AML/CFT Pre-Conference Training 2007: Enhancing International Cooperation on Money Laundering and Terrorism Financing

1. AML/CFT PRE CONFERENCE TRAINING2007 CAIB AGM Calvin E J Wilson Executive Director Caribbean Financial Action Task Force

2. INTERNATIONAL COOPERATION ON ML/FT • MEMBER STATES AGREED TO JOIN WITH THE INTERNATIONAL COMMUNITY TO FIGHT THE TWIN EVILS OF MONEY LAUNDERING AND THE FINANCING OF TERRORISM. • BIRTH OF THE CARIBBEAN FINANCIAL ACTION TASK FORCE • THE MUTUAL EVALUATION PROGRAMME

3. AML/CFT BEAUTY PAGEANT • THE MUTUAL EVALUATION PROGRAMME AND THE END RESULT THE MUTUAL EVALUATION REPORT COULD BE DESCRIBED AS A • BEAUTY PAGEANT WHERE COUNTRIES IN THEIR OWN BEST INTERESTS SHOULD PUT THEIR BEST FOOT FORWARD • SOLID PARTNERS IN THE GLOBAL BATTLE AGAINST TRANS NATIONAL ORGANISED CRIME

4. THE MUTUAL EVALUATION PROGRAMME IS A CRUCIAL ASPECT OF THE WORK OF THE CFATF AS IT IS ONE OF THE MECHANISMS BY WHICH THE SECRETARIAT ENSURES THAT EACH MEMBER STATE FULFILS THE OBLIGATIONS UNDERTAKEN. THROUGH THIS MONITORING MECHANISM THE WIDER MEMBERSHIP IS KEPT INFORMED AS TO WHAT IS HAPPENING ON THE GROUND IN EACH MEMBER COUNTRY THAT HAS SIGNED THE MEMORANDUM OF UNDERSTANDING. THE MUTUAL EVALUATION PROGRAMME

5. THE MUTUAL EVALUATION PROGRAMME • FOR THE INDIVIDUAL MEMBER, THE MUTUAL EVALUATION PROGRAMME PRESENTS A VALUABLE OPPORTUNITY FOR AN OBJECTIVE ASSESSMENT BY A TEAM OF EXPERTS OF THE ANTI MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM FRAMEWORK AS IT EXISTS AT THE TIME OF THE VISIT. • THE PROGRAMME SEEKS TO GIVE DUE RECOGNITION WHERE THE STANDARD BENCHMARKS ARE MET, BUT WITH A VIEW TO SECURING IMPROVEMENTS WHERE NECESSARY, IDENTIFIES WEAKNESSES WHICH HAVE BEEN DETECTED AND MAKE RECOMMENDATIONS WHERE THEY ARE FOUND TO EXIST.

6. THE MUTUAL EVALUATION PROCESS • A MISSION TO EACH OF THE MEMBER COUNTRIES BY A TEAM OF EXPERTS, ONE OR MORE IN THE FIELD OF LAW, FINANCE AND LAW ENFORCEMENT • LED BY THE EXECUTIVE DIRECTOR, DEPUTY EXECUTIVE DIRECTOR, ONE OF THE EXPERT ADVISORS AT THE SECRETARIAT, • OR OTHER SUITABLY QUALIFIED AND EXPERIENCED EXAMINERS WHO FOR THESE PURPOSES WILL BE CONSIDERED A MEMBER OF THE SECRETARIAT.

7. THE MUTUAL EVALUATION PROCESS • THROUGH A RANGE OF INTERVIEWS WITH OFFICIALS IN BOTH THE PRIVATE AND PUBLIC SECTORS, THE TEAM ATTEMPTS TO GLEAN A PRECISE PICTURE OF THE COUNTRY’S ANTI MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM FRAMEWORK . • MONITORING COMPLIANCE WITH THE FATF 40 RECOMMENDATIONS AND THE NINE SPECIAL RECOMMENDATIONS AGAINST THE FINANCING OF TERRORISM

