JAMAICAS CREDIT UNION MOVEMENTS RESPONSE TO FATF AND

JAMAICA’S CREDIT UNION MOVEMENT’S RESPONSE TO FATF AND CFATF VERA LINDO JCCUL JUNE 2018

THE CFATF • THE CFATF IS AN INTERGOVERNMENTAL BODY THAT COMPRISES COUNTRIES OF THE CARIBBEAN BASIN • THESE COUNTRIES HAVE COMMITTED TO FIGHTING ML AND TF AND TO IMPLEMENTING THE FATF RECOMMENDATIONS ON AML AND CFT • THE CFATF MONITORS COUNTRIES PROGRESS BY CARRYING OUT MUTUAL EVALUATIONS (MEVAL) / PEER REVIEWS TO ASSESS COUNTRIES’ LEVELS OF COMPLIANCE • JAMAICA’S LAST MUTUAL EVALUATION WAS IN 2015

RESULTS OF ASSESSMENT 1. THE FINANCIAL SECTOR HAS MODERATELY COMPLIED WITH THE RECOMMENDATIONS TO STRENGTHEN THE AML AND CFT FRAMEWORK 2. IMPROVEMENT IS NECESSARY IN THE REMITTANCE, SECURITIES DEALERS AND MICRO FINANCE SECTORS 3. LEGAL FRAMEWORK OF LAWS AND ENFORCEABLE MEANS AND POWERS AND PROCEDURES OF COMPETENT AUTHORITIES ARE IN PLACE BUT NEEDS STRENGTHENING IN THE AREAS OF PROSECUTION AND COMBATTING TERRORISM

WHAT HAS JAMAICA DONE • AML/CFT FRAMEWORK/AMENDMENTS GEARED AT ENFORCING GREATER COMPLIANCE & EXPANDED TO PULL OTHERS UNDER THE FRAMEWORK (ADDITION OF DESIGNATED NON FINANCIAL INSTITUTIONS (DNFI) • GROUP-WIDE MONITORING • STRENGTHENING OF THE SYSTEM, BUILDING MORE AWARENESS ACROSS SECTORS, ACTS AS A DETERRENT TO MORE PERSONS, RISKBASED APPROACH FOCUSES MORE ON HIGH RISK • INSTITUTIONS FORCED TO ASSESS THEIR RISKS

WHAT HAS JAMAICA DONE • INCREASED WILLINGNESS OF THE FINANCIAL INVESTIGATIONS DIVISION (FID) AND LAW ENFORCEMENT TO WORK WITH FINANCIAL INSTITUTIONS • FINANCIAL INSTITUTIONS, LAW ENFORCEMENT & LEGAL PROFESSION/DPP PUSHING FOR COURT TO EFFECTIVELY DEAL WITH FINANCIAL CRIMES

WHAT HAS JAMAICA DONE • CALL FOR MORE TRAINING OF LEGAL PROFESSION/CLERK OF THE COURTS AND FINANCIAL INVESTIGATORS OF FIS FOR MORE CASES OF FINANCIAL CRIMES TO EFFECTIVELY RESULT IN PROSECUTION • TRAINING IS BEING CONDUCTED ON POCA AND MONEY LAUNDERING RELATED ISSUES AMONG THE JUDICIARY • INCREASED UTILIZATION OF POCA BY LAW ENFORCEMENT IN GOING AFTER CRIMINAL PROPERTY/PROCEEDS OF CRIME

WHAT HAS JAMAICA DONE • PERCEIVED WILLINGNESS OF LAW ENFORCEMENT TO PROSECUTE HIGH PROFILE INDIVIDUALS - MORE PUBLICITY OF THESE CASES IN THE MEDIA • A FINANCIAL INTELLIGENCE UNIT WAS ESTABLISHED WITHIN THE MINISTRY OF FINANCE AS A ONE STOP SHOP THAT WILL FOCUS ON MONEY LAUNDERING AND TAX EVASION PRACTICES • ESTABLISHMENT OF NATIONAL CYBERCRIME TASKFORCE TO FIGHT CYBERCRIMES ACROSS BORDERS

WHAT HAS JAMAICA DONE • NATIONAL INTEGRITY AGENCY (NIA) PROMOTING INTEGRITY AND ELIMINATION OF CORRUPTION AMONG JAMAICANS • NEW GO AML REPORTING SYSTEM TO FID TO BE IMPLEMENTED TO ENHANCE QUALITY OF REPORTING/SHARING OF INFORMATION WITH FINANCIAL INSTITUTIONS

THE JAMAICA LEAGUE’S RESPONSE • THE LEAGUE’S ROLE, AS TRADE ASSOCIATION FOR CREDIT UNIONS (WITHIN THE CONTEXT OF JAMAICA’S AML/CFT FRAMEWORK) IS TO PROTECT THE CREDIT UNION FINANCIAL SYSTEM FROM MONEY LAUNDERING AND TERRORISM FINANCING • WE HAVE LEVERAGED OUR RELATIONSHIP WITH CREDIT UNIONS TO PROVIDE AML CFT ASSISTANCE

THE JAMAICA LEAGUE’S ASSISTANCE TO CUS • WE HAVE HOSTED AML CFT AWARENESS SESSIONS FOR CUS WITH REPRESENTATIVES OF THE CENTRAL BANK (BANK OF JAMAICA) AND THE FINANCIAL INVESTIGATIONS DIVISION (FID) • THE FID HAS TRAINED CU PERSONNEL ON COMPLETING STRS AND TTRS UNDER BOTH POCA AND TPA • THE LEAGUE HAS CIRCULATED FID ADVISORIES AND BOJ GUIDANCE NOTES TO ALL CUS

