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ASSESSING THE IMPACT OF THE LOTTERY SCAM ON THE BANKING & REMITTANCE SECTORS

ASSESSING THE IMPACT OF THE LOTTERY SCAM ON THE BANKING & REMITTANCE SECTORS. Presented By: Justin Felice Chief Technical Director FINANCIAL INVESTIGATIONS DIVISION. Jamaica ’ s Legal Framework- ( AML & CFT). Terrorism Prevention Act (2005) Proceeds of Crime Act & Regulations (2007)

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ASSESSING THE IMPACT OF THE LOTTERY SCAM ON THE BANKING & REMITTANCE SECTORS

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  1. ASSESSING THE IMPACT OF THE LOTTERY SCAM ON THE BANKING & REMITTANCE SECTORS Presented By: Justin Felice Chief Technical Director FINANCIAL INVESTIGATIONS DIVISION

  2. Jamaica’s Legal Framework-( AML & CFT) • Terrorism Prevention Act (2005) • Proceeds of Crime Act & Regulations (2007) • Financial Investigations Division Act (2010) • Terrorism Prevention Regulations (2010) Financial Investigations Div.

  3. REGULATED SECTOR • Financial Institutions (gatekeepers) (POCA, TPA- sec 2) • Designated Non-financial institutions -pending (e.g. Accountants, Attorneys-at-law etc) • Any other person declared by the Minister of National Security/Foreign Affairs (e.g. Exim Bank) Financial Investigations Div.

  4. STR Received by FID Financial Investigations Div.

  5. TTR Received by FID Financial Investigations Div.

  6. Designated Non-Financial Institutions. (pending) • Lawyers, notaries, other independent legal professionals, accountants • Casinos (including internet casinos) • Real estate agents • Dealers in precious stones and metal • Trust company service providers Financial Investigations Div.

  7. LOTTERY SCAM INDICATORS REMITTANCE TRANSACTIONS • Average amounts sent relatively small, between US$250 - $1,000 • Multiple senders to single recipient • Multiple recipients from same sender. • Multiple transactions during the same day or within short period. Financial Investigations Div.

  8. LOTTERY SCAM INDICATORS Profile of the sender • Sender normally elderly • Multiple transactions from same sender • Senders residing in areas where there are not large concentrations of Jamaicans • Senders surnames tend not to be of English origin, hence unlikely to be related to the typical Jamaican Financial Investigations Div.

  9. LOTTERY SCAM INDICATORS PROFILE OF RECIPIENT • Although island-wide most scammers reside in the western parishes • Recipient usually between age 18 to 30 years • The use of multiple IDs and addresses • Usually unemployed or low-income jobs. Financial Investigations Div.

  10. LOTTERY SCAM INDICATORS TRANSACTIONS –OTHER FINANCIAL INSTITUTIONS • Large wire transfers from same sender(s) • Frequent large cash deposits • New accounts being opened or dormant accounts being re-activated. • Joint accounts with older relative (usually mother) Financial Investigations Div.

  11. LOTTERY SCAM INDICATORS TRANSACTIONS –OTHER FINANCIAL INSTITUTIONS • When funds are deposited, withdrawals are mainly via ATM and POS • Source of funds information not credible/ does not match profile of accountholder • Occupation/income not in keeping with level of deposits • Cash intensive businesses registered as decoy Financial Investigations Div.

  12. LOTTERY SCAM INDICATORS Recent trends • Collection of funds (in the USA) by associates who then send funds to Jamaica- identification of victim becomes more difficult. • Couriers/third parties used to collect funds-no direct trail to beneficiaries • Funds sent to other Countries Financial Investigations Div.

  13. CHALLENGES LAW ENFORCEMENT • Inadequate sender information and arduous process in obtaining this information. • Obtaining of witness statement • Need for physical presence of overseas witness/victim for court purposes. • Court system (hearing dates & continuous postponements) • Insufficient resources (personnel, software) Financial Investigations Div.

  14. PROPOSED SOLUTIONS FINANCIAL INSTITUTIONS • Effective implementation of policies and procedures for identification & monitoring of suspicious transactions • Continuous staff training, KYC. • Greater collaboration between local and overseas remittance partners Financial Investigations Div.

  15. PROPOSED SOLUTIONS • Need for greater collaboration in sharing intelligence. • Better use of analysis, understanding the threat to Jamaica. • Creation of a Problem Profile…National Intelligence Model. • Task Force to include ALL agencies with hands on support from US Law Enforcement Agencies. Financial Investigations Div.

  16. PROPOSED SOLUTIONS • Media Campaign • Education re Benefits of Asset Recovery • Reducing Crime • Asset Recovery should be Self Generating • Safer and Stronger Communities • Crime Doesn’t Pay • Asset Recovery Incentive Scheme • Crime Fighting Priorities Financial Investigations Div.

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