20 20 ANNUAL REPORT ii FIU BELIZE ANNUAL REPORT 2020 F0.!J. FINANCIAL INTELLIGENCE UNIT
Director 4998 Coney Drive, Coney Drive Plaza P.O. Box 2197 Belize City, Belize
June 15, 2021
Honourable John Briceno Prime Minister and Minister of Finance, Economic Development and Investment Office of the Prime Minister Sir Edney Ca in Building BELMOPAN
Dear Prime Minister:
FIU Annual Report 2020
Pursuant to Section 19 (l)(b) of the Financial Intelligence Unit (FIU) Act, I am pleased to present to you the FIU's Annual Report for 2020.
Th is Annual Report reflects the Unit's efforts during 2020 to further strengthen our nationa l ca pacity to counter money laundering and the financing of terrorism and proliferation of weapons of mass destruction, all with a view to the safeguarding of Belize's financial system. Th rough these efforts Belize contributes to the protection of the global financial system from criminal abuse.
The FIU commits to continuing collaboration and cooperation with the other member institutions of the National Anti-Money Laundering Committee to ensure that Belize is compliant with the anti-money laundering and cou ntering the financing of terrorism Recommendations of the Financial Action Task Force. '""""'~
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FIU BELIZE ANNUAL REPORT 2020 iii TE~EPHONE: (SO 1)223. 0S9612729 EMA IL: qualhyassurance@f'iubeli:ze.org or fiu.beliie@_Oubclize.org 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
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'- --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- programs. In Belize we saw increased tation Agency for Crime and Security cases of consumer fraud especially (IMPACS) and the United States’ Bureau in social media marketplaces. The FIU of International Narcotics and Law En- also collaborated with tax agencies to forcement Affairs (INL). pursue complaints of malfeasance.
We also used innovative technology to In conclusion, FIU management con- continue to have effective communi- tinues to recognize that the lessons of cation with our reporting entities. This 2020 cannot be overlooked, notwith- included the creation of an online Por- standing the intense desire to move on tal which allowed for the receipt and from the pandemic. Clearly, we must transmission of suspicious transaction be strategic in the exercise of our du- reports (STRs), requests for information ties. We must learn to operate effec- (RFIs) and general feedback. The objec- tively with less-than-optimal resources. tive was to minimize the issue of paper We must therefore plan for the future communication which was a prudent in a proactive fashion, considering that recommended strategy to minimize failures have costs attached to them, contagion by the coronavirus. sometimes even the loss of human life. The virtual workspace is the world of the Finally, the pandemic reminded us that future and we must evaluate efforts to criminal activity does not take a break increase productivity in that new world. simply because of pandemics. If any- Decision-making must be flexible and thing is to be learned, it is that criminals the fear of not having a perfect solution will find novel ways of attacking the fi- should not prevent us from investing in nancial system and the unsuspecting sensible, common sense strategies to public. On the international scene, there improve the common lot. was a 150 percent increase in ransom- ware attacks globally1. Moreover, crimi- nal gangs habitually pursued frauds
1 https://cisomag.eccouncil.org/growth-of-ransomware-2020/
FIU BELIZE ANNUAL REPORT 2020 9 Belize is a small, independent country Country (land area of about 23,000 km2, with a population estimated at 420,000 in Overview mid-2020) located on the south-east- ern quadrant of the Yucatán peninsula in the western Caribbean, sharing its northern boundary with Mexico, and its western and southern boundaries with Guatemala. The borders are porous, with rivers at the north and south, moun- tainous jungle in the west, and with nu- merous cayes and sandbanks along the length of the country off the Caribbean coast on the east. These factors, to- gether with low population density and flat terrain in the north and east of the country, enable the transshipment of il- legal drugs by air and sea from produc- tion areas in South America into Mexico, despite ongoing interdiction efforts co- ordinated with neighbouring countries.
10 FIU BELIZE ANNUAL REPORT 2020 Belize is a lower middle-income country culties in agriculture caused by disease with average per capita income estimat- and drought. ed at USD 3,915 in 2020. Both the size of the rural population and the extent of The financial system is small and rela- rural poverty exceed levels in urban ar- tively undeveloped, with commercial eas. Traditionally, economic activity has banks, credit unions, and insurance been based on export-oriented agricul- companies dominating the formal tural commodity production and some sector. Capital market activity con- agro-processing, although tourism has sists mainly of transactions in domestic now become the main industrial con- public sector securities for prudential tributor to employment, incomes, and reserves management purposes by fi- public sector revenues. The economy nancial institutions, with the securities is highly open, dependent on imports having been issued mainly to fund the for investment and non-food consump- public sector. There is no formal secu- tion items. Reflecting ongoing migration rities market. both into and from Belize, the population is ethnically and culturally diverse; net Two free-zones, one at the western inward migration and a relatively high border with Guatemala and the other at birth rate have resulted in an estimated the northern border with Mexico, facil- average annual population growth rate itate the tax-free import and re-export of 2.7% between 1992 and 2020. Al- of goods for sale to visitors from those though real economic growth averaged two countries, with sales in the free- 3.4% annually between 1992 and 2019, zones taking place mainly in USD cash, average real per capita GDP growth was despite efforts on the part of the author- marginal (0.7%) over the same period as ities to encourage the use of non-cash a result of the rate of population growth. instruments. These goods are not avail- In recent years economic activity has able for sale in the domestic market. been adversely affected by supply diffi-
FIU BELIZE ANNUAL REPORT 2020 11 The country’s business structure also airlift. While other cross-border trade includes locally licensed entities that in goods was not substantially affect- in the past provided business services ed, free-zone operations were closed. exclusively to offshore clients. These Unemployment and underemployment international business companies are increased significantly. The interna- now required to have domestic eco- tional airport was reopened in October, nomic presence that supports reported following special arrangements for vis- profits, and have since early 2020 been itor testing and hotel accommodation, made subject to domestic taxation and but the flow of visitors remained low detailed operations reporting as part of through to year-end. global efforts to close tax loopholes and address potential money laundering by The public finances came under severe multinational entities. pressure as revenue flows contract- ed at the same time that Government Mainly as a result of its dependence on spending expanded rapidly in order to tourism, the COVID-19 pandemic and maintain services in a changed environ- the effort to halt disease transmission ment, to provide for the unanticipated had major negative impact on Belize widespread medical emergency, and to in 2020, with preliminary data indicat- ensure basic income and social support ing GDP contraction of about 14% from for the large number of persons who the 2019 level. The closure of all bor- lost all or most of their incomes as a re- ders to movement of persons brought sult of the virus infection containment the tourism industry to a halt in March, measures. With the expenditure fi- with further disruption resulting from nanced by borrowing and with GDP and restrictions on social gatherings, street- revenue contracting, the public sector side vending, closure of operation of debt/GDP ratio rose sharply. places of entertainment and recreation, the closure of schools, the introduc- By year end, there had not been re- tion of night-time curfews, and the re- ports of noticeable increases in the in- quirement for physical distancing and cidence of financial crime as a result of mask-wearing. The use of bus trans- the COVID-19 emergency, although the portation by commuters countrywide switch to greater use of on-line arrange- declined substantially, and the absence ments for business transactions would of tourist visitors meant a sharp fall-off have increased the risk of identity mis- in the use of water taxis and domestic representation and other forms of fraud;
12 FIU BELIZE ANNUAL REPORT 2020 and the need to acquire personal pro- been removed. As in 2019, there was tective equipment and to put in place little identified evidence of funds asso- quickly other kinds of anti-COVID-19 ciated with the drug shipments entering protection and business support ar- the domestic banking system, and the rangements would have created op- drug items themselves were thought portunities for the deliberate bypassing to have been transported overland to of controls against misprocurement. Mexico. No drug-transit interceptions by sea were reported. The pandemic did not result in any ap- parent reduction in the efforts of nar- The domestic response to the pandem- co-traffickers to use Belize as a transit ic resulted in the shifting of anti-money point for cocaine and other illegal items laundering and countering the financ- from production centres in the south to ing of terrorism (AML/CFT) registration, user-markets in the north. As in 2019, oversight and outreach activities to the the authorities intercepted a number of electronic media, with reviews being drug shipments together with transpor- conducted by desk analysis, telephone tation aircraft but were aware of ship- and on-line, and with presentations to ments that landed in Belize and escaped and interactions with groups making interdiction. In addition to seized aircraft greatly expanded use of video-confer- and cargo, with persons being arrest- encing facilities. A special electronic ed in at least one case, the authorities portal was provided by the FIU for the encountered a number of wrecked or receipt of STRs. burnt aircraft from which all cargo had
FIU BELIZE ANNUAL REPORT 2020 13 The following table summarises selected country indicators during 2020, compared with data for earlier years.
Table 1: Belize - Selected Indicators
ITEMS 2016R 2017R 2018R 2019R 2020P
Population (000) mid-year 378.0E 387.9E 398.1E 408.5E 419.2E
Population Growth Rate (%) 2.6 2.6 2.6 2.6 2.6
Real GDP Growth Rate (%) (.04) 1.7 2.9 1.8 (14.1)
Non-Financial Public 88.9 96.4 96.0 97.5 125.8 Sector Debt/GDP (%)
External Debt/GDP (%) 67.8 68.4 68.2 68.8 86.4
Overall Central Government (4.1) (1.4) (1.0) (4.6) (10.8) Fiscal Surplus (% of GDP)
Unemployment Rate (% of Labour 8.0 9.0 9.4 7.7 13.7 Force) (April of year shown)
Consumer Prices Index (% change) 0.7 1.1 0.3 0.2 0.1
Coronavirus Cumulative Infections 0 0 0 0 10,776
COVID-19 Deaths 0 0 0 0 248
Data Sources: Statistical Institute of Belize Central Bank of Belize International Monetary Fund data in the Concluding Staff Statement on Belize, 12 March 2021 Ministry of Health and Wellness
Notes: Numbers in brackets are negative Population, Labour and GDP numbers are estimates Fiscal data based on the fiscal year (April to March) beginning April in the year shown R = revised P = preliminary E = intercensal estimates
14 FIU BELIZE ANNUAL REPORT 2020 The FIU in Belize was established in The 2002 by the FIU Act, No. 35 of 2002, in keeping with global agreements to Financial counter financial crime including money laundering (ML) and terrorist financing (TF) at both national and international Intelligence levels. The international mandate was subsequently extended to include pro- Unit hibiting the financing of proliferation of weapons of mass destruction (PF). The anti-money laundering, countering the financing of terrorism and countering the financing of proliferation of weap- ons of mass destruction (AML/CFT/ CPF) mandates are set out in 40 Rec- ommendations issued by the FATF, an inter-governmental group established in 1989 initially for the specific purpose of dealing with money laundering, which was seen at the time as having the ca- pacity to destabilize the global financial system, with the mandate subsequent- ly extended as indicated earlier. The Recommendations, which have been
FIU BELIZE ANNUAL REPORT 2020 15 revised from time to time, are regarded domestic operations and providing pol- as the global standard for dealing with icy advice to the Minister. ML/TF/PF. The MLTPA is the primary AML/CFT/ The FIU is one of four domestic agen- CPF legislation in Belize. It sets out in cies in Belize carrying responsibility for particular the obligations for report- ensuring the implementation of AML/ ing entities, which are entities whose CFT/CPF obligations as outlined in the regular occupation or business is the provisions of the Money Laundering carrying on of any activity listed in the and Terrorism (Prevention) Act (MLTPA), First Schedule of the Act; it establish- Chapter 104 of the Substantive Laws of es a framework to address proceeds Belize, Revised Edition 2011. The other of crime; and it empowers the FIU and three institutions are the Central Bank the other three Supervisory Authorities of Belize, the Office of the Supervisor of to carry out a broad range of oversight Insurance and Private Pensions, and the and enforcement activities. International Financial Services Com- mission (IFSC). Under these arrange- Unlike other FIUs, the Belize FIU is both ments the FIU is responsible for the su- a monitoring, data gathering, and inves- pervision of Designated Non-Financial tigations agency, and one authorised Businesses and Professions (DNFBPs). to prosecute and to impose penalties, administratively and through the judi- The four domestic Supervisory Author- cial process, for breaches of the rules. It ities cooperate with each other within maintains strong links with peer institu- the context of a formal Memorandum of tions in other countries for the purpose Understanding (MOU) that was signed of information sharing; is a member of in 2020. Prior to the signing, however, the Egmont Group of FIUs, and rep- the institutions cooperated closely with resents Belize in the country’s member- each other on an informal basis, as well ship of the Caribbean Financial Action as collaborating more formally with oth- Task Force (CFATF), an FATF-style re- er local law enforcement and regulato- gional body based in Trinidad & Tobago ry agencies as members of a National that is an associate member of the FATF Anti-Money Laundering Committee and that oversees its members’ techni- (NAMLC), established under the MLT- cal and effectiveness compliance with PA and chaired by the FIU, and whose the FATF Recommendations. main functions include coordination of
16 FIU BELIZE ANNUAL REPORT 2020 Signing of Group of AML/CFT Supervisory Authorities MOU
Top Left: Kent Clare, Director - FIU Top Right: Alma Gomez, Supervisor - OSIPP Bottom Left: Claude Haylock, Director General - IFSC Bottom Right: Ambassador A. Joy Grant, Governor - CBB
FIU BELIZE ANNUAL REPORT 2020 17 The full scope of the FIU’s functions currently includes:
• countering financial crime, broadly defined, through independent review and research, through receipt and analysis of STRs, dissemination of intelligence to appropriate law enforcement authorities, investigation and prosecution of financial crime, and depriving criminals of the proceeds of crime; • ensuring coordination and cooperation among law enforcement agencies, government departments, and regulatory authorities in the effort to counter ML, TF, and PF, and to prosecute criminal activity involving these activities. These are effected at a high level through NAMLC (mentioned earlier), and at the investigations and enforcement level both directly and through a Financial Crimes Working Group (FCWG), chaired by the Belize Police Department (BPD) with the FIU as Deputy Chair, and which meets as required; • cooperating with and assisting external counterparts, including international law enforcement agencies and other official regulatory or supervisory bodies in other countries, that are charged with responsibilities similar to those that are devolved on the FIU and NAMLC; • representing Belize’s interests in the CFATF and participating in peer evaluations of FATF-mandated supervision technical compliance and effectiveness assessments in other CFATF member jurisdictions; • informing and educating the domestic population regarding ML, TF, PF and financial crime issues generally, and in relation to the obligations of the general public to assist with the detection, prevention, discouragement, and deterrence of financial crime; and • serving as Secretariat for NAMLC.
