In September 2016, FSVC received a grant from the U.S. Department of State to provide capacity-building to law enforcement, financial institutions and other relevant actors in Dubai (United Arab Emirates) and Jordan to strengthen local as well as regional anti-money laundering and combating the financing of terrorism (AML/CFT) capabilities. The program will continue through September 2018.
To develop this proposed program, FSVC held discussions with several potential counterparts in Dubai (e.g., Dubai Customs and Dubai Judicial Institute, or DJI) and in Jordan (e.g., Anti-Money Laundering Unit, Public Security Department, Customs Department and Judicial Institute of Jordan, or JIJ). A number of innovative activities were developed as a result of these discussions, and designed specifically to target identified weaknesses in CFT at regulatory agencies, law enforcement agencies and prosecutors’ offices, while strengthening in-country (national) and inter-country (regional) CFT efforts.
- Improved CFT Supervision of Non-Profit Organizations (NPOs): As a direct result of FSVC’s support, the NPO Registry and Ministry of Social Development (MoSD):
- Contributed to the efforts of including NPOs as reporting entities under the AML Law of Jordan, which took effect in February 2017;
- Risk mapped the entire NPO sector of Jordan using the risk indicators, and is now able to allocate more time and resources to the supervision of higher-risk NPOs;
- Designed a targeted, risk-based supervision plan, in accordance with Financial Action Task Force (FATF)’s Recommendation 8, and adopted the compliance pyramid approach to supervision;
- Provided clearer information to NPOs about the information they are required to collect and submit, thereby providing the MoSD better information from NPOs; and
- Streamlined the reporting requirements for NPOs, including reducing the template for annual program and financial reports from 12 pages to 7 pages, thereby reducing the average time to complete them from 4 hours to 2 hours. With 5,200 NPOs in Jordan, this is a decrease of around 10,400 reporting hours for NPOs.
- Improved Detection of Terrorist Financing in Capital Markets: FSVC worked with the Jordan Securities Commission (JSC) to develop specific money laundering and terrorist finance typologies for the securities sector to assist in the identification of suspicious activities. As a result, the JSC incorporated the typologies and red flags in its AML/CFT Guidelines Manual for the securities sector. The new manual is currently awaiting final approval by the Board of Directors of the JSC and, once approved, will be distributed to all 57 securities companies in Jordan. This Manual will be critical in helping securities companies better detect suspicious activities.
- Improved Evidence to Investigate and Prosecute Terrorist Financing Cases: As a result of FSVC support to security agencies, namely the Judicial Military Directorate (JMD), the Public Security Department (PSD) and the General Intelligence Department (GID), security agencies are now:
- Forming cooperation units between the JMD, Customs Department, PSD and the AML Unit, to facilitate real-time cooperation and exchange of information;
- Establishing timelines of activities to help build terrorist finance cases;
- Conducting link analysis of financial and communication information between suspects;
- Using social media sources as evidence for prosecution (e.g., having informants on WhatsApp groups and monitoring Twitter through TweetDeck);
- Deploying terrorist finance investigative tools and tactics, such as informant development;
- Providing training on financial crimes to all future graduating judges and prosecutors from the Judicial Institute of Jordan, including how to develop the financial profiles of suspects through interviews, analyze bank records (e.g., account opening documents, Know-Your-Customer (KYC) records, bank account statements, wire transfers, safety deposit boxes), currency exchanges and credit card records; and
- Reviewing passenger lists from airlines to detect the movement of foreign terrorist fighters (FTFs), per United Nations Security Resolution (UNSCR) 2178.
- Over 35 money laundering and terrorist financing (TF) risks were detailed in reports that were shared with the National Risk Assessment (NRA) Sub-Committee;
- Over 100 private sector representatives from the banking, securities, money exchange and designated non-financial businesses and professions (DNFBPs) participated in FSVC’s activities to identify these risks; some DNFBP entities stated that it was the first time they were engaged with the regulator on CFT issues;
- FSVC helped local authorities develop a risk-scoring model to score these identified risks to the economy;
- FSVC helped local authorities develop over 9 practical CFT mitigation strategies to reduce or eliminate local TF risks across various sectors;
- Thanks to FSVC, in August 2017, the Central Bank of the UAE revised KYC compliance regulations for on-shore financial institutions to use a risk-based approach; and
- FSVC helped regulators, law enforcement and prosecution agencies improve information exchange and communication on TF cases.