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Annual Report 2019

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Annual Report 2019 ANNUAL 2019 | REPORT Insert Letter of Transmittal Insert Mission/ Vision Statement VISION A premier agency supporting a robust and dynamic economy by safeguarding Belize from money laundering, terrorist financing and other financial crimes. MISSION To contribute to the economic and social stability of Belize by: safeguarding its financial and business sectors from 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. CORE VALUES Integrity Accountability Leadership Professionalism Teamwork Commitment Results Driven ANNUAL REPORT 2019 CONTENTS PAGE Organisational Chart . .3 List of Tables, Figures and Appendices . 4 List of Acronyms and Abbreviations. 6 Director’s Message. .9 Country Overview. 12 The Financial Intelligence Unit. .16 National Anti-Money Laundering Committee. .19 National Risk Assessment. .21 Analysis and Intelligence. 22 STR Patterns . 25 Criminal Activity Types and Trends . .30 Supervision and Enforcement. 32 DNFBPs. 33 DNFBP Examinations and Outcomes. .41 Investigations and Prosecutions. 44 Types of Offences Investigated . 45 Investigative Tools. .47 Domestic and International Cooperation. 48 Presentations, Training and Meetings. 51 1 2 ANNUAL REPORT 2019 ORGANISATIONAL CHART STRATEGIC CONSULTANT DIRECTOR LEGAL CONSULTANT DEPUTY DIRECTOR NRA COORDINATOR RESEARCH ASSISTANT HEAD OF HEAD OF HEAD OF OFFICE/HUMAN SYSTEMS/NETWORK COMPLIANCE INVESTIGATIONS FINANCIAL ANALYSIS RESOURCES ADMINISTRATOR DEPARTMENT DEPARTMENT DEPARTMENT MANAGER COMPLIANCE INVESTIGATORS FINANCIAL ANALYSTS OFFICERS (3) (3) (4) QUALITY ASSURANCE SECRETARY CLERICAL OFFICER OFFICE ATTENDANT SECURITY OFFICER OFFICER 3 LIST of TABLES, FIGURES and APPENDICES TABLES PAGE Table 1: Belize: Selected Economic Indicators ............................................................................................15 Table 2 : Reporting Entities under the MLTPA ............................................................................................24 Table 3: STR Submissions by Reporting Entity Sector, 2015 – 2019 .....................................................26 Table 4: STRs by Suspicious Transaction Type or Area of Interest, 2015 – 2019 ................................27 Table 5: Types and Values of Currencies Reported in STRs, 2015 – 2019 ...........................................28 Table 6: DNFBP Registration Activity by Sector .......................................................................................35 Table 7: DNFBP De-Registrations ................................................................................................................ 38 Table 8: Number of MLCO Approvals ......................................................................................................... 39 Table 9: DNFBP On-Site Examinations by Sector, 2018 – 2019 ............................................................41 Table 10: Source of Funds Queries ................................................................................................................. 46 Table 11: RFIs by Area of Interest, 2016 – 2019 ..........................................................................................50 Table 12: Overseas Training Workshops Attended by FIU Staff Members .............................................53 Table 13: Overseas Meetings and Conferences Attended by FIU Staff Members ................................54 4 ANNUAL REPORT 2019 FIGURES Figure 1: The Intelligence Cycle ...................................................................................................................... 23 Figure 2: Information Sharing Process ........................................................................................................... 23 Figure 3: Number of STR Submissions, 2015 – 2019 .................................................................................25 Figure 4: STR Submissions by Location of Suspicious Activities, 2019 ...................................................29 Figure 5: Percentage Shares of STR Submissions, 2019 .............................................................................29 Figure 6: STR Submissions by Resolution Status, 2019 ..............................................................................30 Figure 7: Allocation of AML/CFT Supervisory Responsibility ..................................................................32 Figure 8: Number of Registered DNFBPs: Dec 2015 – Dec 2019 ..........................................................34 Figure 9: Registered DNFBPs by Geographical Location ..........................................................................36 Figure 10: Registration Updates by Sector, 