18 FIU BELIZE ANNUAL REPORT 2020 The FIU is headed by a Director, ap- compliance reviews of DNFBPs, es- pointed by the Governor-General on sentially private business firms whose the advice of the Prime Minister, and is primary business is not that of a finan- assisted by a Deputy Director. FIU oper- cial institution. Under the MLTPA, each ations are conducted through four main reporting entity (DNFBP or otherwise) functional areas: Analysis, Compliance, is expected to have a money launder- Investigations, and National Risk As- ing compliance officer (MLCO), whose sessment (NRA), with human resources, function is to ensure that the business financial management, and operations operation conducts ongoing due-dil- and information management support igence reviews on its clients and sup- being provided by a Human Resources pliers, and of transactions conducted or Department and by Systems Adminis- attempted by those clients and suppli- tration. ers, and to report (AML/CFT/PF) suspi- cious transactions to the FIU. The De- The Analysis Department reviews and partment engages in ongoing outreach analyses trends and patterns in financial sessions to familiarise DNFBPs with flows, including the size and composi- their behavioural and reporting obliga- tion of flows, origins and destinations, tions and conducts both desk and on- transactions purposes, and, in particu- site examinations to ensure that entities lar, departures from trends. Patterns in are operating in accordance with their non-financial value exchange transac- obligations2. Reports from the Compli- tions are also reviewed for indicators of ance Department, including STRs from possible ML predicate criminal activity. DNFBPs, are reviewed by the Analysis This work is based on analyses of STRs Department. involving both domestic and cross-bor- der transactions, together with reports The work of the Investigations Depart- of other crimes that may result in finan- ment is in keeping with the FIU’s man- cial proceeds or proceeds of value oth- date in its Act to investigate and pros- er than financial instruments. Findings ecute activities involving ML, TF, and from analytical reviews are passed on financial crime generally. This Depart- to the Investigations Department as ap- ment works closely with other law en- propriate. forcement agencies, both domestic and foreign, with the Department Head The Compliance Department is respon- serving as Deputy Chairperson of the sible for the registration and AML/CFT domestic FCWG.
2 Similar activities are undertaken by the other Supervisory Authorities in respect of entities that report to them.
FIU BELIZE ANNUAL REPORT 2020 19 With the continuing expansion and in- portance to the FIU given the fact that tensification of international cooperation real estate agents are classified as DN- in addressing financial crime, countries FBPs and are subject to AML/CFT/CPF have increasingly found it necessary, in supervision by the FIU, and given evi- line with the FATF Recommendations, dence of past fraudulent activity in the to bring a risk-based approach to the sector. effort. The FIU, as Chair of NAMLC, co- ordinated the completion of the coun- Notwithstanding the COVID-19 restric- try’s first NRA in 2020, together with a tions and the physical distancing re- draft action plan to address issues iden- quirements, the FIU participated in nu- tified in the NRA. Keeping the NRA up- merous meetings, conferences, and dated, in line with continuing changes in training sessions during the year, with the domestic and international environ- all but a very few sessions held on-line. ment, together with providing oversight FIU staff members were involved as in the ongoing implementation of action presenters at meetings, conferences plans, given FIU’s role as the NAMLC and outreach sessions; as participants in Secretariat, will require further strength- peer discussion sessions; and as train- ening of this area of operations within ees in sessions designed to enhance the FIU. the capacity of both the Unit and the Belize jurisdiction to deliver effectively During the year the FIU participated on the AML/CFT/CPF mandate. More in discussions on required legislative detail on staff participation in these ses- changes, and on two draft Bills in par- sions is provided in a subsequent sec- ticular, one covering real estate oper- tion of this Report. During the year, the ations, the other addressing financial FIU as a unit received considerable di- securities. Formal regulation of the rect technical support from a number real estate industry is of particular im- of entities, including CFATF and the US
20 FIU BELIZE ANNUAL REPORT 2020 (the latter through the US Treasury and into 2020 had been focused on produc- through the in-country Embassy), and ing Belize’s first NRA. This broad-based indirectly through a broader range of in- undertaking was intended to develop stitutions including the UN and the Eu- a comprehensive understanding of the ropean Union. ML and TF threats faced by the coun- try, and its level of vulnerability to those In order to strengthen its operation- threats, resulting in a determination of al function, the Belize FIU during 2020 risks and their prioritisation. With parts added a legal officer to support its finan- of the information used to prepare the cial investigators, all but one of whom, risk assessment being somewhat dated including the Department Head, are (challenges with human resources and on attachment from the BPD. This at- data availability had delayed completion tachment arrangement allows the FIU of aspects of the exercise), substantial both to draw on its own internal analy- effort during 2020 went into presenting sis and investigation capacity as well as the findings to stakeholders, and re- on the technical and physical capacity ceiving feedback, and into developing of the Police Department. Through the an Action Plan to address the technical FCWG, the FIU also has access to legal compliance and operational effective- guidance from the Office of the Director ness gaps identified by the NRA. of Public Prosecutions. Under the MLT- PA, the FIU can seek the forfeiture of More information on the activities of the the proceeds of financial crime. FIU during 2020 are provided in subse- quent sections of this Report. As mentioned briefly earlier, the FIU also coordinates national AML/CFT/ At the end of the year the FIU had 28 CPF risk assessment activities, and in persons on staff, including four mem- the period through the end of 2019 and bers on attachment from the BPD.
FIU BELIZE ANNUAL REPORT 2020 21 The NAMLC was formally established in 2014 by an amendment to the MLT- PA, included as Section 77B of that National Act. Chaired by the Director of the FIU, Anti-Money NAMLC is charged with: a) advising the Minister on matters involving countering ML, Laundering countering TF, and combating PF. In addition, NAMLC is Committee responsible for the development and implementation of a (NAMLC) national action plan that includes the effective collaboration of supervisory and law enforcement agencies in the AML/CFT/CPF effort, and to suppress financial crime;
b) advising the Minister on Belize’s participation in the international AML/CFT/CPF effort and on the country’s relations with external agencies; and
c) advising the Minister on the development and maintenance of effective AML/ CFT and anti-proliferation policies and strategies.
22 FIU BELIZE ANNUAL REPORT 2020 Given its composition and responsibili- The following is a list of senior public ties, the overall success of the effort to sector officials who were NAMLC mem- counter financial crime is in no small part bers, or who participated in NAMLC ac- dependent on the level of involvement tivities during 2020: and participation of NAMLC members and the institutions they represent, the • the Director of the FIU effectiveness of NAMLC’s activities, and • the Solicitor General the level of support provided to the FIU • the Financial Secretary in its role as NAMLC Secretariat. • the Chief Executive Officer of the Ministry responsible NAMLC met formally on four occasions for the Police Department during 2020 (in February, July, October, • the Commissioner of Police and December) to address matters that • the Director General of arose requiring broad consultation in- the International Financial volving the Committee as a whole, al- Services Commission though members maintained informal • the Director General of the contact with each other on specific -is Belize Tax Service Department sues. While participants were in physi- • the Governor of the cal attendance at the February meeting, Central Bank of Belize the COVID-19 transmission suppression • the Director of Public measures instituted by the authorities Prosecutions resulted in the other three meetings • the Comptroller of Customs being held virtually. All meetings were • the Director of Immigration chaired by the Director of the FIU. • the Supervisor of Insurance and Private Pensions
FIU BELIZE ANNUAL REPORT 2020 23 The formal meetings considered or dealt with a number of issues. Among them:
i. completion of the NRA and the preparation of an Action Plan to address identified risks. Arrangements were agreed for the updating of the NRA beginning in mid-2021; ii. strengthening supervision of reporting entities and assisting them in identifying and mitigating AML/CFT risks, based on CFATF guidance; iii. participation in a regional asset recovery project; iv. implementation of the new arrangements for the domestic on-boarding of international business companies, and the integration of the two separate companies registries into a single, electronic Companies Registry; v. alerting the public to the possibility of unauthorised and fraudulent activity by persons claiming to represent Government agencies, particularly in relation to tax matters; vi. development of a concept paper for the regulation of Virtual Asset Service Providers; vii. development of a strategy for the dissemination of the NRA results and Action Plan; viii. requesting technical assistance from the World Bank for the strengthening of the national AML/CFT regime; and ix. development of an asset recovery forum within the FCWG to ensure asset recovery is pursued during financial crime investigations and prosecutions.