8. THE MUTUAL EVALUATION PROCESS • CRUCIAL TO THIS UNDERTAKING IS THE NEED FOR A NATIONAL AGENCY WITHIN THE MEMBER STATE, HEADED BY A CO-ORDINATOR, WHO COULD BE A LEGAL OFFICER WITH NO MINISTERIAL RESPONSIBILITY, WHO WILL BE RESPONSIBLE FOR THE CO-ORDINATION OF THE MUTUAL EVALUATION PROCESS. • IT IS NECESSARY FOR ALL GOVERNMENT DEPARTMENTS AND AGENCIES AS WELL AS THOSE PRIVATE SECTOR ORGANISATIONS THAT WILL BE CALLED UPON TO PARTICIPATE IN THE EVALUATION TO INFORM ALL RELATED OFFICIALS OF THE NATURE, RATIONALE AND IMPORTANCE OF THE EXERCISE.

9. THE MUTUAL EVALUATION PROCESS • THE NATIONAL ANTI MONEY LAUNDERING COMMITTEE. • BUILDING RELATIONSHIPS BETWEEN ALL NATIONAL STAKEHOLDERS • SERVING THE BEST INTERSTS OF THE NATION

10. THE NATIONAL ANTI MONEY LAUNDERING COMMITTEE • THE AML/CFT METHODOLOGY, THE TOOL BY WHICH AML/CFT REGIMES ARE ASSESSDED FOR COMPLIANCE. • COMPLEX AND INTRICATE • THE EVOLVING OPINIONS ON THE ESSENTIAL CRITERIA AGAINST WHICH THE RECOMMENDATIONS ARE RATED. • THE EXTENT AND NATURE OF THE SUPPORTING ANALYTICAL DATA TO BE INCLUDED IN THE REPORT

11. THE NATIONAL ANTI MONEY LAUNDERING COMMITTEE • THE THRUST OF THE CURRENT ROUND OF ASSESSMENTS GLOBALLY IS EFFECTIVE IMPLEMENTATION. • UNCERTAINTY AS TO HOW THIS IMPORTANT FACTOR IS TO BE ADDRESSED. • CURRENT WORK OF THE FATF WORKING GROUP TO DEVISE GUIDELINES FOR ASSESSORS IN THIS AREA.

12. THE NATIONAL ANTI MONEY LAUNDERING COMMITTEE • CRTICAL TO THE EFEECTIVENESS CONSIDERATIONS IS THE COLLATING OF STATISTICS ON THE OPERATION OF THE AML/CFT SYSTEM. • COUNTRIES SHOULD DEVISE A NATIONAL PLAN TO COLLATE STATISTICS BY ALL MEMBERS OF THE DOMESTIC AML/CFT COMMUNITY. • EMBARKING ON SUCH AN EXERCISE IS A MAJOR UNDERTAKING AND RESOURCE INTENSIVE. • FEW COUNTRIES HAVE MOVED IN THIS DIRECTION.

13. THE NATIONAL ANTI MONEY LAUNDERING COMMITTEE • ASSESSING EFFECTIVENESS AND ASSIGNING RATINGS TO THE RECOMMENDATIONS IS PROVING TO BE QUITE A CHALLENGE FOR EXAMINERS GLOBALLY. • THIS IS REFLECTED IN PROTRACTED AND INTENSE PLENARY DISCUSSIONS ON THE REPORTS. • SOME AREAS OF CONTENTION • POLITICALLY EXPOSED PERSONS • THIRD PARTY INTRODUCERS • CRIMINALISING ALL THE AREAS COVERED BY THE FATF LIST OF PREDICATE OFFENCES

14. THE NATIONAL ANTI MONEY LAUNDERING COMMITTEE • THE ONUS IS ON THE COUNTRY TO BE EXAMINED TO DEMOSTRATE THE NATURE AND EFFECTIVENESS OF ITS AML/CFT INFRASTRUCTURE. • A MAJOR DIFFICULTY HERE IS COMPLETING THE MUTUAL EVALUATION QUESTIONNAIRE • RECENT CFATF TRAINING SEMINAR FOR COUNTRIES THAT ARE BEING ASSESSED 2007/EARLY 2008 . • THIS INITIATIVE WILL HAVE TO BE INSTITUTIONALISED

