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AML Seminar to Lawyers - JFIU 3 March 2010

AML Seminar to Lawyers - JFIU 3 March 2010. Stewart McGlynn Chief Inspector of Police Joint Financial Intelligence Unit. STR Filing. Suggested format & content detailed in JFIU website Email Fax Post Verbal (urgency - follow-up by hardcopy). Concerns. Urgency Confidentiality

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AML Seminar to Lawyers - JFIU 3 March 2010

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  1. AML Seminar to Lawyers - JFIU3 March 2010 Stewart McGlynn Chief Inspector of Police Joint Financial Intelligence Unit

  2. STR Filing • Suggested format & content detailed in JFIU website • Email • Fax • Post • Verbal (urgency - follow-up by hardcopy)

  3. Concerns • Urgency • Confidentiality • Tipping Off • Crime Report Vs STR

  4. Feedback • Acknowledgement of Receipt • File Ref. • Contact Person Details • Consent / No Consent Letter • Arrest / Prosecutions / Convictions • STR Quarterly Analysis Report

  5. Case Example 1 STR

  6. STR Report Made • Walk-in Client • Background Not Known • Purchase of sizeable commercial property investment • Source of finance unknown

  7. Learning Points • Poor / Negligible CDD / KYC • Absence of risk based approach • Sub Standard STR • JFIU unable to make assessment • What would you think?

  8. Case Example 2 Company A Law Firm Mr. X Resident in In Country Y 12 installments of cash / cashier order HK$ 170 Million Company B

  9. Learning Points • Effective CDD / KYC • Risk based approach • Good quality STR, allowing JFIU to perform its function • Protection for you

  10. Case Example 3 UK Resident Mr. X Fake Letter from a local bank Mr. Z of law firm PRC Pity worth US 8.35M Company A Company B Paid US$ 316,750.00 Company C

  11. Learning Points • Reported knowledge of Crime Proceeds – Fraud • Crime report could have been made but STR acceptable in this case • Urgency? Unsure? Contact JFIU

  12. Case Example 4 Paid Down-payment HK$ 734,900 (10%) Mr.X , a HKID holder Law Firm $ from gambling Purchase price HK$ 7,349,000

  13. Learning Points • Common sense, proportionate approach to KYC and CDD • If it looks like a duck………. • No risk of prosecution

  14. Country Comparison STR filed by Law Firms

  15. STR filed by Law Firms

  16. Some Final Thoughts • JFIU understands the burden that CDD and KYC entails • Law / International Standards • Increase in quality STRs from the sector desirable – intelligence is our business • JFIU is here to help – Contact us

  17. Contact JFIU Telephone:2866 3366 Fax :2529 4013 Email:jfiu@police.gov.hk Mail:GPO Box 6555 Hong Kong stewartmcglynn@police.gov.hk Telephone:2860 3547

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