Two issues remained outstanding at virtual assets and virtual assets services year-end, reflecting time constraints on providers, and, in the other, the changes the availability of NAMLC members and in the legislation affecting legal entities their institutions as a result of the ongo- licensed by the IFSC had resulted in the ing COVID-19 restrictions and the re- private sector raising tax liability issues. quirements of a new Administration fol- At year-end, the Belize Tax Service De- lowing general elections in November. partment (BTSD) and the IFSC were in In one case, it had not been possible to the process of addressing the issues. commence discussions on the issue of
24 FIU BELIZE ANNUAL REPORT 2020 Conducting an NRA is in line with the recommendations of the FATF which seeks to ensure that AML/CFT regimes are developed to support measures that would adequately mitigate ML and TF risks based on the actual levels and types of risks identified in the country. Belize commenced its first NRA in May 2016 in order to identify, assess and un- derstand the ML and TF risks within the country and establish a risk-based and National more effective AML/CFT regime. The NAMLC, which is responsible for Risk advising the Minister of Finance in the development of national policies and a plan of action to combat ML and TF, Assessment was also responsible for conducting the NRA, with the actual work being coordi- nated by the FIU. The NRA, which was organized, led and owned by the coun- try, was conducted using the World Bank’s NRA Tool, which is an analytical risk assessment tool to guide countries in conducting their ML and TF risk as- sessment at the national level. The tool consists of modules which are made up of variables that represent factors (threats and vulnerabilities) related to ML and TF risks. All variables in the modules are assessed, using an ap- proach that leads to a conclusion about the level of risk in the country. The as- sessment, using the World Bank Tool together with the use of a three-phased
FIU BELIZE ANNUAL REPORT 2020 25 process involving preparation, assess- plan with key stakeholders, beginning in ment and finalization, was completed by January of 2021. The authorities were of seven working groups that were made the view that knowledge of the results up of staff-members from the country’s of the NRA would assist competent au- AML Supervisory Authorities, law en- thorities to develop policies to effective- forcement agencies, other competent ly combat ML/TF and assist financial in- authorities, and government ministries stitutions and DNFBPs with information and departments. necessary to identify, assess, monitor, manage and mitigate their ML/TF risks. The finalization phase of the NRA was Sharing components of the national Ac- conducted during 2020. This phase in- tion Plan with stakeholders would pro- cluded the World Bank’s review of the vide them with knowledge of the plans draft risk assessment report to ensure to mitigate national risks and the role the accurate use of the assessment they needed to play in mitigating those tool, finalization of the risk assessment risks. Implementation of the Action Plan report, and approval of the report by was also expected to start early in 2021. NAMLC. A detailed national action plan was also developed by working group At the completion of Belize’s first ML/TF leaders and approved by NAMLC for NRA, it was determined that the coun- the implementation of a risk-based ap- try’s ML risk was medium-high while the proach to prevent or mitigate the iden- TF risk was medium-low. ML/TF risks tified ML and TF risks. One outcome of are a combination of threats (the predi- the finalization phase was the -devel cate crimes linked to ML), vulnerabilities opment of a strategy to disseminate (the opportunities that allow ML to take the results of the NRA, and to share place), and consequences (the impact the components of the national action of vulnerability).
National Money Laundering Risk
In the assessment of ML risks, the ML ability rating of medium-high on a risk threat for the country was assessed to map as per Figure 1 below. Using this be Medium, while national ML vulnera- method in accordance with the World bility was assessed to be Medium-High. Bank’s NRA methodology, the ML risk The ML risk level for the country was level for the country was determined to then determined by mapping the ML be Medium-High. Threat rating of medium and ML vulner-
26 FIU BELIZE ANNUAL REPORT 2020 Figure 1: Country Money Laundering Risk Level
M M MH H H
M M MH MH H
ML M M MH MH ML ML M M M
OVERALL THREAT OVERALL L ML ML M M
OVERALL VULNERABILITY
L = Low ML = Medium Low MH = Medium High H = High
In determining the ML threat level for the laundering threat (MLT); a second cate- country, 25 criminal offences which may gory of offence (Corruption and Bribery) present linkages to ML were assessed. was assessed to be Medium-High MLT; The assessment of these offences in- four offences (Theft, Tax Evasion, Fraud, cluded analysis of the prevalence of the and Forgery) were assessed to be Me- offences, possible proceeds being gen- dium MLT; and three offences (Robbery, erated from the offences and whether Smuggling of Goods, and Failure to De- the source of criminal proceeds were clare Currency) were assessed to be domestic or foreign criminal activities. Medium-Low MLT. These offences were Of the 25 predicate offences assessed, regarded as the main proceeds-gener- one offence (Illicit Trafficking in Narcot- ating crimes in Belize and are listed in ic Drugs and Psychotropic Substances) Table 2 below. The remaining 16 offenc- was assessed to involve a High money es were assessed to constitute low MLT.
FIU BELIZE ANNUAL REPORT 2020 27 Table 2: Main Offences that Generate Proceeds of Crime in Belize
MONEY LAUNDERING NO. PREDICATE OFFENCE SOURCE THREAT RANK
1 Illicit trafficking High Foreign, Home in narcotic drugs and psychotropic substances
2 Corruption and Bribery Medium High Foreign, Home
3 Theft Medium Home
4 Tax evasion Medium Foreign, Home
5 Fraud Medium Foreign, Home
6 Forgery Medium Foreign, Home
7 Robbery Medium Low Home
8 Smuggling (goods) Medium Low Foreign, Home
9 Failure to declare Medium Low Foreign, Home currency
The national ML vulnerability is influ- The sectoral vulnerability assessment enced by the ML vulnerabilities iden- indicates that most of the DNFBP and tified in the sectoral and national AML Other Financial Services sectors have frameworks. In assessing vulnerabilities high and medium-high vulnerability to in these frameworks, variables which ML. reflect key features of the frameworks were assessed.
28 FIU BELIZE ANNUAL REPORT 2020 The following tables present the results of the ML risk rating of the various sectors,3 including the sector vulnerability ratings.
Table 3: Money Laundering Risk Rating of Financial Sectors
FINANCIAL ML RISK NO. THREAT VULNERABILITY SECTOR RATING
1 Remittance High High High Service Providers
2 International High Medium High High Securities
3 Money Lenders Medium High Medium High Medium High
4 International OFS (A) Medium High Medium High Medium High
5 Credit Union Medium Medium High Medium High
6 International Medium High Medium Medium High Banking
7 International OFS (B) Medium High Medium Medium High
8 Domestic Banking Medium Medium Medium
9 International Low Medium Medium Low Insurance
10 Domestic Insurance Low Medium Low Medium Low
3 International OFS (A) includes international asset protection and management, money transmission services and payment processing services. International OFS (B) includes brokerage consultancy or advisory ser- vices.
FIU BELIZE ANNUAL REPORT 2020 29 Table 4: Money Laundering Risk Rating of Non-Financial Sectors
FINANCIAL ML RISK NO. THREAT VULNERABILITY SECTOR RATING
1 Real Estate Agents High High High
2 Dealers in Motor High High High Vehicles
3 Businesses High High High Operating in a Free Zone
4 Lawyers/ Notaries High Medium High High
5 Casinos & Medium High Medium High Medium High Licensed Gaming Premises
6 Accountants/ Medium High Medium High Medium High Auditors/ Tax Advisors
7 TCSPs Medium High Medium High Medium High
8 NPOs/NGOs Medium Low Medium High Medium
9 Dealers in Precious Low Medium Medium Low Metals & Stones
30 FIU BELIZE ANNUAL REPORT 2020 National Terrorist Financing Risk
In the assessment of the TF risk for the lize or foreign jurisdictions. There were country, TF vulnerabilities was assessed also no intelligence reports to suggest to be medium-low while TF threats was regional or global terrorist organizations assessed to be low. The TF vulnerability or individuals were targeting Belize for and threat ratings resulted in an overall acts of terrorism, TF, terrorist recruiting TF risk level of medium low. or terrorism training. While there were three TF investigations during the pe- Based on the various measures under- riod under review, there were no pros- taken at the national level to strength- ecutions or convictions. Based on the en and improve capacity to detect and absence of evidence of terrorism activ- respond to terrorist acts; detect, inves- ity or intelligence to support TF related tigate, and prosecute various forms of activity in Belize, the TF threat was as- TF; and considering the fact that these sessed to be LOW. measures have not been adequately tested; the TF vulnerability for Belize has Risk assessment and mitigation is an on- been assessed as being Medium Low. going process which requires regularly updating the country’s understanding During the period under review there of its ML and TF risks. In line with this, were no intelligence reports to suggest it was expected that the process of up- domestic terrorist organizations were dating Belize’s understanding of its risks operating within Belize and targeting Be- would start in 2021.
FIU BELIZE ANNUAL REPORT 2020 31 Under the MLTPA, the FIU is the sole Analysis agency legally authorized to receive STRs. An STR is submitted when a re- and porting entity has reasonable grounds to suspect that a certain activity may be related to or is a direct result of ML or Intelligence TF. The FIU provides an STR form on its website for reporting entities to docu- ment the details of and report to the FIU activity that they deem to be suspicious.
The core function of the Analysis De- partment of the FIU is the receipt, anal- ysis and dissemination of information relating to suspected ML, TF and other activities involving financial crime. The department also reviews and analyses trends and patterns in financial flows, including the size and composition of flows, origins and destinations, trans- actions purposes, and, in particular, de- partures from trends, and provides the results of its analyses and recommen- dations, including policy recommen- dations, to management which may further share it with the Investigations Department, competent authorities and
32 FIU BELIZE ANNUAL REPORT 2020 FIU BELIZE ANNUAL REPORT 2020 33 other AML/CFT stakeholders. The work and from domestic agencies, as well of the Analysis Department is an import- as against an ongoing inflow of infor- ant information source for the FIU’s In- mation on criminal behavioural patterns vestigations Department, and for other and typologies from peer institutions competent authorities in the jurisdiction. and agencies abroad. At the same time, staff members in the department are Domestically, the department liaises engaged in the routine review of devel- with the other AML/CFT Supervisory opments in international business prac- Authorities in Belize (Central Bank of tices in media reports and specialised Belize, IFSC, and the Office of the Su- news sources. pervisor of Insurance and Private Pen- sions), and works closely with the FIU’s Both financial and non-financial report- Compliance Department to verify that ing entities, whose regular occupation reporting entities are adhering to their or business is the carrying on of any ac- obligations under the MLTPA to report tivity listed in the First Schedule of the suspicious transactions. Externally, the MLTPA, are required to file STRs with department maintains close contact the FIU whenever they encounter trans- with departments or divisions of foreign actions, or attempted transactions, that entities that have responsibilities and give them reasonable grounds to sus- mandates similar to those of the FIU. pect that the transaction is related to ML, TF, or other criminal activity. The The department’s main information flow table below lists the reporting entities on AML/CFT/CPF issues of interest to that are subject to STR reporting, and Belize comes from STRs. This infor- that are required to follow know your mation is reviewed against the results customer (KYC) protocols and conduct of past analyses and against data al- customer due diligence reviews. ready available in domestic databases
34 FIU BELIZE ANNUAL REPORT 2020 Table 5 : Reporting Entities under the MLTPA4
FINANCIAL ENTITIES NON-FINANCIAL ENTITIES
Domestic and Lawyers/Notaries/Other International Banks Independent Legal Professionals
Credit Unions Accountants/Auditors/Tax Advisors
International Financial Casinos and Gaming Service Providers Establishments
Trust and Corporate Remittance Service Providers Service Providers
Domestic and International Insurance Businesses NGOs
Moneylenders and Pawnbrokers NPOs
Businesses Operating in a Free Zone
Real Estate Agents
Dealers in precious metals and precious stones
Dealers in vehicles
4 Banks, Credit Unions, Remittance Services Providers, and Money Lenders and Pawnbrokers are super- vised by the Central Bank of Belize. International Financial Services Providers (except International Banks) and Trust and Corporate Services Providers are supervised by the International Financial Services Commission. All Insurance businesses are supervised by the Office of the Supervisor of Insurance and Private Pensions. All other entities listed are supervised by the FIU. NGOs are non-Governmental organisations, while NPOs are non-profit organisations.
FIU BELIZE ANNUAL REPORT 2020 35 The Intelligence Cycle
The intelligence cycle is the frame of This process may also be used to deter- the analytic process. During this pro- mine whether a reporting entity is meet- cess raw information is transformed, ing its AML/CFT obligations, or whether generating an intelligence product used its internal policies may be hindering its by management to determine an ap- own efforts to prevent financial crime, in propriate course of action, e.g., wheth- which case a report may be made by er further investigation or other action the FIU to the relevant Supervisory Au- is required on the part of the FIU, and thority. whether other entities, including other law enforcement agencies, need to be involved.