15. THE NATIONAL ANTI MONEY LAUNDERING COMMITTEE • COUNTRIES ARE NOW ALLOWED TO IMPLEMENT THE FATF RECOMMENDATIONS DEPENDING ON THE LEVEL OF RISKS IN ANY GIVEN AREA. • COUNTRIES MUST BE ABLE TO OUTLINE HOW THIS DETERMINATION WAS MADE. • VERY FEW COUNTRIES HAVE EMBARKED UPON THE ASSESSMENT OF AML/CFT RISKS AT A NATIONAL LEVEL. • FSRBS SHOULD ARRANGE TECHNICAL ASSISTANCE AND TRAINING FOR THOSE COUNTRIES WHICH NEED ASSISTANCE

16. THE NATIONAL ANTI MONEY LAUNDERING COMMITTEE • PLACING TERRORIST FINANCING LEGISLATION ON THE STATUTE BOOKS. • THE INTRODUCTION OF SUPERVISORY REGIMES FOR DESIGNATED NON FINANCIAL BUSINESSES AND PROFESSIONS. • THE ALLOCATION OF ADEQUATE RESOURCES TO ALL AML/CFT STAKEHOLDERS AND PROVIDING TRAINING ON AN ONGOING BASIS

17. THE NATIONAL ANTI MONEY LAUNDERING COMMITTEE • EDUCATION FOR OFFICIALS AT THE HIGHEST ECHELONS OF THE POLITICAL DIRECTORATE ON THE EXTENT AND SERIOUSNESS OF THE OBLIGATIONS UNDERTAKEN WITH THE INTERNATIONAL COMMUNITY AND THE IMPLICATIONS FOR NON COMPLIANCE. • IMPACT OF THE PUBLICATION OF THE MUTUAL EVALUATION REPORTS • RESPONSE OF THE INTERNATIONAL MARKETS AND INVESTMENT COMMUNITY

18. THE NATIONAL ANTI MONEY LAUNDERING COMMITTEE • MINISTRY OF JUSTICE • ATTORNEY GENERAL –CENTARL AUTHORITY • MINISTRY OF NATIONAL SECURITY-FINANCIAL INTELLIGENCE UNIT POLICE-CUSTOMS-IMMIGRATION- COAST GUARD-ARMY • MINISTRY OF FINANCE-CENTRAL BANK-SECURITIES EXCHANGE COMMISSION-SUPERVISOR OF INSURANCE- SUPERVISORS FOR CREDIT UNIONS- REGULATORS FOR TRUST AND COMPANY SERVICE PROVIDERS • SELF REGULATORY ORGANISATIONS-ATTORNEYS-ACCOUNTANTS- REAL ESTATE AGENTS, • REGULATORY BODIES –DEALERS IN PRECIOUS METALS/PRECIOUS STONES, CASINOS - MONEY SERVICE BUSINESSES -BUREAUX DE CHANGE

19. THE NATIONAL ANTI MONEY LAUNDERING COMMITTEE • FOCUS OF ALL THESE ENTITIES • ENGENDERING A STRONG CULTURE OF COMPLIANCE IN THE JURISDICTION • REPUTATION • REPUTATION • REPUTATION

20. THE MUTUAL EVALUATION PROCESS • THE MUTUAL EVALUATION EXERCISE IS NOT A TRIAL, IT IS A CONSTRUCTIVE CONSULTATIVE DIALOGUE BETWEEN PROFESSIONALS, BE THEY BANK SUPERVISORS/REGULATORS, LEGAL OFFICERS OR MEMBERS OF THE DEFENCE FORCE, POLICE AND CUSTOMS DEPARTMENTS, REPRESENTATIVES OF THE PRIVATE SECTOR • THE AIM IS TO ASSIST THE MEMBER STATE TO IMPROVE ITS ANTI MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM FRAMEWORK SO THAT THE LEGISLATION, REGULATIONS, ADMINISTRATIVE PROCEDURES, PROGRAMMES AND POLICIES ARE IN COMPLIANCE WITH THE 40 FATF AND 9 SPECIAL RECOMMENDATIONS.

