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ARO Seminar Ankara. tristram.hicks@npia.pnn.police.uk. What is financial crime?. The handling of the proceeds of crime (drug dealing, theft, smuggling, trading counterfeit goods) Market manipulation (insider trading) Tax evasion Fraud. What is money laundering?.
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ARO Seminar Ankara tristram.hicks@npia.pnn.police.uk
What is financial crime? The handling of the proceeds of crime (drug dealing, theft, smuggling, trading counterfeit goods) Market manipulation (insider trading) Tax evasion Fraud
What is money laundering? • The handling of the proceeds of predicate crimes (drug dealing, theft, smuggling, trading counterfeit goods)
What is financial investigation? The covert mapping of criminals and their assets before arrest The intrusive use of financial intelligence, multiple databases, analysis, mixed with traditional surveillance, human sources and other field intelligence
Speakers • Tristram Hicks, Detective Superintendent Scotland Yard • Head of Financial Intelligence • Recipient of all London STRs • Head of London Asset Recovery Team • Police rep on National Strategic Committees
Speakers • Cedric Woodhall • Senior Officer UK Customs • Head of • Set up UK Asset Recovery Office
Speakers • Lawrie Day • Scotland Yard Detective • Accredited Financial Investigator • International AML adviser (Kosovo, Croatia, Albania, northern Cyprus)
Speakers • Jill Thomas • Europol AML specialist • Secretary of CARIN • Secretary of ARO Platform
Speakers • Nottenboom • Netherlands specialist prosecutor • Founder of ARO
ARO Seminar Ankara tristram.hicks@npia.pnn.police.uk
ARO SeminarAnkaraUK experience tristram.hicks@npia.pnn.police.uk
Key tools • Find bank accounts • Access to SARs • Seize cash • Freeze accounts & assets • Incentive money for agencies
Incentive money for agencies • 50% to Ministry of Interior • 18.75% Police • 18.75% Prosecution • 12.5% Courts administration
Incentive money for agencies Pros Cons Changes focus from good policing to revenue Perverted ‘cost/benefit analysis ‘Better, quicker, cheaper’ investigations ignored ‘Incentive’ time limited • Helps senior management • Helps middle management • Helps shop floor • Helps government
Incentive money for agencies • Perceptions • Police allow drug dealers to carry on until car is worth seizing (moral hazard) • Prosecutors change indictment/ bring case to get the money (Judicial disapproval) • Police/prosecutors working for themselves not the public (public distrust)
Standard Intelligence Unit Operational Heads Briefing Officer Manager Analyst F.I.O.
A Working AML Regime Acquis and FATF compliant Increased State revenue Deters & disables organised crime Outputs: Prosecutions & Confiscation Outcomes Suspicious activity Intervention Police Prosecutors Customs Tax Social welfare Tax evasion Local crime Other crime Strategic Group SARs FIC Receiving Analysis Dissemination Feedback to Sectors Financial sector Awareness Trust Feedback
Financial investigators UK only
Training History • Fraud Training • Fraud and Confiscation Training • Confiscation Training • Intelligence then Investigation then Confiscation Training
UK training is EU recommended • Council of the EU, Evaluation of Financial Crime and Financial Investigation, Report on the UK. • UK powers and training systems should be presented to the EU, its Members and Agencies
Course Format • Pre-read • 5 day course • Allocation of Tutor • Creation of Professional Development Portfolio • Regular Continuous PD
Course style • Interactive problem solving • Main Courses follow one case
Key lessons from UK Beware! Cultural resistance of senior police managers, prosecutors, judges Emphasise operational efficiency: better, quicker, cheaper investigations Seize and freeze first, ask questions later Importance of cash seizure Collect statistics now! Beware recycling the money to agencies
Money Laundering & Proceeds of Crime (ML & POC) tristram.hicks@npia.pnn.police.uk