THE JAMAICA LEAGUE’S ASSISTANCE TO CUS • THE LEAGUE HAS DEVELOPED UPDATED CREDIT UNION MEMBER APPLICATION FORMS TO CAPTURE THE KYC INFORMATION REQUIRED UNDER POCA AND TPA – THE FORMS CAN BE ACCESSED ONLINE • THE LEAGUE DEVELOPED MODEL AML CFT POLICIES AND PROCEDURES AS TEMPLATES FOR CUS

THE JAMAICA LEAGUE’S ASSISTANCE TO CUS • THE LEAGUE DEVELOPED JOB DESCRIPTIONS FOR RISK AND COMPLIANCE MANAGERS (NOMINATED OFFICERS) • THE LEAGUE PROVIDES TRAINING FOR RISK MANAGERS AND FACILITATES THEIR CREDIT UNION RISK MANAGERS’ ASSOCIATION MEETINGS

THE JAMAICA LEAGUE’S ASSISTANCE TO CUS • THE LEAGUE CONDUCTS AML CFT INTERNAL AUDITS TO MONITOR CREDIT UNIONS’ COMPLIANCE WITH POCA AND TPA AND THE FID ADVISORIES AND BOJ GUIDANCE NOTES • FRAUD ALERTS ARE DISPATCHED TO CUS AND SUGGESTIONS MADE TO MINIMIZE ML RISKS ESPECIALLY IN AREAS WITH HIGH INCIDENCES OF LOTTO SCAMMING

THE JAMAICA LEAGUE’S ASSISTANCE TO CUS • THE LEAGUE HAS DEVELOPED AN ENTERPRISE RISK MANAGEMENT FRAMEWORK FOR CUS AND ASSISTED THEM TO DEVELOP THEIR RISK REGISTERS. • RISK CHARTER • RISK COMMITTEES • RISK MANAGER • RISK ASSESSMENT: H M L VIA RISK REGISTERS • RISK REPORTS TO THE BOD – MONTHLY AND ANNUALLY

THE JAMAICA LEAGUE’S ASSISTANCE TO CUS • THE LEAGUE FORWARDS THE UN SANCTIONS LIST RECEIVED FROM THE BOJ FROM TIME TO TIME, TO CUS • THE LEAGUE IS CURRENTLY RESEARCHING A TRANSACTION MONITORING TOOL FOR CUS

THE JAMAICA LEAGUE’S ASSISTANCE TO CUS • THE LEAGUE SITS ON THE JAMAICA BANKERS ASSOCIATION (JBA) COMPLIANCE AND ANTI-FRAUD COMMITTEES WHICH: • FACILITATES GREATER COLLABORATION AND CO-OPERATION WITHIN THE FINANCIAL SECTOR THAT ASSISTS WITH UNDERSTANDING OF LAWS/REGULATIONS, TREATMENT & PROMOTION OF BEST PRACTICES

THE JAMAICA LEAGUE’S ASSISTANCE TO CUS • THE LEAGUE SITS ON THE JBA COMPLIANCE AND ANTI-FRAUD COMMITTEES WHICH: • PROMOTES A MORE UNIFIED APPROACH TO ADDRESSING FINANCIAL CRIMES PROVIDING UPDATES ON FRAUD EXPERIENCES, INFORMATION SHARING, IDENTIFYING TRENDS, RECOMMENDATIONS FOR RESOLVING ISSUES AND BEST PRACTICES AND PROMOTION OF A MORE UNIFIED APPROACH.

THE JAMAICA LEAGUE’S ASSISTANCE TO CUS • THE LEAGUE SITS ON THE JBA COMPLIANCE AND ANTI-FRAUD COMMITTEES WHICH: • FACILITATES MORE ENGAGEMENT WITH LAW ENFORCEMENT • PROMOTES PUBLIC AWARENESS OF FINANCIAL CRIMES (DR/CR CARDS, CYBERCRIME, ETC. ) AND HOW THEY CAN PROTECT THEMSELVES

THE JAMAICA LEAGUE’S ASSISTANCE TO CUS • THE LEAGUE HAS DEVELOPED AML AND CFT ONLINE TRAINING COURSES AND EXAMS (3 COURSES AND 6 EXAMS) COVERING POCA OVERVIEW, OFFENCES AND PENALTIES, KYC , KYE, ROLE OF CU EMPLOYEES INCLUDING NOMINATED OFFICER AND INTERNAL AUDITOR, CFT • VIA CPD ONLINE – CREDIT UNION NATIONAL ASSOCIATION (CUNA) USA

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HOW CAN CARIBBEAN CREDIT UNIONS ACCESS CPD ONLINE? • LEAGUE BROKERED AGREEMENT WITH CUNA FOR YOUR STAFF AND VOLUNTEERS ACCESS TO CPD ONLINE WITH OVER 300 COURSES. • POCA ANTI-MONEY LAUNDERING COURSE FOR JAMAICA’S CUS HAS BEEN DEVELOPED • COST PER CU PAYABLE BY JANUARY 1 EACH YEAR: • VOLUNTEER AND STAFF COMPLEMENT OF LESS THAN OR EQUAL TO 25: US $4, 500 PLUS TAX = 5, 242. 50 • VOLUNTEER AND STAFF COMPLEMENT OF GREATER THAN 25: US $6, 500 PLUS TAX = $7, 572. 50

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