21. THE DOCUMENTS FOR THE MUTUAL EVALUATION MISSION • THE MUTUAL EVALUATION QUESTIONAIRE • THE AML/CFT METHODOLOGY • THE CFATF MUTUAL EVALUATION PROCEDURES • THE 40 FATF RECOMMENDATIONS ON MONEY LAUNDERING • THE NINE SPECIAL RECOMMENDATIONS TO COMBAT THE FINANCING OF TERRORISM • THE VIENNA CONVENTION-DRUG TRAFFICKING • THE PALERMO CONVENTION-ORGANISED CRIME • UN CONVENTION FOR THE SUPPRESSION OF THE FINANCING OF TERRORISM • UN SECURITY COUNCIL RESOLOUTIONS 1267 AND 1373

22. THE MUTUAL EVALUATION PROCESS • RECEIVE ME RESPONSE 2 MONTHS BEFORE ON-SITE • SECRETARIAT TO PREPARE PARTIAL DRAFT IN ADVANCE OF ON-SITE • ON-SITE: 8 DAYS OF MEETINGS • LAST 2 DAYS – TEAM LOOKS AT EACH RECOMMENDATION TO AGREE RATINGS • 1ST DRAFT MER – 8-10 WEEKS AFTER ONSITE

23. THE MUTUAL EVALUATION PROCESS • INITIAL FULL REVIEW BY COUNTRY AND SUBMISSION OF COMMENTS • POSSIBLE 2ND FACE TO FACE MEETING • DRAFT MER TO PLENARY 1 MONTH BEFORE MEETING • IFI PRO-FORMA REVIEW PRIOR TO PLENARY • ERG PROCESS AT BEGINNING OF PLENARY • PLENARY DISCUSSION • PUBLICATION OF REPORT

24. THE MUTUAL EVALUATION REPORTPUBLICATION ON THE CFATF WEBSITE • SCRUTINY FROM REGIONAL AND INTERNATIONAL PARTNERS • ACCOLADES AND EMULATION • CENSURE AND SANCTIONS • INDEED THE CFATF EXPERIENCE HAS BEEN THAT MEMBERS, BY VIRTUE OF THE MUTUAL EVALUATION REPORT HAVE BEEN ABLE TO IMPLEMENT IMPROVEMENTS IN THEIR LEGISLATIVE FRAMEWORK THROUGH THE RECOMMENDATIONS OF THE EXAMINERS

25. THE MUTUAL EVALUATION REPORT • MONITORING ROLE OF THE NATIONAL ANTI MONEY LAUNDERING COMMITTEE PIVOTAL - • RECTIFICATION OF IDENTIFIED DEFICIENCIES- RECOMMENDATIONS OF EXAMINERS • DELIVERY OF TECHNICAL ASSISTANCE AND TRAINING • BUILDING DOMESTIC CAPACITY • WORKING WITH INTERNATIONAL DONOR COMMUNITY

26. THE MUTUAL EVALUATION REPORT • CFATF SECRETARIAT –REGIONAL CO-ORDINATOR FOR DONOR ASSISTANCE • GROUP OF COOPERATING AND SUPPORTING NATIONS-CANADA,FRANCE, NETHERLANDS,MEXICO, SPAIN, UNITED KINGDON, UNITED STATES OF AMERICA • INTERNATIONAL MONETARY FUND • WORLD BANK • FATF SECRETARIAT • UNITED NATIONS

27. FATF NON COPERATIVE COUNTRIES AND TERRITORIES EXERCISE 1999-2005 • DESIGNED TO COMBAT NATIONAL AND INTERNATIONAL THREATS • MAINTAIN THE SAFETY AND SECURITY OF THE INTERNATIONAL FINANCIAL SYSTEM

28. STATEMENTS BY THE INTERNATIONAL COMMUNITY • UNITED NATIONS RESOLUTIONS • COMMONWEALTH -HEADS OF GOVERNMENTS • INTERNATIONAL MONETARY FUND • G7 FINANCE MINISTERS • ORGANISATION FOR ECONOMIC COOPERATION AND DEVELOPMENT • FINANCIAL STABILTIY FORUM

29. SPIRIT OF THE STATEMENTS • TO COMBAT TRANSNATIONAL ORGANISED CRIME • TO IMPROVE REGULATION OF OFFSHORE FINANCIAL CENTRES • MEASURES NECESSARY TO DETER MONEY LAUNDERING • MAINTAIN THE CREDIBILITY AND INTEGRITY OF THE GLOBAL FINANCIAL SYSTEM