Figure 2: The Intelligence Cycle
MATTER IDENTIFIED FOR ACTION DISSEMINATE PLANNING/TASKING & DIRECTION The product is shared with all the necessary This is the foundation where stakeholders and, unless “structure” is created. The steps authorized by the FIU, it and guidelines to produce a good should only be used for product is set out here. It is critical intelligence purposes. to the success of the overall outcome of any finished product.
EVALUATE & REVIEW COLLECTION & COLLATION This step is taken at every stage of the cycle to keep This is where contact is made with the the process on track. necessary agencies and data There is a possibility that repositories to gather pertinent new information may be information that will aid in the analysis added to ensure that all of the case at hand. Information that is collected is sorted and categorized bases are covered before PROCESS & ANALYZE dissemination. for value to be added. Data collected are then converted to usable information through data reduction. The information is thoroughly scrutinized and evaluated, and a detailed report is produced.
36 FIU BELIZE ANNUAL REPORT 2020 Figure 3: Information Sharing Process
1111111111111111111 .. ... I I I I I I I I Reporting STR Entities ■ I ■ 1• 1 Belize FIU Law Enforcement/ Other Competent Authorities
STR Patterns
Figure 4 below shows the number of available on the FIU website; complet- STRs submitted by reporting entities ed forms are submitted on a confiden- over the period 2016 to 2020, while Fig- tial basis. It is an offence (referred to as ure 5 shows STR submissions by month “tipping off”) under the MLTPA for any during the period 2018 to 2020. Table 6 person who knows or suspects that a that follows identifies the types of en- report is being prepared or will be sent tities making the submissions. An STR or has been sent to the FIU to disclose is prepared and submitted to the FIU to another person any information or whenever a reporting entity suspects matter in relation to the report unless that a transaction, or attempted trans- the person is a Court, Supervisory Au- action, involves or is related to ML, TF, thority or other person authorized by or represents the proceeds of criminal law to receive such information. activity. As noted earlier, STR forms are
FIU BELIZE ANNUAL REPORT 2020 37 Figure 4: Number of STR Submissions 2016 - 2020
2020 279
2019 294
2018 255
2017 232
2016 221
0 50 100 150 200 250
Figure 4 shows that, except for 2020 reduced submissions by International when the number of STR filings de- Banks and by Remittance Service Pro- clined (mainly as a result of the restric- viders. There has been a steady decline tions that were imposed on the move- over the period in submissions from In- ment of persons in 2020 in response to ternational Financial Service Providers. the COVID-19 pandemic), the number STRs were filed by real estate agents for of STRs submitted has been steadily the first time in the 5-year reporting pe- increasing. As shown in Table 6 below, riod; this was attributed to the enhanced while Banks, Credit Unions, and Remit- AML outreach efforts by the FIU’s Com- tance Service Providers have been ac- pliance Department during the report- counting for the majority of the filings, ing period. Table 7 breaks down STR total submissions by this group declined submissions by suspicious transaction marginally in 2020, mainly as a result of type.
38 FIU BELIZE ANNUAL REPORT 2020 Table 6: STR Submissions by Reporting Entity Sector 2016 - 20205
REPORTING ENTITIES 2016 2017 2018 2019 2020
Domestic Banks 115 94 71 117 126
International Banks 26 27 30 34 27
International Financial 44 29 21 16 12 Services Providers
Credit Unions 7 37 72 72 72
Attorneys at Law 3 0 4 0 3
Remittance Service Providers 11 38 45 42 30
International Remittance 1 0 0 0 0 Services Providers6
Casinos 0 0 0 1 0
Domestic and International 1 5 8 8 3 Insurance Providers
Supervisory Authorities 3 1 4 0 0
Moneylenders 0 0 0 2 0
Real Estate Agents 0 0 0 0 6
Other 10 1 0 2 0
Total 221 232 255 294 279
5 The number of STRs submitted by Reporting Entity is smaller than the number of STRs by Suspicious Transaction Type as an individual STR may contain more than one suspicious transaction type. 6 This category of entity did not exist after 2016.
FIU BELIZE ANNUAL REPORT 2020 39 Table 7: STRs by Suspicious Transaction Type 2016-2020
SUSPICIOUS TRANSACTIONS TYPE 2016 2017 2018 2019 2020
Fraud 62 70 78 85 64
Money Laundering 50 8 11 10 17
Activity outside Customer Profile 26 18 38 47 39
Drug Trafficking 2 5 3 8 12
Due Diligence 34 0 0 0 0
Embezzlement 6 0 0 3 7
Unauthorized Currency Exchange 16 22 6 7 45
Large Cash Transactions 15 16 26 28 29
Tax Evasion 0 9 9 14 23
Structuring 0 41 30 26 25
Failure to Disclose Required 0 12 5 10 16 KYC Information7
Operating without Licence 0 11 5 2 1
Unwilling to Declare Source of Funds 0 17 25 29 30
Terrorist Financing 0 0 1 0 0
Other 10 12 23 25 9
TOTAL 221 241 260 294 317
7 The category that was previously reported as “Incompliant with KYC obligations” has now been renamed “Failure to disclose required KYC information” to make it clear that the suspicion involves customer inability or refusal to provide information or documentation required by the reporting entity.
40 FIU BELIZE ANNUAL REPORT 2020 Table 8: Number of Fraud-Type Reported in STRs 2019 – 2020
FRAUD 2019 2020
Fraudulent Documentation/identification 21 11
False Statement 9 6
Loan Fraud 10 2
Insurance Fraud 5 1
Securities Fraud 5 4
Forgery 4 5
Wire Transfer Fraud 9 3
Check Fraud 4 2
Possible Scam/Ponzi Scheme 5 12
Online Banking Fraud 4 4
Credit/Debit Card Fraud 3 4
Romance Scam 2 1
Tax Fraud 2 2
Advance Fee Fraud 1 1
Invoice Re-Direction Fraud 1 0
Sales Scam 0 3
Medical Fraud 0 1
Empty Envelope Fraud 0 1
Counterfeit Currency 0 1
85 64
FIU BELIZE ANNUAL REPORT 2020 41 Fraud, unauthorized currency exchange The sharp increase in the unauthorized and activity outside customer profile currency exchange category involved were the most commonly reported deposit transactions in a credit union suspicious activities in 2020, although which turned out to be local payments other categories (eg, structuring, un- in exchange for foreign currency de- willingness to declare sources of funds, posits in another jurisdiction. Suspicion large cash transactions, and tax eva- of tax evasion has been steadily in- sion) appeared in a substantial number creasing, and has been attributed to im- of reports. During the five-year period proved transactions scrutiny on the part reported in Table 7, fraud was the most of reporting entities. frequent reason for STR submission; Table 8 shows the various categories of suspected fraud that were reported in 2019 and 2020.
Value
The monetary values involved in STRs USD-denominated STRs rose sharply were generally reported in either BZD, in 2020 compared with values during USD or EUR. The value of individual the previous three years. Aggregat- transactions was not always available ed values of STRs involving Euros and due to the type of transaction being UK sterling were relatively small, or not undertaken or reflecting the point at available. On an aggregated value ba- which the suspicion was formed and sis, the overwhelming majority of STRs reported. Falling into this category were came from domestic banks, with cred- attempted transactions that were not it unions, locally licensed international completed, including attempts to open banks, and attorneys-at-law reporting accounts. As Table 9 below shows, the much smaller values. total aggregated values of BZD- and
42 FIU BELIZE ANNUAL REPORT 2020 Table 9: Types and Values of Currencies Reported in STRs 2016-2020 (Values in millions of currency units)
CURRENCY 2016 2017 2018 2019 2020
BZD 16 11.7 61.2 29 156.37
USD 102 56.9 17.1 18.1 102.39
EUR 1 0.7 n/a 0.007 0.0045
GBP n/a 10.9 n/a 0.005 n/a
Geographical Location
Of the 279 STRs submitted, 261 oc- ity related to mainland Belize District curred in Belize while 18 had the activity and 18 were based on activity related to occurring internationally. The majority Ambergris Caye and Caye Caulker. The of the reporting involved activity in the lowest number of STRs submitted (6 or Belize District, accounting for 137 or 2.1% of the total) came from the Toledo 49.1% of total submissions. From these District. Chart 1 below shows the geo- submissions, 119 were based on activ- graphical distribution of STR reporting.
FIU BELIZE ANNUAL REPORT 2020 43 Corozal 7 Chart 1: STR Submissions by Location of Suspicious ! Activities 2020 Orange Cayes Walk 18 59 Belize 119
Cayo 27 Stann Creek 24
Foreign Jurisdiction Corozal Toledo % Toledo 6 3% 6 % 2 Orange Walk Stann Creek 21% 9%
Cayo 10%
Chart 2: Percentage of Belize STR Submissions 49% by Location 2020
44 FIU BELIZE ANNUAL REPORT 2020 Resolution
STRs are reviewed upon receipt and stances and with different economic given a priority ranking based on a scor- actors, so that each event adds to the ing matrix to determine whether there store of knowledge available to the FIU, should be further analysis and the pri- improving its capacity to deliver on its ority that analysis should be given. The mandate. findings from the initial review may re- sult in the involvement of the Investiga- The FIU seeks to analyse and resolve tions Department at a very early stage the matter in a timely manner. Classifi- in the proceedings, or involvement may cation as active indicates that analysis take place during the course of subse- is ongoing, while resolved indicates that quent analysis. Although STRs may be analysis is complete, and the informa- closed when matters related to a par- tion has either been disseminated or ticular transaction are satisfactorily re- filed for intelligence. Of the 279 STRs re- solved, the typologies and behaviour ceived in 2020, 218 (78%) were resolved patterns may resurface in other circum- while 61 (22%) were active at year end.
Chart 3: STR Submissions by Resolution Status 2020
22% Active 78% Resolved
FIU BELIZE ANNUAL REPORT 2020 45 ACTIVITY TYPES AND TRENDS
The FIU has identified the following continuing and emerg- ing trends in ML techniques and predicate offenses during the course of 2020:
• Activity inconsistent with the stated business purpose • Tax evasion • Unauthorized currency exchange • Structuring o Avoiding declaring source of funds (domestic banks); o Avoiding obtaining approval from the Central Bank (Remittance Service Providers).
46 FIU BELIZE ANNUAL REPORT 2020 TYPOLOGY Sales Scams Person A posts items for sale on social media and Person B expresses interest in purchasing. Person A provides Person B with payment instructions which, usually, is to be made via a remittance services pro- vider or a bank. When Person B presents Person A electronically with evidence of payment, Person A does not respond, and ceases communication with Person B. Red Flags: • request for quick pre-payment as items are allegedly in short supply; • limited seller identification; • generic photos of sale items rather than photos of specific sale items. Possible Actions: • request same-time exchange of payment and item; • request “Trying before buying”, especially for electronic or mechanical items; • research and compare prices of similar items; • request seller to show proof of possession of items; • utilise a trusted intermediary to receive and hold both payment and items.
FIU BELIZE ANNUAL REPORT 2020 47 Suspicious Transactions by Sector Domestic Banks and Credit Unions There were 198 STRs submitted by International Banks domestic banks and credit unions in 2020: 70.9% of total submissions or a Of the 27 STR submissions from interna- 4.7% increase compared to 2019. The tional banks, the majority (15) were fraud most common activities involved in related. The remaining 12 submissions STRs from domestic banks were relat- involved suspicion of activity not with- ed to tax evasion, failure to disclose re- in institutions’ risk appetite, embezzle- quired KYC information or documents, ment, tax evasion, failure to disclose re- and activity outside of customer profile. quired KYC information or documents, The most common suspicious activity sanctioning by other jurisdictions, activi- reported by credit unions in 2020 was ty outside customer profile, and bribery. classified as unauthorized currency ex- change. Insurance Designated Non-Financial Businesses and Professions There were three STR submissions by this sector. Of the three submissions, This grouping had nine submissions: two were related to adverse risk-pro- three submissions by Attorneys-at-law file information from suspicions of drug and six submissions by real estate trafficking, and one related to fraud. agents.
