT Ii FIU BELIZE ANNUAL REPORT 2020 FIU BELIZE ANNUAL REPORT 2020 Iii Mission

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ANNUAL REPORT Ii FIU BELIZE ANNUAL REPORT 2020 FIU BELIZE ANNUAL REPORT 2020 Iii Mission 20 20 ANNUAL REPORT ii FIU BELIZE ANNUAL REPORT 2020 FIU BELIZE ANNUAL REPORT 2020 iii Mission Vision A premier agency supporting a robust and dynamic economy by safeguarding Belize from money laundering, terrorist financing and other financial crimes. iv FIU BELIZE ANNUAL REPORT 2020 Mission To contribute to the economic and social stability of Belize by: • safeguarding its financial and business sectors from Vision abuse without obstructing legitimate business; • engaging in tactical and strategic intelligence gathering, analysis and sharing; and • securing compliance with the highest international standards and best practices for combating money laundering and terrorist financing. FIU BELIZE ANNUAL REPORT 2020 v Integrity Accountability Leadership Professionalism CORE VALUES Teamwork Commitment Results Driven vi FIU BELIZE ANNUAL REPORT 2020 Organizational STRUCTURE Director Strategic Consultant Legal Advisor Deputy Director NRA Coordinator Research Assistant Head of Head of Head of Office/Human Compliance Investigations Financial Analysis Systems/Network Resources Department Department Department Administrator Manager Compliance Investigators Financial Officers (4) (4) Analysts (4) Quality Assurance Secretary Clerical Office Security Officer Officer Attendant Officer FIU BELIZE ANNUAL REPORT 2020 vii Contents List of Tables and Figures 1 List of Abbreviations and Acronyms 4 Director’s Message 7 Country Overview 10 The Financial Intelligence Unit 15 National Anti-Money Laundering Committee (NAMLC) 22 - National Risk Assessment 25 - National Money Laundering Risk 26 - National Terrorist Financing Risk 31 Analysis and Intelligence 32 - The Intelligence Cycle 36 - STR Patterns 37 - Suspicious Transactions by Sector 48 viii FIU BELIZE ANNUAL REPORT 2020 Supervision and Enforcement 51 - Registration of DNFBPs 53 - Registration Updates 59 - De-registration Process 60 - Approval of the Money Laundering Compliance Officer 62 - AML/CFT Examinations 64 - Outreach and Awareness 67 - Enforcement 68 - Enhancing Supervisory Activities 68 Investigations and Prosecutions 70 - Financial Crimes Working Group 73 - Investigative Tools 75 - Domestic and International Cooperation 76 Presentations, Training and Meetings 79 - Overseas Training 80 - Virtual Overseas Training 81 - Virtual Overseas Conferences and Meetings 85 Appendices Appendix 1: Cases Investigated with the 88 Assistance of the FCWG Appendix 2: Number of RFIs By Country 2018 – 2020 91 FIU BELIZE ANNUAL REPORT 2020 ix x FIU BELIZE ANNUAL REPORT 2020 LIST OF TABLES and FIGURES Tables Table 1: Belize: Selected Indicators 14 Table 2: Main Offences that Generate Proceeds 28 of Crime in Belize Table 3: Money Laundering Risk Rating 29 of Financial Sectors Table 4: Money Laundering Risk Rating of 30 Non-Financial Sectors Table 5: Reporting Entities Under the MLTPA 35 Table 6: STR Submissions by Reporting 39 Entity Sector 2016 – 2020 Table 7: STRs by Suspicious Transaction 40 Type 2016-2020 Table 8: Number of Fraud-Type Reported 41 in STRs 2019 – 2020 Table 9: Types and Values of Currencies Reported 43 in STRs 2016-2020 FIU BELIZE ANNUAL REPORT 2020 1 Table 10: DNFBP Registration Activity by Sector 57 Table 11: DNFBP De-Registrations 2018-2020 61 Table 12: Number of MLCO Approvals 63 Table 13: Cases Investigated During 2020 72 Table 14: Source of Funds Queries/Cash Seizures 73 Table 15: RFIs by Suspected Activity 77 2018 - 2020 International RFIs Table 16: Workshops and Presentations in 80 Belize Involving the FIU – 2020 Table 17: Overseas Training Workshop 81 Attended by FIU Staff – 2020 Table 18: Training Workshops with FIU 82 Staff Participation – 2020 Table 19: Meetings and Conferences with 85 FIU Staff Participation – 2020 2 FIU BELIZE ANNUAL REPORT 2020 Figures Figure 1: Country Money Laundering Risk Level 27 Figure 2: The Intelligence Cycle 36 Figure 3: Information Sharing Process 37 Figure 4: Number of STR Submissions 2016 – 2020 38 Figure 5: Number of Registered DNFBPs: 56 Dec 2016 – Dec 2020 Figure 6: Registration Updates By Sector 2019-2020 59 Charts Chart 1: STR Submissions by Location of 44 Suspicious Activities 2020 Chart 2: Percentage of STR Submissions by Location 2020 44 Chart3: STR Submissions by Resolution Status 2020 45 Chart 4: Registered DNFBPs By Geographical Location 58 Chart 5: Types of Alleged Offences Investigated in 2020 74 Chart 6: Requests for Information 76 Chart 7: Countries Requesting Information in 2020 78 FIU BELIZE ANNUAL REPORT 2020 3 ABBREVIATIONS and ACRONYMS AML Anti-Money Laundering BPD Belize Police Department BTSD Belize Tax Service Department BZD Belize dollar CARICOM Caribbean Community CARICOM IMPACS CARICOM Implementation Agency for Crime and Security