2018 – 2019 .............................................................................37 Figure 11: Types of Alleged Offences Investigated in 2019 .........................................................................45 Figure 12: RFIs Submitted to the FIU Belize, 2016 – 2019..........................................................................48 Figure 13: RFI Submissions to the FIU 2019 by Main Submitting Countries ..........................................49 APPENDICES Appendix 1: Cases Investigated by the FIU during 2019 .................................................................................55 Appendix 2: Cases Investigated with the Assistance of the FCWG, 2019 ..................................................57 Appendix 3: Workshops and Presentations in Belize Involving the FIU, 2019 ...........................................59 Appendix 4: RFI Submissions to the Belize FIU by Country of Submission, 2016 - 2019 .......................61 5 ACRONYMS and ABBREVIATIONS aka also known as AML/CFT Anti-Money Laundering/Combating the Financing of Terrorism BCIE Banco Centroamericano de Integración Económica (aka CABEI) BCCI Belize Chamber of Commerce and Industry BELTRAIDE Belize Trade and Investment Development Service BIFSA Belize International Financial Services Association BPD Belize Police Department BZD Belize dollars CABEI Central American Bank for Economic Integration (aka BCIE) CAIS Central American Integration System (aka SICA) CARICOM Caribbean Community CARSI Central America Regional Security Initiative CBB Central Bank of Belize CDB Caribbean Development Bank CDD Customer Due-Diligence CE Common Era CELAC Community of Latin American and Caribbean States CEO Chief Executive Officer CFATF Caribbean Financial Action Task Force 6 ANNUAL REPORT 2019 COPOLAD Cooperation Programme between Latin America, the Caribbean and the European Union on Drugs Policies CRC Costa Rican colones DNFBPs Designated Non-Financial Businesses and Professions DPP Director of Public Prosecutions EU European Union EUR Euro FATCA Foreign Account Tax Compliance Act FATF Financial Action Task Force FCWG Financial Crimes Working Group FINTRAC Financial Transactions and Reports Analysis Centre of Canada FIU Financial Intelligence Unit GBP UK Pounds Sterling GDP Gross Domestic Product GTQ Guatemalan quetzal IBC International Business Company IDB Inter-American Development Bank IFSC International Financial Services Commission IMF International Monetary Fund km2 square kilometres KYC Know Your Customer ML Money Laundering MLCO Money Laundering Compliance Officer MLTPA Money Laundering and Terrorism (Prevention) Act 7 MXN Mexican peso N/A, n/a Not Available NAMLC National Anti-Money Laundering Committee NGOs Non-Governmental Organisations NPOs Non-Profit Organisations NRA National Risk Assessment OECD Organisation for Economic Co-operation and Development OFAC Office of Foreign Assets Control (part of the US Treasury Department) ORINCO Organisation of Insurance Companies OSIPP Office of the Supervisor of Insurance and Private ensionsP OTA Office of echnicalT Assistance, US Treasury PEP(s) Politically Exposed Person(s) RFIs Request(s) for Information SICA Sistema de la Integración Centroamericana (aka CAIS) STR(s) Suspicious Transaction Report(s) TF Terrorism Financing UK United Kingdom of Great Britain and Northern Ireland UN United Nations UNODC United Nations Office on Drugs and Crime US, USA United States of America USD United States dollars WTO World Trade Organisation 8 ANNUAL REPORT 2019 DIRECTOR’S MESSAGE The Belize Financial Intelligence Unit (the FIU) is a hybrid to have open and frank discussions on matters of mutual type FIU that is responsible for the reception and analysis interest and to minimize barriers to cooperation. The FIU, of suspicious transaction reports (STRs) from Reporting and other supervisory agencies, reiterated that sound AML Entities, and investigating and prosecuting financial crimes, supervision was predicated on strengthening the financial as necessary. The FIU is also ex officio chair of the system and removing obstructions to legitimate business. National Anti-Money Laundering Committee (NAMLC) A common misperception is that AML efforts run counter and provides secretariat functions to workings of the to ease of doing business, and that the investment in a Committee. One of the premiere mandates of NAMLC prudent, viable AML regime is a non-recoverable cost to is to advise the Minister of Finance on the development the business sector. On the contrary, it was highlighted, and of a national, coordinated Anti-Money Laundering (AML) generally agreed, that such capacity is a sterling, intangible action plan. It is only through
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