48 FIU BELIZE ANNUAL REPORT 2020 Remittance Service Providers
In the Remittance Service Providers sector there were 30 submissions. The most frequent suspicious activity re- ported involved “structuring”, account- International Service ing for 23 of the submitted STRs. These Providers structuring submissions were as a result of persons using multiple agents, and/ For International Financial Services or persons conducting multiple transac- licensees, only corporate service pro- tions on the same day to avoid the need viders submitted STRs. Of the 12 sub- to obtain exchange control permission missions by this subsector, four submis- from the Central Bank of Belize for indi- sions each were for activities not within vidual transactions exceeding USD500. institutions’ risk appetite, and fraud, with No other sector reported structuring the remaining four submissions involv- transactions. The remaining STRs from ing embezzlement, failure to disclose this sector involved fraud (six) and drug required KYC documents, funds com- trafficking (one). mingling, and bribery.
Attorneys-at-Law Real Estate Agents
In the three submissions made by At- Three types of suspicious activities were torneys, there were four reported sus- involved in the six STR submissions: picious activities categories, two related these were fraud, concerns related to to fraud, one for tax evasion and one for possible drug-trafficking, and failure to failure to disclose required KYC docu- disclose required KYC documents. ments.
FIU BELIZE ANNUAL REPORT 2020 49 RESPONSE TO COVID-19 BY THE ANALYSIS DEPARTMENT In responding to the COVID-19 pan- demic and the national measures im- plemented to control the spread of the virus, the Analysis Department took the following actions with respect to its re- lations with reporting entities and the general public:
• a survey questionnaire was sent to reporting entities to assess the effects of the pandemic on transaction monitoring and reporting obligations and to understand the response measures implemented to ensure ongoing AML/CFT compliance;
• a portal was created for the secure transmission of confidential information between the FIU and individual reporting entities; and
• a COVID-19 related fraud alert was issued to the general public.
50 FIU BELIZE ANNUAL REPORT 2020 The First Schedule of the MLTPA identi- fies activities and businesses subject to the obligations of the Act while the Third Schedule identifies the Supervisory Au- thority for the activities and businesses subject to the Act. The Compliance De- partment of the FIU leads the Unit’s su- pervision of DNFBPs function.
A DNFBP is any person who intends to Supervision carry on or is carrying on a business or profession for which the FIU is specified and as the Supervisory Authority under the Third Schedule of the MLTPA. These Enforcement persons include:
o Lawyers, notaries and other independent legal professionals8; o Accountants, auditors and tax advisers; o Casinos, gambling houses and online gaming; o Dealers in precious metals and precious stones; o Businesses operating in a free zone area; o Non-Governmental organisations; o Non-profit organisations; o Real Estate agents; and o Vehicle dealers. 8 Lawyers, notaries and legal professionals are reporting entities when they carry out the following activi- ties for their clients: Buying and selling of real estate Management of client money, securities or other assets Management of bank savings or securities accounts Organization of contributions for the creation, operation or management of companies, or Creation, operation or management of legal persons or arrangements, and buying and selling of business entities.
FIU BELIZE ANNUAL REPORT 2020 51 The FIU focuses its supervisory activities on the following key areas to ensure that re- porting entities meet their AML/CFT obligations:
o initial registration with the o reviewing independent audits FIU, along with the updating of AML/CFT compliance of registration information regimes of DNFBPs; whenever changes o enforcing compliance occur, or annually, if no with AML/CFT obligations changes have taken place, through the imposition of whichever occurs first9; administrative sanctions; o ensuring that each DNFBP o ensuring awareness of AML/ appoints an MLCO who is a CFT obligations and new ML senior member of staff, and and TF typologies and trends whose appointment as MLCO through outreach sessions is approved by the FIU; and ongoing provision of o conducting regular desk and advice and training; and on-site compliance reviews and o issuing instructions, guidelines examinations, focusing on the and recommendations to existence and effectiveness of help DNFBPs comply with AML/CFT policies, procedures, their AML/CFT obligations. operations and manuals;
9 The DNFBP registration and documentation requirements are set out in Section 5 of the MLTPA (DNFBP) Regulations, Statutory Instrument No. 9 of 2014, available on the FIU website.
52 FIU BELIZE ANNUAL REPORT 2020 In accordance with Section 85B of the Registration MLTPA, any person who intends to carry on or is carrying on business as a DN- of DNFBPs FBP must register with the FIU10. Entities that operate as a DNFBP are required to submit an application for registration along with the prescribed application fee to the FIU. Subsequently, each year on the anniversary of the initial registra- tion date, DNFBPs are required to pay an annual fee, and update their regis- tration information where changes have taken place, and where such changes have not previously been notified to the FIU. Each DNFBP is required to update its registration information promptly whenever there is a material change in its ownership or management, or in its circumstances and activities; and the legislation provides for penalties for fail- ure or undue delay in updating the reg- istration information. Once registered with the FIU, DNFBPs remain on the register unless they are de-registered.
Section 7 of the Money Laundering and Terrorism (Prevention) (Des- ignated Non-Financial Businesses and Professions) Regulations 2014, 10 Details of the registration requirements and procedure, including the information that needs to be pro- vided, are set out in the MLTPA (DNFBP) Regulations. See previous footnote.
FIU BELIZE ANNUAL REPORT 2020 53 Statutory Instrument No. 9 of 2014 (“DNFBP Regulations”), states that the Supervisory Authority may refuse an application for registration if:
1-The application does not meet the application requirements set forth in the Regulation 5(3) of the DNFBP Regulations.
2- The applicant fails to provide any information or documents re- quired by the Supervisory Authority.
3- The Supervisory Authority is of the opinion that, in the case of an applicant for registration that is not licensed or regulated, the appli- cant does not, or does not intend to, carry on the relevant business for which it seeks registration.
4- Any of the applicant’s directors, senior officers or owners, or their -as sociates, has committed an offence which constitutes a serious crime.
5- The applicant, having previously been registered under these Reg- ulations, has been de-registered under regulation 8 of the DNFBP Regulations.
54 FIU BELIZE ANNUAL REPORT 2020 During 2020 there were no applica- the end of December 2020, there were tions submitted to the FIU which were six applications on hold for completion refused registration. All complete ap- of initial registration. These applications plications received by the FIU met the that were on hold required the submis- criteria under the regulations to register sion of additional information or docu- as a DNFBP. ments required by the FIU.
When applications for registration are Despite the effects of COVID-19 in 2020, received, each application is vetted to the number of registered DNFBPs con- ensure all the required documents are tinued to increase, as had occurred in submitted and that these documents each year since 2016. There were in- and the directors, shareholders, and the creases of 8% from 2016 to 2017, 6% MLCO satisfy the FIU’s fit and proper from 2017 to 2018, 9% from 2018 to 2019 criteria. To prevent criminals and their and 7% from 2019 to 2020. associates from operating in any of the DNFBP sectors, due diligence checks Figure 5 shows the growth in the num- are conducted on all directors, share- ber of registered DNFBPs between the holders and MLCOs on the application end of 2016 and the end of 2020. The documents to ensure that each person increases reflect an ongoing registra- is fit and proper to operate. Where sub- tion drive on the part of the FIU fol- mitted applications may require addi- lowing a change in the legislation in tional information or documentation, 2014 that broadened the range of in- the applications are placed on hold and stitutions defined as DNFBPs, together the entity is advised via electronic mail with sustained growth in the numbers of the shortcomings of the application of non-profit organisations, real estate so that the requirements may fully be agents, and vehicle dealers since 2015. met within a stipulated timeframe. As at
FIU BELIZE ANNUAL REPORT 2020 55 Figure 5: Number of Registered DNFBPs: Dec 2016 – Dec 2020
2020 1163
2019 1079
2018 987
2017 928
2016 854
At the end of 2020, the FIU recorded At year end, the largest number of reg- a total of 117 new registrations and 33 istered entities in a sector was 319, for de-registrations. These activities result- non-profit organizations. This was- fol ed in a 7% increase with a total of 1163 lowed by businesses operating in a free DNFBPs registered with the FIU. During zone area with 269; real estate agents the year, the FIU reclassified 1 entity that with 184; and vehicle dealers with 170 was originally registered as an audit firm registered entities. These four sectors to an accounting firm, prompting the in- accounted for a total of 942 registra- troduction of a new category of regis- tions, or 81% of registered DNFBPs. tration activity to capture the reclassifi- cation of sectors that registered entities The FIU has noted a continuous increase are assigned. An entity may be reclassi- in the number of registered NPOs and fied for change in business operations real estate agents. or to address input error.
56 FIU BELIZE ANNUAL REPORT 2020 Table 10 below shows the number of DNFBPs registered by sector for the years from 2018 – 2020. Table 10: DNFBP Registration Activity by Sector
REGISTRATIONS 2020 2020 SECTOR 2020 NEW 2018 TOTAL 2020 TOTAL 2019 TOTAL REGISTRATIONS DEREGISTRATIONS RECLASSIFICATION
Casinos 7 7 1 0 0 8
Gambling Houses and Online Gaming 2 22 2 0 0 24
Real Estate Agents 150 171 20 7 0 184
Dealers in Precious Metals and Stones 30 38 3 3 0 38
Non-Profit Organizations 224 267 56 4 0 319
Non-Governmental Organizations 47 48 6 2 0 52
Vehicle Dealers 159 169 15 14 0 170
Other Independent Legal Professionals 4 10 5 0 0 15
Lawyers/Notaries 55 58 2 1 0 59
Accountants 14 17 2 0 +1 19
Auditors 7 6 0 0 -1 6
Businesses Operating in a Free Zone 288 266 5 2 0 269
TOTAL 987 1079 117 33 1 1163
FIU BELIZE ANNUAL REPORT 2020 57 Registered DNFBPs by Geographic Location
With the country’s business capital (Belize City) and the Ambergris main tourist island destinations Corozal Caye of Ambergris Caye and Caye 284 69 Caulker all being located in the Belize District, this District con- J tinued to record the largest Caye number of registered DNFBPs Orange Caulker Walk 9 of all districts in the country, with 67 Belize 479 or 41% of the total number of 401 DNFBPs at the end of 2020.
The second largest number of registered DNFBPs were re- Cayo corded for the Corozal District, 254 accounting for 284 or 24% of the Stann country total. This can be at- Creek tributed to the large number of 47 business entities located in the Corozal Free Zone, accounting for 94% of the Corozal District total. The Cayo District main- Toledo tained the third highest number 32 of DNFBPs with 254 or 22% of the total, while the Orange Walk District accounted for 67 or 6% of the country’s registered DNFBPs. The numbers record- ed for Stann Creek and Toledo were 47 or 4 %, and 32 or 3%, Chart 4: Registered DNFBPs respectively. Chart 4 to the left by Geographical Location shows the distribution of DN- FBPs by District.
58 FIU BELIZE ANNUAL REPORT 2020 Registration Updates
As noted earlier, registered DNFBPs are of DNFBPs were not able or allowed required to update their registration in- to remain operational since the March formation on file with the FIU prompt- 2020 introduction of measures to con- ly (within 14 days) following a material trol the spread of the COVID-19 virus, change in ownership, management, and had difficulty meeting their annual business activities, or in their legal sta- fee payment and updating of informa- tus. The FIU also takes the opportuni- tion requirements. The FIU recognised ty, when annual fees are being paid, to the difficulties and continued to work confirm the accuracy of registration in- with the entities on a case-by-case ba- formation on file. sis to meet these obligations.
