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Combating Money Laundering: the joint IADB/OAS program to develop Financial Intelligence Units |
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by Rafael Franzini Batlle, Chief, Anti-Money Laundering Unit, CICAD/OEA |
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and PDF version The Financial Intelligence Units are agencies that within the juridical administrative system of their country, have as a mission to analyze financial operations and discover any money laundering operations. The type of operations that they act upon are determined by the law in each country but, in general, these are catalogued as suspicious or involving large quantities of money. The financial institutions, and in some cases certain professionals, that receive notice of a suspicious operation due to an inconsistency of a client’s profile or another reason such as lack of economic or legal base, are required by law to send these operations to the FIU. The same must be done when their clients carry out operations over a certain pre-established limit, generally when it is higher than $10,000. The FIU analyzes, crosses data, applies information and if it considers that it is facing a money laundering operation, communicates its findings to the authority in charge of investigating these crimes. This process may appear simple by its description, but it is not. The FIUs need to build data bases full of information; possess specialized information technology programs and equipment; and specialized accountants, lawyers, analysts and financial technicians. In summary, they must have the structure to handle data which at times is received in an unsophisticated manner. FIUs are organizations that are extremely sophisticated and multidisciplinary. Information: the Most Valuable Ingredient The primary ingredient of the FIU is information. Without information, a FIU would not exist. Banks, exchange houses, notaries, casinos and art galleries among others, are establishments that could potentially be used to launder money and which represent the primary providers of the information required to make the FIU thrive. Since money laundering is a crime with a transnational characteristic, just like the crimes that precede it, the information provided by other states is also vital. In 1995, when only a few FIUs existed, the Egmont Group was created to facilitate the access to international information and promote the exchange of information among FIUs. This inter-governmental organization has over 50 operating units and has established a network through which they can exchange information using encryption. The work of the Units is not easy. An adequate legal framework which permits access to information, sophisticated equipment capable of processing it and highly trained specialists to interpret it, are the conditions required to be able to carry out its functions. These three areas are the principal objectives of the program being implemented by OAS/CICAD and the IADB. For a period of two years, efforts will be directed at improving these three elements as agreed with the participating countries. |