30. TWENTY FIVE POINT CRITERIA • LOOPHOLES IN FINANCIAL REGULATIONS 1-11 • OBSTACLES RAISED BY OTHER REGULATORY REQUIREMENTS 12-14 • OBSTACLES TO INTERNATIONAL COOPERATION 15-22 • INADEQUATE RESOURCES FOR PREVENTING AND DETECTING MONEY LAUNDERING ACTIVITIES 23-25

31. SOURCESOF INFORMATION FOR EXAMINATION OF POTENTIAL TARGET COUNTRIES • OPEN SOURCE DATA • RESTRICTED-INFORMATION-MUTUAL EVALUATION REPORTS • DIRECT EXPERIENCES IDENTIFYING PROBLEMS OF COOPERATION

32. GUIDING FEATURES TO EXAMINE JURISDICTIONS • LOOPHOLES IN LAWS • SHORTCOMINGS IN THE ACTIVITIES OF FINANCIAL CENTRES • PRACTICAL OR OPERATIONAL IMPEDIMENTS TO COOPERATION

33. CFATF COUNTRIES REVIEWED AS A PRIORITY • ANTIGUA AND BARBUDA • THE BAHAMAS • BELIZE • BERMUDA • BRITISH VIRGIN ISLANDS • CAYMAN ISLANDS • DOMINICA • PANAMA • ST. LUCIA • ST. KITTS AND NEVIS • ST. VINCENT AND THE GRENADINES

34. CFATF COUNTRIES THAT WERE LISTED • THE BAHAMAS • CAYMAN ISLANDS • DOMINICA • PANAMA • ST. KITTS AND NEVIS • ST. VINCENT AND THE GRENADINES • GRENADA • GUATEMALA

35. SOME FACTORS THAT LED TO LISTING • INADEQUATE CONTROL AND SUPERVISION OF THE OFFSHORE SECTOR • NEGATIVE RESPONSES TO ENQUIRIES ON IDENTIFICATION OF SHAREHOLDERS • OBSTACLES TO IDENTIFICATION OF BENEFICIAL OWNERS OF COMPANIES • REFUSAL TO PROVIDE RECORDS IN PURE CRIMINAL TAX MATTERS

36. LEGISLATIVE SHORTCOMINGS • FAILURE TO CRIMINALIZE MONEY LAUNDERING BEYOND DRUGS • NO MANDATORY SYSTEM FOR REPORTING SUSPICIOUS TRANSACTIONS • EXCESSIVE SECRECY PROVISIONS

37. EFFECTS OF LISTINGS • ADVERSE ECONOMIC IMPLICATIONS • LOSS OF BUSINESSES, JOBS AND INVESTMENTS • FEELINGS OF HELPLESSNESS AND VULNERABILITY • DIVERSION OF SIGNIFICANT HUMAN AND FINANCIAL RESOURCES TO RESPOND TO THE INITIATIVES

38. SUCCESSOR TO THE FATF NCCT EXRCISE • THE FATF REMAINS VIGILANT ON INTERNATIONAL COOPERATION ISSUES AND WILL NOT HESITATE TO ACT IF A COUNTRY POSES A SERIOUS THREAT TO THE INTERNATIONAL EFFORT TO COMBAT MONEY LAUNDERING AND TERRORIST FINANCING. • INTERNATIONAL COOPERATION REVIEW GROUP • REVIEW OF COUNTRIES THAT POSE THREATS TO EXPEDITIOUS AND EFFECTIVE COOPERATION BETWEEN STATES ON AML/CFT ISSUES.

39. CRITERIA FOR PRORITISING COUNTRIES OR REVIEW • SEVERE DEFICIENCIES IN IMPLEMENTING THE AML/CFT STANDARDS(EG LACK OF CRIMINALISATION OF ML/FT, LACK OF PREVENTIVE MEASURES,LACK OF FIU • CONCRETE CASES OF NOT ADEQUATELY RESPONDING TO REQUESTS FOR INTERNATIONAL COOPERATION • SIZE OF FINANCIAL SECTOR AND INTEGRATION INTO WORLD MARKETS • ACTUAL ML/FT THREATS.