At the end of 2020, 593 entities had pro- Figure 6 below shows the number of vided updated registration information registration updates by sector-groups during the year and had paid the annual for 2019 and 2020. There were de- fee. This was a decline from the previ- creases in registration updates in eight ous year’s total of 628. As mentioned sectors during 2020, with the overall de- earlier, COVID-19 affected the opera- clines being heavily influenced by the tional and financial capabilities of many closure of free-zone businesses as part of Belize’s business entities. A number of the COVID-19 containment effort.
Figure 6: Registration Updates by Sector 2019-202011
200 188 178 180 157 160 140 129 120 100 90 92 76 80 70 60 40 42 40 30 27 13 13 13 23 21 20 6 5 8 0 ACCOUNTANTS ATTORNEYS BUSINESSES GAMING DEALERS IN NGOS NPOS OTHER REAL ESTATE VEHICLE & AUDITORS OPERATING IN PRECIOUS INDEPENDENT AGENTS DEALERS A FREE ZONE METALS & STONES LEGAL PROFESSIONALS ■ Registration Updates 2019 ■ Registration Updates 2020
11 Some sectors in the figure have been grouped for presentation, so that all individual DNFBP sectors are not shown.
FIU BELIZE ANNUAL REPORT 2020 59 De-registration Process
New registrations, updating of registration information, and de-registrations are pro- cesses that keep the DNFBP register up-to-date, and help the FIU to identify issues and potential problem-areas in its overall supervision of DNFBPs.
An entity may be de-registered by the FIU for the following reasons:
(a) where the DNFBP ceases its AML/CFT obligations; to conduct business; (iii) the DNFBP or its (b) where the DNFBP ceases business represents a to conduct activities that significant ML/TF risk; qualify it as a DNFBP; (iv) any of the DNFBP’s (c) where the FIU has reasonable directors, senior officers, grounds to believe that: owners or their associates (i) the DNFBP is in have committed a contravention of the serious criminal act; or AML/CFT legislation or (v) it is in the public interest has failed to satisfy any of that the DNFBP be its AML/CFT obligations; de-registered; and (ii) the DNFBP does not (d) where a DNFBP applies have the capacity or to be de-registered for willingness to comply with reason (a) or (b) above.
60 FIU BELIZE ANNUAL REPORT 2020 While the FIU recorded significant in- Over the past three years, entities that creases in the number of de-registra- were deregistered were as a result of tions between 2018 and 2019, the total cessation of businesses. In 2020, busi- decreased in 2020. Since the onset of nesses that were deregistered had the COVID-19 pandemic, the FIU has ceased to operate due to the effects maintained communication with DN- of the COVID-19 pandemic. Of the to- FBPs and has understood that some tal number that were deregistered, 42% entities were experiencing difficulty in were vehicle dealers who advised that meeting their financial and legal obli- they were unable to continue opera- gations. A number of DNFBPs indicated tions due to foreign exchange availabil- that they did not intend to cease busi- ity constraints. The real estate agents’ ness, and would re-start operation when category came next with 21% of the circumstances normalized, and would number of de-registrations, with opera- therefore not wish to be de-registered. tors citing the same constraints as vehi- cle dealers.
Table 11: DNFBP DE-REGISTRATIONS 2018-2020
YEAR NUMBER OF DE-REGISTRATIONS
2018 31
2019 69
2020 33
FIU BELIZE ANNUAL REPORT 2020 61 Section 18 of the MLTPA requires all DNFBPs to appoint an MLCO who is ap- proved by the FIU. Applications for the approval of appointment of MLCOs are scrutinized by the FIU against “fit and proper” criteria, including being subject to a background check, before they are approved by the FIU.
In sole-trader businesses, no applica- Approval of tion is required for the MLCO. The sole trader is deemed to be the MLCO for the Money the business. One of the prescribed functions of the Laundering MLCO is responsibility for oversight of the entity’s AML/CFT compliance pro- Compliance gram. To meet this responsibility, the MLCO should have an appropriate level Officer of seniority within the organization, and possess core competencies and knowl- edge in administering AML measures. Other responsibilities of a reporting en- tity’s MLCO include:
• preparing and maintaining the reporting entity’s manual of AML/ CFT compliance procedures; • receiving and considering internal reports on unusual transactions and suspicious activities; • where appropriate, submitting STRs to the FIU; and • acting as liaison between the reporting entity and the FIU.
62 FIU BELIZE ANNUAL REPORT 2020 With the steady increase in DNFBP reg- in MLCOs in registered DNFBPs. There- istrations, there has been a continuous after, the increase in applications and stream of applications for MLCO ap- approvals reflected a combination of pointments. Table 12 below shows the increases in the number of registered number of annual MLCO approvals in all DNFBPs and changes in MLCOs in enti- sectors of DNFBPs from 2016 to 2020. ties already registered with the FIU.
The number of approved applications In 2020, there were three applications for MLCOs decreased by 34% in 2017 for MLCO that were denied because as the majority of DNFBPs had already the applications were submitted from been registered with the FIU. During entities that were sole proprietorships, 2018 the number of MLCO approvals and the proposed appointees for MLCO increased significantly due to changes were not affiliated with the entities.
Table 12: Number of MLCO Approvals
YEAR TOTAL APPROVED TOTAL DENIED
2016 104 0
2017 69 0
2018 114 0
2019 163 0
2020 151 3
FIU BELIZE ANNUAL REPORT 2020 63 AML/CFT Examinations
The MLTPA requires all DNFBPs to im- be put in place in each entity plement an AML/CFT compliance pro- to establish the bona fides gram. A typical AML/CFT compliance of customers, to understand program should, at minimum, entail the customers’ business, and to following: verify, on an ongoing basis, that customers’ business practices • BUSINESS RISK ASSESSMENT: and transactions do not result each reporting entity should in AML/CFT difficulties for the assess and clearly understand entity. Customer due diligence the ML/ TF risks facing the is an ongoing activity; business and should use that understanding to prepare a • ESTABLISHING SOURCES OF risk management program FUNDS AND SOURCES OF and allocate compliance WEALTH OF CUSTOMERS. resources to mitigate the risks; This would be a specific aspect of customer due diligence; • ESTABLISHING POLICIES AND PROCEDURES: these would • ESTABLISHING AND be part of the risk mitigation UNDERSTANDING THE arrangements and would be COMMERCIAL RATIONALE for specific to the requirements customers’ business, business of each business operation. structures or transactions; Policies and procedures should also be subject to • RISK RATING OF CUSTOMERS: independent review and audit customers should be risk- for effectiveness on a regular rated based on the level of basis, and updated as needed; ML/TF risk they present to the entity. Particular attention • CUSTOMER DUE DILIGENCE: needs to be paid to Politically policies and procedures should Exposed Persons, both
64 FIU BELIZE ANNUAL REPORT 2020 domestic and foreign, and As a result of the national measures to country risk, where cross- implemented to contain the spread of border business transactions the COVID-19 virus, DNFBP compliance are involved. This area requires examinations in 2020 were done on a enhanced due diligence; desk-review basis. The selection of enti- ties for review focused on two high-risk • APPOINTING AN MLCO sectors: vehicle dealers and real estate and facilitating the agents. The FIU conducted a total of 33 activities of the MLCO; desk-based examinations, 19 in the real estate sector and 14 in the vehicle deal- • PROVIDING AML/CFT ers’ group. TRAINING for all staff, including regular refreshers; For examination purposes, entities were chosen using a risk-based approach • MONITORING TRANSACTIONS which took into consideration such fac- AND REVIEWING FILES: tors as estimated income generated, lo- the MLTPA requires cation of the entity, international affilia- ongoing monitoring of all tions, client-base profile of an entity, risk business relationships and profiles of the shareholders and direc- enhanced monitoring in tors of the entity, and the specific type cases of higher risk; of business activities in which the entity was engaged in its sector. • SUBMITTING SUSPICIOUS TRANSACTION REPORTS The desk-based review required enti- to the FIU; and ties to submit specific documentation, which included operational procedures • MAINTAINING RECORDS for a and manuals, staff and customer files, minimum period of five years. financial records, and staff training ma- terial.
FIU BELIZE ANNUAL REPORT 2020 65 The entities reviewed had had no pre- procedure in place to document vious examinations for compliance with and report unusual or suspicious their AML/CFT obligations. The follow- transactions to the MLCO; ing were the general findings: ix) MLCOs were not generally familiar with the need for i) there were no manuals DNFBPs to consult the United containing AML/CFT Nations Security Council policies and procedures, Resolution (UNSCR) Sanctions and little evidence of the List before establishing existence of other aspects business relationships; and of an AML/CFT regime; x) there was no consistent ii) staff members were not monitoring of client transactions. familiar with, or aware of, their obligations under the MLTPA; During and following examination visits, iii) there was no evidence of entities were apprised of the deficien- independent AML/CFT cies identified during the examinations. audits being conducted; Documented feedback reports con- iv) staff were not trained in taining required remedial action, with AML/CFT procedures; timelines for completion, were issued v) in cases where an MLCO was to the entities examined to assist them in place, there was no evidence in meeting the AML/CFT obligations as of a formally approved job set forth in the MLTPA. description for the position; vi) there was minimal evidence The deficiencies noted in these sectors of training offered to MLCOs may be attributed to the small size of in guiding DNFBPs to satisfy most entities in a relatively low-income AML/CFT obligations environment, and to a scarcity of ca- under the MLTPA; pacity to provide the required level of vii) staff members were not instruction and performance support as aware of a STR process; it relates to AML/CFT obligations. viii) there was no process or
66 FIU BELIZE ANNUAL REPORT 2020 Outreach and Awareness
The FIU, with the active participation of on sector-specific indicators of ML and the Compliance Department, contin- TF activities; and on suspicious transac- ued its efforts to deliver on its mandate tions identification, monitoring and re- to conduct outreach and stakeholder porting. A total of seven virtual outreach engagement to increase AML and CFT sessions were conducted in 2020 for awareness in DNFBPs during 2020. Due five DNFBP sectors: casinos and gam- to COVID-19 pandemic-related restric- bling houses, real estate agents, vehicle tions, the FIU hosted virtual outreach dealers, accountants and auditors, and sessions. dealers in precious metals and stones.
To enhance the capacity and effec- FIU staff were pleased with the level of tiveness of outreach activities, the FIU intervention and participation by DNFBP adopted an approach in which the in- staff members in all the outreach- ses formation shared was presented on a sions held during the year. program-basis for each sector, resulting in a series of sessions, with each series effectively customized for each sector. The outreach sessions in 2020 focused
FIU BELIZE ANNUAL REPORT 2020 67 Enforcement
The DNFBP Regulations empower the establishment of AML/ FIU to take disciplinary action against a CFT policies, procedures, DNFBP by imposing an administrative systems and controls; and penalty where it is satisfied that the DN- - failure to satisfy AML/ FBP has violated a legal requirement. CFT obligations. Violations include: In June 2019, the FIU issued a notice of - carrying on a designated intent to take disciplinary action against business activity in an entity for carrying on a designated respect of which it is not business or activity for which it was not registered with the FIU; registered with the FIU. An administra- - late filing or late notification tive penalty was imposed on the entity; of changes to registration this was paid in August 2020. information; - record keeping failures; - deficiencies relating to the
Enhancing Supervisory Activities
The COVID-19 pandemic brought on under the MLTPA, the FIU conducted challenges in conducting supervisory virtual meetings, outreach and exam- activities for DNFBPs. In its efforts to ination interviews. Going forward, con- remain effective in its supervision man- tinuous improvement in meeting AML/ date, the FIU made adjustments to its CFT obligations by DNFBPs will require approach to oversight. In order to assist increased knowledge and capacity DNFBPs in meeting their obligations within the entities.
68 FIU BELIZE ANNUAL REPORT 2020 FIU BELIZE ANNUAL REPORT 2020 69 Investigations and Prosecutions
Under its Act, the FIU is empowered to investigate and prosecute activities related to financial crime, including ML and TF. The methodology for activities in the FIU’s Investigations and Prosecu- tions Department utilizes general and specialized techniques and instruments, which include interviews, searches, documenting declarations of witnesses, as well as obtaining and documenting evidence for use in Court proceedings.