CFATF Caribbean Financial Action Task Force CFT Countering the Financing of Terrorism CPF Combating the Financing of Proliferation of Weapons of Mass Destruction DNFBPs Designated Non-Financial Businesses and Professions ECOFEL Egmont Centre of FIU Excellence and Leadership EUR Euro FATF Financial Action Task Force FCWG Financial Crimes Working Group FIU Financial Intelligence Unit GBP UK Pounds Sterling GDP Gross Domestic Product IFSC International Financial Services Commission KYC Know Your Customer ML Money Laundering MLCO Money Laundering Compliance Officer 4 FIU BELIZE ANNUAL REPORT 2020 MLT Money Laundering Threat MLTPA Money Laundering and Terrorism (Prevention) Act MXN Mexican peso N/A or n/a Not Available NAMLC National Anti-Money Laundering Committee NGOs Non-Governmental Organisations NPOs Non-Profit Organisations NRA National Risk Assessment OFS Other Financial Services PF Financing the Proliferation of Weapons of Mass Destruction RFI Request for Information STR Suspicious Transaction Report TCSP Trust and Corporate Service Provider TF Terrorist Financing UK United Kingdom of Great Britain and Northern Ireland UN United Nations UNODC United Nations Office on Drugs and Crime UNSCR United Nations Security Council Resolution US United States USD United States dollar FIU BELIZE ANNUAL REPORT 2020 5 6 FIU BELIZE ANNUAL REPORT 2020 2020 was an unusual year for everyone, to say the least. The COVID-19 pandem- Director’s ic wreaked havoc across the globe leav- ing devastated economies, homes, and human lives in its wake. At one point, the MESSAGE challenges of combating money laun- dering and terrorism financing seemed to pale next to the mortifying reports of teeming emergency rooms, the unavail- ability of ventilators and, in a few sad cases, persons dying in ambulances. At this writing, we are guardedly optimis- tic that the worst is behind us and that we may be able to return to a form of normalcy that we would not have expe- rienced in over a year. Notwithstanding, there were occasional celebratory and otherwise noteworthy moments. The following are some of those highlights. FIU BELIZE ANNUAL REPORT 2020 7 The Belize Financial Intelligence Unit mometers to office security to moni- (FIU) never closed its doors during the tor temperatures, copious sanitization pandemic. Even during the ‘stay at of working quarters and general work home’ orders, a skeletal crew of officers premises and, most important, a clear, was deployed to ensure that sensitive written COVID-19 emergency plan. The databases were monitored daily, and Plan provided for eventualities in the that investigative staff were accom- best- and worst-case situations. modated to supply the necessary dili- gence. Moreover, we continued to pro- The challenge of working from home vide responses to both domestic and also provided an opportunity for finan- international requests for information cial analysts to develop several strate- in line with the requirements of the Fi- gic analyses which are crucial to under- nancial Action Task Force’s (FATF) Im- standing sector money laundering risk. mediate Outcome 2. Unfortunately, The guidance from these documents the case was not the same across the continues to be developed as more in- globe as many regional and internation- formation becomes available but the al FIUs were forced to close their doors output has been, and will continue to for some time to mitigate pandemic be, useful to the FIU and its domestic spread. Within a few weeks, we were counterparts in our joint commitment to able to resume delivery of some other tackle financial crime. This is in line with non-essential services on a staff-rota- the expectations of FATF’s Immediate tional basis. Gradually, we were able to Outcome 6. return to regular office hours. Circumstances resulting from the pan- Notwithstanding the need for diligence, demic have amplified the usefulness FIU management had to balance that of remote working tools, including the requirement with the health and safe- virtual meeting place. Zoom, Micro- ty of our most important resource, our soft Teams, Skype, Webex and Google staff. In consideration that various staff Meet are a selection of virtual meeting resided in both urban and rural ar- applications that have brought the re- eas, extreme care was taken to assure motest parts of the globe to one com- minimized exposure to contamination. mon space. FIU technical staff took full Some measures included staggered advantage of webinars, live streams reporting and departure hours to avoid and virtual meetings hosted by sever- rush hour traffic, providing infrared ther- al international partners including the 8 FIU BELIZE ANNUAL REPORT 2020 United Nations Office on Drugs and targeting the sale of personal protective Crime (UNODC), the FATF, the Caribbe- equipment and government stimulus an Community (CARICOM) Implemen-
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