40. WHERE ARE WE AT NOW THE HEADS OF CFATF FINANCIAL INTELLIGENCE UNITS FORUM ENHANCING INTERNATIONAL COOPERATION ON JUDICIAL, REGULATORY AND LAW ENFORCEMENT ISSUES IN THE FIGHT AGAINST TRANS-NATIONAL ORGANISED CRIME AND THE FINANCING OF TERRORISM. FACILITATING THE SIGNING OF MEMORANDA OF UNDERSTANDING BETWEEN FIUS IN THE REGION AND ALSO WITH FIUS IN OTHER PARTS OF THE WORLD FACILITATING CFATF MEMBERS TO BECOME MEMBERS OF EGMONT

41. WHERE ARE WE NOW • ENCOURAGE MEMBERS IN THE REGIONS • TO FOLLOW EXISTING CENTRES OF EXCELLENCE AND BEST PRACTICES • WITHIN THE CFATF REGION FACILITIES EXIST FOR ELECTRONIC OR PAPERLESS TRIALS, COMPUTERSISED CASE MANAGEMENT AND PLANS FOR THE E-FILING OF DOCUMENTS TO INITIATE NEW CASES OR ADVANCE EXISTING ONES. • OFFICIALS IN THIS JURISDICTION ARE WILLING TO ACCOMMODATE SHORT VISITS OR PERIODS OF SECONDMENT BY OFFICALS FROM THE WIDER CFATF MEMBERSHIP. SUCH EXAMPLES OF BEST PRACTICE MUST BE EMULATED.

42. WHERE ARE WE NOW • TO DEVELOP AND SUSTAIN A STRONG, NATIONWIDE CULTURE OF COMPLIANCE WITH INTERNATIONAL BENCHMARKS AGAINST TRANS NATIONAL ORGANISED CRIME IN ALL ITS FORMS BECAUSE OF THE ATTENDANT REPUTATIONAL RISKS WHERE A JURISDICTION IS SEEN OR PERCEIVED AS HAVING DEFENSIVE MECHANISMS WHICH ARE LESS THAN SATISFACTORY. • PROVIDE ONGOING TRAINING FOR ALL CRIMINAL JUSTICE OFFICIALS IN AREAS SUCH AS BASIC AND ADVANCED FINANCIAL CRIME INVESTIGATIONS, CORRUPTION, AND CONSPIRACY TO DERAUD, ASSET SEIZURE, FREEZING AND CONFISCATION. • THIS COULD ENTAIL DRAWING ON THE BROADRER EXPERIENCES AND EXPERTISE OF THE AGENCIES LIKE THE ASSET FORFEITURE AND RECOVERY UNIT IN DEVELOPED COUNTRIES FOR TRAINING IN MONEY LAUNDERING/ ASSET FORFEITURES AND CONFISCATION PROSECUTIONS AND THE OPERATIONS OF A CIVIL FORFEITURE SCHEME

43. WHERE ARE WE NOW • TRUMPETING REGIONAL ACCOMPLISHEMNTS TO THE INTERNATIONAL COMMUNITY • IN SOME INSTANCES IN THE CARIBEAN BASIN REGION SUCH A POSITION HAS LED TO JURISDICTIONS BEING AHEAD OF INTERNATIONAL STANDARDS ON CERTAIN MATTERS, • THE COVERAGE OF ‘GATEKEEPERS’SUCH AS LAWYERS AND REAL ESTATE AGENTS • THE ABOLISHING OR IMMOBILIZATION OF BEARER SHARES; • THE UNDERTAKING OF RETROSPECTIVE DUE DILIGENCE ON ALL EXISTING CLIENTS IN KEEPING WITH MODERN KNOW YOUR CUSTOMER PRINCIPLES;

44. WHERE ARE WE NOW • ENTRENCHED REGIONAL PARTICIPATION IN THE FATF WORKING GROUPS • REGIONAL VOICE/REGIONAL INTERESTS COULD BE INSTRUMENTAL IN FRAMING THE AML/CFT BENCHMARKS • MORE CFATF MEMBERS SHOULD GRASP THE OPPORTUNITY-FOLLOW THE LEAD OF THE BRITSH VIRGIN ISLANDS/CAYMAN ISLANDS/THE BAHAMAS.