The Investigations and Prosecutions Department consists of five Investi- gators and a legal officer who use ad- vanced strategies and procedures to in- vestigate ML and TF. The key task of FIU investigators and the legal officer is to obtain information relating to alleged fi- nancial crime; prepare case files for use in the prosecution of persons charged for financial crimes; and to prosecute criminally, where possible, those who may be involved in violating the FIU Act, the MLTPA, or the Criminal Code. In ad- dition, the use of new technologies and
70 FIU BELIZE ANNUAL REPORT 2020 regional coordination between law en- forcement agencies now enable a wide range of intelligence activities includ- ing witness testimony being promptly collected, processed, and cross-refer- enced for use in prosecutions. Further- more, investigators can utilize a range of judicial orders for the collection and processing of information, the intercep- tion and monitoring of communications, and for the seizure and recovery of as- sets, as necessary.
During 2020, 17 cases of financial crimes were investigated, of which 12 were in- vestigated with the collaboration of members of the FCWG, while the oth- ers were investigated by the BPD and by the FIU. Some of the cases involved more than one suspected offence. Sev- en of the 17 cases were closed, six cas- es were before the Court at year-end, and the remainder were still under in- vestigation. The FIU also assisted with nine Mutual Legal Assistance Treaty requests from other jurisdictions; one cash seizure case; two applications for cash detention at the Magistrate’s Court; and a total of 40 requests for assistance from other agencies, including the BPD, the Joint Intelligence Coordination Cen- ter, and the Belize office of the Interna- tional Criminal Police Organization.
FIU BELIZE ANNUAL REPORT 2020 71 Table 13: Cases Investigated during 2020 (without FCWG participation) NO. AGENCY OFFENCE OFFENCE INVOLVED INVOLVED INVOLVED SUSPECTED CASH VALUE VALUE CASH OF PERSONS OF CASE STATUS STATUS CASE NATIONALITY INVESTIGATING
1. FIU Belizean Fraud N/A BZD 50,000.00 Under Investigation
2. FIU Belizean Money N/A N/A Under Laundering, Investigation Theft
3. FIU 1 Canadian Obtaining N/A BZD 10,325.00 Under and 2 Property by Investigation Americans Deception, Theft
4. FIU/ Belizean Money N/A BZD 91,639.58 Under BPD Laundering, Investigation Fraud, Theft
5. FIU/ Belizeans Money N/A BZD 27,960.00 Closed BPD Laundering No charges instituted
Section 38 of the MLTPA authorizes below (“Source of Funds Queries/Cash the seizure of cash by Customs or Seizures”) shows three instances where Police officers where officers have cash was seized. One of the cases was reasonable grounds to suspect that the closed without charges being laid, as the cash represents the proceeds of crime persons involved were able to establish as defined in that Section. Table 14 the legitimacy of the source of funds.
72 FIU BELIZE ANNUAL REPORT 2020 Table 14: Source of Funds Queries/Cash Seizures NO. AGENCY INVOLVED INVOLVED LOCATION LOCATION CASH VALUE VALUE CASH OF PERSONS OF CASE STATUS STATUS CASE NATIONALITY NATIONALITY INVESTIGATING INVESTIGATING
1. FIU/ Belizean Belize City BZD 23,714.00 Open BPD USD 1,063.00 Source of funds to be established.
2. FIU/ Belizean Belize City BZD 6,175.00 Open BPD USD 143.00 Source of funds to be established.
3. FIU/ Belizean Belmopan City BZD 27,960.00 Closed BTSD Source of Funds established, however BTSD confiscated BZD 13,980.00.
FINANCIAL CRIMES WORKING GROUP
In 2017, NAMLC created the Finan- tionality Services; and the IFSC. The cial Crimes Working Group (FCWG). group is chaired by a member of the The FCWG comprises several NAM- BPD, with the Senior Investigator in the LC member agencies including: the FIU serving as Deputy Chairperson. The BPD; the FIU; the Office of the Director FCWG-coordinated objectives include of Public Prosecutions; the BTSD; the pursuing ML and related predicate of- Customs and Excise Department; the fence cases, recovering the proceeds Department of Immigration and Na- of crime, sharing learned experiences
FIU BELIZE ANNUAL REPORT 2020 73 from case development, and improving the ML matter was still under investiga- the operational capacity of members. tion at year-end. Five of the cases re- During 2020, the FCWG met only twice, main under investigation. Of the six cas- partly due to COVID-19 considerations. es that were closed, five were before Of the twelve cases that were brought the Court for trial. See Appendix 1 for over from 2019, six were closed during further information on the cases investi- the year, and one partially closed as gated with the assistance of the FCWG. charges were instituted for theft, whilst
Chart 5 below shows the types of alleged offences that resulted in investigative action being taken by the FIU in coordination with other law enforcement agencies.
Chart 5: Types of Alleged Offences Investigated in 2020
Money Laundering - 14
Carrying on Moneylending - 1 Suppression of Documents - 1 Concealment of Documents - 1
Failure to Disclose - 1
Failure to Assist - 1 Obstruction - 1 Theft - 10
Fraud - 4
Obtaining Property Uttering a False Document - 4 by Deception - 7
74 FIU BELIZE ANNUAL REPORT 2020 INTERCEPTION OF COMMUNICATION ORDER
An Order issued by the Supreme Court, Investigative requiring communication service pro- viders to intercept and retain specified TOOLS communications or communications of a specified description, received or transmitted, and to further allow the Police or the FIU to enter the providers’ PRODUCTION ORDER premises to install devices to intercept and retain specified communications or An Order issued by the Supreme Court, communications of a specified descrip- requiring the production of documents, tion related to ML/TF investigations. devices or information that may assist the Police or an authorized officer of the FREEZING ORDER FIU in investigations in relation to sus- pected ML/TF offences. An administrative order issued by the FIU to any reporting entity to freeze for MONITORING ORDER seven business days funds or other fi- nancial assets or economic resources An Order issued by the Supreme Court, of any person or entity, to facilitate any directing a reporting entity to provide investigation, prosecution or proceed- the Police or the FIU with information ings for ML/TF offences. An application for a specified period of time regard- must be made to the Supreme Court for ing transactions conducted through authorization to extend a freezing order accounts held by a particular person beyond seven business days. who is reasonably suspected to have committed, is about to commit, or was involved in, or has benefited or is about to benefit directly or indirectly from the commission of, an offence.
FIU BELIZE ANNUAL REPORT 2020 75 Domestic and International Cooperation
In the global fight against ML/TF, coor- throughout the year, in accordance dination and cooperation at the national, with the provisions of both the MLTPA regional and international levels are crit- and the FIU Act. The FIU worked col- ical, given the ease with which people lectively with other local law enforce- and financial resources can cross - bor ment authorities as part of the intelli- ders. In order to strengthen and sup- gence-sharing process and other forms port this partnership Belize continued of cooperation, with mutual support its collaboration and coordination with being provided both formally and infor- domestic and international institutions mally.
Chart 6: Requests for Information
94 International 94 International 64 International 78 International
2017 2018 2019 2020
16 Domestic 17 Domestic 16 Domestic 24 Domestic
During 2020, a total of 105 Requests for the remaining 78 were from foreign Information (RFIs) were received by the FIUs and law enforcement agencies FIU, a substantial increase compared (see Appendix 2). .Assistance was pro- with the 80 that were received in 2019. vided in cases involving theft, obtaining Of the 105 RFIs received, 24 came from property by deception, and in respect of local law enforcement agencies, while other serious predicate offences.
Information Requests by Suspected Activity
Continuing the trend of the two previ- sion following in order of interest. Other ous years, the majority of incoming in- RFIs arose out of unspecified STRs and formation requests involved suspected ongoing financial investigations. ML, with suspected fraud and tax eva-
76 FIU BELIZE ANNUAL REPORT 2020 Table 15: RFIs by Suspected Activity 2018 - 2020 International RFIs
CLASSIFICATION 2018 2019 2020
Bribery 3 0 0
Corruption 2 0 0
Due Diligence 8 0 0
Drug Trafficking 4 3 1
Embezzlement 6 0 0
Fraud 24 12 22
Financial Investigation 0 0 6
Money Laundering 32 29 35
Murder 1 0 0
Sex Crime 0 1 0
Suspicious Transaction Reports 0 0 15
Tax Evasion 11 2 11
Terrorist Financing 0 3 1
Theft 15 1 1
Other 5 7 2
TOTAL 111 58 94
FIU BELIZE ANNUAL REPORT 2020 77 Chart 7 - Countries Requesting Information in 2020
Belarus - 5
Bulgaria - 3 Germany - 2 Others - 18
Israel - 2
Latvia - 3
USA - 9 Lithuania - 4
Lichtenstein - 2
Malta - 4 United Poland - 2 Kingdom - 3
Spain - 2 Ukraine - 7
Russia - 11 Switzerland - 4
78 FIU BELIZE ANNUAL REPORT 2020 information sharing and to ensure that planned outreach sessions were deliv- ered as programmed, and for assessing Presentations, the performance of supervised institu- tions, given that the new information de- Training and livery mechanisms also provided new opportunities for criminal activity. Spe- Meetings cial emphasis had to be placed on ways in which the organization could capture The impact of the COVID-19 pandem- and hold the attention of its online par- ic on Belize and the global community ticipants, particularly persons working resulted in an increase in virtual train- from home. ing and meeting sessions throughout 2020. Given the continuing impact of Table 18 below lists presentations, train- the pandemic throughout 2020 it was ing sessions and other financial systems expected at year-end that the use of development activity in Belize which the online facilities for meetings and train- FIU either led or participated in, along ing sessions would continue into 2021. with the other AML/CFT supervisory or The requirements for online interaction law enforcement agencies, or with pri- encouraged staff members to devel- vate sector interests. op new skills and techniques, both for
FIU BELIZE ANNUAL REPORT 2020 79 Table 16: Workshops and Presentations in Belize Involving the FIU - 2020
WORKSHOPS/ ORGANISERS/ DATE PRESENTATIONS MAIN PARTICIPANTS FACILITATORS
January Anti-Money Laundering FIU/Private & Public National Bank of Compliance Workshop Sector Entities Belize Limited, and Seminar Belize American Chamber of Commerce
February Time Management Analysts/ Belize Chamber Training Compliance Officers/ of Commerce Administrative Staff & Industry
Overseas Training
As a direct result of the COVID-19 pan- sible supervision gaps, but also to im- demic, many programs had to be can- prove the operational efficiency and -ef celed or postponed which resulted in fectiveness of the institutions to which only one staff member travelling over- participants were attached. Table 19 seas to participate in a regional training below describes the overseas pro- session. Participation in this training ses- gramme in which the FIU staff member sion was not only intended, through the participated during the year. development of develop participants’ skills, to reduce regulatory risks through enhancing the capacity to identify pos-
80 FIU BELIZE ANNUAL REPORT 2020 Table 17: Overseas Training Workshop Attended by FIU Staff - 2020
ORGANISERS/ DATE WORKSHOP PARTICIPANT FACILITATORS
February Mutual Evaluation NRA Coordinator CFATF 10th -12th Pre-Onsite Training
NRA Coordinator Sharlene Jones (second from right) participating in a Mutual Evaluation Pre-Onsite Training at the CFATF Secretariat, Port of Spain, Trinidad and Tobago.
Virtual Overseas Training As indicated in the preceding paragraph, intended to develop staff members’ the COVID-19 restrictions prevented skills but also to keep them apprised of overseas travel after March 2020, so developments in ML and other criminal that FIU staff members’ participation practices and typologies. in workshops and training sessions in- volving cross-border presentations or Table 20 below lists the virtual overseas participants were all virtual. Participation programmes in which FIU staff mem- in these training sessions was not only bers participated during the year.
