The Financial Intelligence Units of the Egmont Group, exchange information worldwide to track terrorist financing and fight crimes like money laundering. Their exchange of information occurs pursuant to the Egmont Group’s Principles for Information Exchange (June 2001) and Best Practices for the Exchange of Information (updated June 2004). Sometimes Financial Intelligence Units (“FIU’s”) share information from a suspicious activity or suspicious transaction report filed by a bank or other entity. This can happen especially because FIU’s are the repository of the suspicious activity/transaction reports filed in their respective jurisdictions.
As the World Bank’s 2004 report “Financial Intelligence Units: An Overview” mentions, various jurisdictions define suspicious activity differently. In the United States however, there are extensive rules about filing a Suspicious Activity Report. Banks in the United States for example, are required by both 31U.S.C. §5318 (g) and 31 C.F.R Part 103.18 to file a Suspicious Activity Report with the FIU known as the Financial Crimes Enforcement Network. As 31 C.F.R. Part 103.18 explains, a bank is generally required to file a Suspicious Activity Report within thirty days of a transaction which amounts to at least $5000 and: involves funds derived from crime; or disguises criminal activity; or evades reporting requirements; or has no apparent lawful purpose. According to Guidance on Preparing A Complete & Sufficient Suspicious Activity Report Narrative, remembering the five “W’s”, (i.e. who, what, where, when, & why), is particularly helpful when supplying information in a Suspicious Activity Report to a FIU.
FIU’s also study the methods used to launder money and then develop laundering “typologies” about them. One such typology, Egmont Group Case Ref: 06058, shows how information about two suspicious trusts collected by the FIU of one country was passed on as a tip to a different country. Yet another typology, Egmont Group Case Ref: 06063, demonstrates how a FIU analyzed wire transfers from Europe in order to spot two suspected members of a terrorist group involved in the 9/11 tragedy. Finally, FIU typologies are used by law enforcement and regulators to track emerging criminal trends and develop countermeasures to financial crimes like money laundering.
(Edited January 8, 2010)
Copyright 2007 Fred L. Abrams