45. FUTURE FOCUS FOR CFATF MEMBERS • STRIVING FOR FULL COMPLIANCE WITH THE INTERNATIONAL BENCHMARKS • TIMELY ADHERENCE WITH THE CFATF MUTUAL EVALUATION PROCEDURES • ACTIVE PARTICIPATION IN THE PLENARY DISCUSSIONS OF THE MUTUAL EVALUATION REPORTS • PARTICIPATION AS EXAMINERS IN CFATF/FATF/FSRBS/IMF/WB MUTUAL EVALUATION MISSIONS • ACTIVE PARTICIPATION IN THE CFATF WORKING GROUPS ON LEGAL, FINANCIAL AND LAW ENFORCEMENT

46. FUTURE FOCUS FOR CFTAF MEMBERS • ADVERSERIAL STANCE OF THE PAST IS TO BE REPLACED WITH FULL ENGAGEMENT IN THE GLOBAL AML/CFT DIALOGUE WITH ALL INTERNATIONAL PARTNERS • PROVIDING FEEDBACK TO THE SECRETARIAT ON FATF PAPERS AND INITIATIVES • PARTICIPATING WHERE APPLICABLE IN FATF WORKING GROUP MEETINGS AS CFATF REPRESENTATIVES

47. THE WAY AHEAD • IN RECENT YEARS AS THE RISKS OF TRANS NATIONAL CRIMINALS ORGANISATIONS HAVE INCREASED, THE INTERNATIONAL STANDARDS TO COMBAT THEM HAVE EXPANDED IN TANDEM, WITH SIGNIFICANT COST IMPLICATIONS FOR THE GLOBAL COMMUNITY. • THIS IS OCCURING IN A CLIMATE WHERE, THERE HAS BEEN IN REAL TERMS, REDUCTIONS IN AID AND INVESTMMENT AND UNFAVOURABLE POLICY DECISIONS BY INTERNATIONAL ORGANISATIONS ON TRADE ISSUES. • GIVEN THESE CIRCUMSTANCES THE CHALLENGES POSED FOR MACRO ECONOMIC POLICYMAKERS, PARTICULARLY IN SMALL COUNTRIES ARE INDEED FORMIDABLE AS THE NEED TO ADHERE TO EVER CHANGING INTERNATIONAL STANDARDS DEMAND THE RE-ALLOCATION OF SCARCE RESOURCES.

48. THE WAY AHEAD • REGIONAL BODIES SHOULD • ADVOCATE FOR A GLOBAL ASSESSMENT OF ALL THE IMPLICATIONS OF FULL ADHERENCE TO THE INTERNATIONAL AML/CFT STANDARDS • ADVOCATE FOR A DIALOGUE AT THE HIGHEST POLITICAL LEVELS INTERNATIONALLY AS TO THE TRUE COSTS OF PROTECTING THE INTERNATIONAL FINANCIAL SYSTEM AGAINST MONEY LAUNDERS. • ADVOCATE FOR A MECHANISM SO THAT THESE COSTS COULD BE MORE EQUITABLY SHARED BY ALL STATES.

49. THE WAY AHEAD • THE RESULT • THE ENHANCEMENT OF GLOBAL CAPACITY, PARTICULARLY OF COUNTRIES IN THE REGIONS, TO BUILD DOMESTIC INFRATSTRUCTURE THAT WOULD EFFECTIVELY AND SUCCESSFULLY PURSUE TRANS- NATIONAL CRIMINAL ORGANISATIONS AND THOSE WHO FINANCE TERRRORISM

50. FUTURE FOCUS FOR CFTAF MEMBERS • STRENGTHENING REGIONAL AML/CFT CAPACITY • PUBLIC AND PRIVATE SECTOR DIALOGUE AND PARTNERSHIP • CONTINUOUS TRAINING INITIATIVES • SPREADING THE MESSAGE THATALL THIS WORK IS TO BE LOOKED AT IN TERMS OF PROTECTING OUR NATIONAL AND REGIONAL