FIU BELIZE ANNUAL REPORT 2020 81 Table 18: Training Workshops with FIU Staff Participation - 2020
WORKSHOPS/ ORGANISERS/ DATE SEMINARS MAIN PARTICIPANTS FACILITATORS
February Cryptocurrencies Compliance Officers United Nations Office on Drugs and Crime (UNODC) Global E-Learning
March Technical Working Deputy Director US Embassy Group – Caribbean Basin Security Initiative
May Money Laundering Compliance Officers/ UNODC Global Havens Research Assistant E-Learning
June The Financial Investigator Egmont Group/ Investigations in The Egmont Wildlife and Forestry Centre of FIU Crime E-Workshops Excellence and Leadership (ECOFEL)
International Legal Compliance Officers UNODC Global Framework Against E-Learning Chemical, Biological, Radiological and Nuclear Terrorism
Cyber Security Webinar Network Administrator Belize Chamber of Commerce and Industry/ Adams Consulting
Webinar on “REGTECH Deputy Director/NRA Promontory/ and SUPTECH as Coordinator/Strategic Florida CO-CREATORS: Consultant/Office Manager/ International Practical Use Cases Quality Assurance Officer/ Banker’s for Regulators” Analysts/Compliance Officers Association Innovation Committee
82 FIU BELIZE ANNUAL REPORT 2020 July The Role of the FIUs NRA Coordinator/Analysts ECOFEL/Egmont in National ML/TF Group of FIUs Risk Assessments: Lessons Learned
COVID-19 Best Analysts/Compliance Officers ECOFEL/Egmont Practices for FIUs Group of FIUs
Illegal Wildlife Trade NRA Coordinator/ Investigator/ ECOFEL/Egmont as a Financial Crime Analysts/Compliance Officers Group of FIUs
North and Central Investigator/Analysts/ US Department Americas Region Research Assistant of Justice Money Laundering 101 Workshop
Webinar “FinTech” Deputy Director/ Egmont Group with a Focus on NRA Coordinator of FIUs Virtual Assets, Virtual Assets Service Providers & Mobile Payment Services
Democratic People’s Deputy Director/NRA US Department of Republic of Korea Coordinator/ Strategic Treasury/Internal Cyber Hack and Consultant/Office Manager/ Revenue Service Cryptocurrency Case Quality Assurance Officer/ Study Webinar Investigator/Analysts/ Compliance Officers/ Research Assistant
August Virtual Regional Deputy Director/NRA CARICOM Training – Trade Based Coordinator/Legal Advisor/ IMPACS/UNODC/ Money Laundering Investigator/Analysts/ Caribbean Basin Compliance Officers/ Security Initiative Research Assistant Connect
New Psycho-active Investigator CARICOM Substances, Synthetic IMPACS/UNODC/ Opioids, Precursors Caribbean Basin and Dangerous Security Initiative Substances Awareness, Connect Safe Interdiction and Intelligence Sharing
FIU BELIZE ANNUAL REPORT 2020 83 September Regional Webinar Legal Advisor/Investigator UNODC/ on Integrity, Ethics World Customs and Accountability in Organization/ Law Enforcement Intenational Criminal Police Organization Airport Communication Project
October Drug Enforcement Investigator US Embassy Agency Training
11th European Deputy Director/Legal Advisor/ CARICOM IMPACS Development Analyst/Investigator Fund - Regional Asset Recovery in Practice Workshop
Asset Recovery Legal Advisor/Investigator CFATF/Regional Workshop Security System- Asset Recovery Unit/ US Department of Treasury – Office of Technical Assistance
Anti-Money Director/Investigator/Analysts/ UNODC Regional Laundering Day Compliance Officers Office in Panama
November Supervision Project Director/Deputy Director/ CFATF/ – Strengthening NRA Coordinator/ Strategic Government Supervisory Systems Consultant/Office Manager/ of Canada and – AML/CFT Training Analysts/Compliance Officers/ United Kingdom Program Structure Research Assistant
December Legal, Regulatory Deputy Director/Investigator/ CARICOM- and Administrative Legal Advisor UNSCR 1540 Measures relevant to Programme and UNSCR 1540 & Article the Government III of the Biological of Belize Weapons Convention
84 FIU BELIZE ANNUAL REPORT 2020 Virtual Overseas Conferences and Meetings
Staff members of the FIU also partici- were organised from outside of Belize pated in virtual overseas conferences which were attended virtually by staff and meetings during 2020. Table 21 members. lists the meetings and conferences that
Table 19: Meetings and Conferences with FIU Staff Participation - 2020
NATURE OF CONFERENCE DATE FIU PARTICIPANTS OR MEETING ORGANISERS
March Director CARICOM – The Bankers CARICOM Association of Finance and Trade Respondents’ Playbook Training Session
Analyst/Senior Banking Sector Compliance Central Bank Compliance Officer Officers Meeting of Belize
July Director/Deputy Director Egmont Group Plenary Egmont Group Heads of FIUs of FIUs
NRA Coordinator Egmont’s IEWG Working Egmont Group Group Virtual Meeting of FIUs
Deputy Director/Senior 2nd Governance Summit Belize Association Compliance Officer on Improving Data of Planners Ecosystems for Governance and Decision Making
Investigator CARICOM IMPACS Virtual CARICOM IMPACS Security Conference 2020 Securing our Community within the Era of COVID-19 and Beyond
FIU BELIZE ANNUAL REPORT 2020 85 September Deputy Director Virtual Financial Crimes US Department TWG Conference of State’s Bureau of International Narcotics and Law Enforcement Affairs/CARICOM IMPACS
October Director/Deputy Director CFATF XII Council of CFATF Ministers Meeting
Director/Deputy Director 32nd Meeting of CARICOM CARICOM Standing Committees of Regional Intelligence Heads and FIUs
November NRA Coordinator/In- 4th Global Conference International vestigator/Analysts on Criminal Finances Criminal Police & Cryptocurrencies Organization/ European Union’s Law Enforce- ment Agency/ BASEL Institute of Governance
Director/Deputy Director Heads of CFATF FIUs Forum CFATF
December Director/Deputy Direc- CFATF LI Plenary & Work- CFATF tor/NRA Coordinator/ ing Group Meetings Strategic Consultant/ Legal Advisor/Senior Compliance Officer
86 FIU BELIZE ANNUAL REPORT 2020 Appendices
FIU BELIZE ANNUAL REPORT 2020 87 APPENDIX 1: Cases investigated with the assistance of the FCWG12 NO. VALUE VALUE AGENCY OFFENCE OFFENCE CHARGED INVOLVED INVOLVED SUSPECTED SUSPECTED SUSPECTED/ CASE STATUS STATUS CASE APPROXIMATE APPROXIMATE INVESTIGATING INVESTIGATING
1.* FIU Theft, money N/A BZD Open. Under laundering 1,731,000.00 Investigation
2.* FIU Obtaining proper- N/A BZD Open. Under ty by deception, 119,000.00 Investigation theft, money laundering
3.* FIU Uttering a false Uttering a false BZD Closed. document, theft document, 8,000.00 Matter before and obtaining theft and ob- the Court property by taining property deception by deception
4.* FIU Obtaining prop- Obtaining prop- USD Closed. erty by decep- erty by decep- 289,000.00 Matter before tion, uttering a tion, uttering a the Court. false document, false document theft, money and obtaining a laundering money transfer by deception
5.* FIU Obtaining prop- N/A USD Open. Under erty by decep- 552,000.00 Investigation tion, uttering a false document, theft, money laundering
12 Cases marked with an asterisk were brought over from 2019.
88 FIU BELIZE ANNUAL REPORT 2020 6.* FIU/ Theft, money Theft BZD Partially BPD laundering 85,000.00 closed. Theft matter before the Court. The money laundering matter still under in- vestigation.
7.* FIU Money laun- N/A N/A Open. Under dering Investigation
8.* FIU/ Theft, fraud, N/A BZD Closed BPD money laun- 189,000.00 No charges dering instituted
9.* BPD Theft, money N/A BZD Closed. laundering 54,000.00 Theft matter before the Court. Await- ing money laundering charges.
10.* FIU/ Carrying on Carrying on USD Closed. BPD moneylend- moneylending 74,500.00 Matter before ing business in business in MXN the Court. Belize without Belize without 1,698,500 holding a valid holding a valid Moneylenders Moneylend- license granted ers license by the Registrar granted by the of Moneylenders Registrar of Moneylenders
11.* FIU/ Theft, money N/A BZD Open. Under BPD laundering 498,000.00 Investigation
FIU BELIZE ANNUAL REPORT 2020 89 12.* FIU Suppression of Suppression N/A Closed. documents, con- of documents, Matter before cealment of doc- concealment the Court. uments, failure to of documents, disclose, failure failure to dis- to assist, obstruc- close, fail- tion, giving false ure to assist, information. obstruction, giving false information.
90 FIU BELIZE ANNUAL REPORT 2020 Appendix 2: Number of RFIs by Country 2018 - 2020
NO. COUNTRY 2018 2019 2020
1 Albania 3 0 0
2 Argentina 0 1 0
3 Armenia 0 0 1
4 Aruba 1 0 0
5 Austria 0 0 1
6 Belarus 0 0 5
7 Belgium 0 1 0
8 Brazil 2 0 0
9 British Virgin Islands 0 0 1
10 Bulgaria 1 0 3
11 Canada 4 0 0
12 Cayman Islands 3 0 1
13 China 0 2 0
14 Croatia 0 3 0
15 Denmark 1 0 1
16 Ecuador 3 0 0
17 France 2 1 0
18 Gabon 0 1 0
19 Germany 0 5 2
20 Ghana 0 1 0
FIU BELIZE ANNUAL REPORT 2020 91 21 Greece 1 0 1
22 Guyana 0 0 1
23 Hungary 2 0 1
24 India 1 1 0
25 Isle of Man 0 0 1
26 Israel 0 1 2
27 Italy 1 0 0
28 Japan 0 1 0
29 Jersey 1 0 0
30 Kazakhstan 1 1 0
31 Kyrgyz Republic 0 2 1
32 Latvia 0 2 3
33 Liechtenstein 0 0 2
34 Lithuania 2 2 4
35 Macedonia 1 2 1
36 Malta 2 3 4
37 Moldova 0 0 1
38 Monaco 1 3 0
39 Mongolia 0 1 1
40 Montenegro 2 0 0
41 Namibia 0 0 1
42 Netherlands 0 1 0
43 New Zealand 0 1 0
92 FIU BELIZE ANNUAL REPORT 2020 44 Palestine 0 0 1
45 Panama 5 1 0
46 Paraguay 1 0 0
47 Phillipines 0 0 1
48 Poland 0 1 2
49 Romania 1 1 0
50 Russia 5 7 11
51 San Marino 1 0 1
52 Senegal 0 1 0
53 Serbia 1 1 0
54 Seychelles 1 0 0
55 Slovakia 1 0 0
56 Spain 0 1 2
57 Sri Lanka 0 0 1
58 St. Vincent and the Grenadines 1 0 0
59 Switzerland 2 0 4
60 Tajikistan 1 0 0
61 Turkmenistan 0 1 0
62 Ukraine 6 0 7
63 United Kingdom 9 3 3
64 United States of America 18 11 9
65 Venezuela 1 0 0
TOTAL 94 64 81
FIU BELIZE ANNUAL REPORT 2020 93 Enquiries related to this report should be addressed to:
THE DIRECTOR Financial Intelligence Unit - Belize
4998 Coney Drive Business Plaza Coney Drive P.O. Box 2197 Belize City, Belize +(501) 223-2729 / 223-0596 +(501) 223-2531 [email protected] www.fiubelize.org
94 FIU BELIZE ANNUAL REPORT 2020 FIU BELIZE ANNUAL REPORT 2020 95 2020 fiu.belize@fiubelize.org www.fiubelize.org
96 FIU BELIZE ANNUAL REPORT 2020