Red Flags of Terrorist Financing: AML Compliance Expert

Funding of terrorism involves providing funds from both legal and or illegal sources, directly or indirectly or knowing that the monies are to be used to finance terrorism activity or organizations

Red Flags Indicative of TF

Behavioural indicators:

  1. The parties to the transaction (owner, beneficiary) are from countries known to support terrorist activities and organizations;
  2. Use of false companies including shell companies;
  3. Inclusion of the individual in the United Nations 1267 Sanctions list;
  4. Media reports that the account holder is linked to known terrorist organizations or is engaged in terrorist activities;
  5. Beneficial owner of the account not properly identified;
  6. Use of nominees, trusts, family member or third-party accounts;
  7. Use of false identification;
  8. Abuse of non-profit organization.

About the Author: Antoinette Sydney LLB LEC CAMLFC CFRMP, Bar No. SYA2015211, Attorney at Law. The author is the first Online Lawyer based in Trinidad and Tobago. Her entire Law Practice is based Online using technology. Client meetings are conducted at mutually convenient meeting points. She has clients in Guyana, St Vincent, Barbados, the British Virgin Islands and North America. She specializes in Corporate Law and Anti-Money Laundering Compliance. She helps clients to start their Online Business Empire.

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I am a Certified Professional in the following areas:

Taxation;

Corporate Training;

Anti-Money Laundering and Financial Crimes;

Fraud Risk Management;

Graphic Design.

Services include:

Anti-Money Laundering (AML) Training for staff, directors;

Anti-Money Laundering Audits;

Compliance Program drafting;

Consulting services and much more.

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How are Art Dealers used to wash dirty money?: Free Anti Money Laundering Training in Trinidad!!

One of my friends is an artist and she tells me of here adventures. She once told me that at one of her art shows a customer saw her painting, went for her cheque book and was prepared to buy my friend’s piece. The lady issued a cheque payable to my friend’s personal name. In order to advance her career my friend must be close with art dealers and art galleries. She told me that the art galleries take a commission for each painting that the artist sells.

I attended my friend’s art exhibition and I was amazed at the people in the crowd. They were mainly well-dressed professionals. Everyone was refined and sipped on the complimentary wine. The prices of the paintings ranged from $1200.00 TTD to $200,000.00 TTD. I became curious as to how money launderers can abuse art dealers to launder money.

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  1. High value artwork can be purchased with cash obtained from criminal activities and then re-sold to another purchaser for more than the purchase price. This second purchaser can pay via cheque with the payee being the Art Dealer. The dirty money has been laundered and the proceeds from the sale of the artwork will appear legitimate because the funds will pass through a financial institution when the cheque is encashed.
  2. Artwork can be purchased with dirty money and shipped to another country where it will be sold at a profit. This allows for the cross-border movement of a high valued asset.
  3. A money launderer can purchase artwork at a low price with funds from illegal activity and then use the services of an auctioneer to sell the art to the highest bidder. The auctioneer can be paid in cash with money gained from the proceeds of crime.
  4. An art dealership can be registered, an art gallery can be opened to display art. The expenses of the art dealership such as rent and salaries can be paid with dirty money.
  5. After purchasing artwork with dirty money, the high valued art can be used as collateral for a loan application with a financial institution or money lending service.
  6. An artist can be hired to forge rare pieces of art and these can be sold to unsuspecting customers, who think that they are being the original.
  7. Pieces of art from a young and upcoming artist can be purchased and then can be sold in a few years when and if the artist becomes famous.
  8. The money launderer can connect with companies who want to contribute artwork to a Charity. The artwork that will be sold to the company can be purchased at minimal cost. The owner of a charity here in Trinidad told me about an instance where he asked for sponsorship from a big local company. The company donated almost $100,000 TTD in artwork to his cause.
  9. Art work can be purchased cheaply and then sold online to anyone interested in the piece. Naturally the piece will be sold for more than the purchase price.
  10. Expensive artwork can be stolen from a museum and then sold privately to an interested buyer.

The nature of these art sales is usually private and this makes it ideal for those desirous of washing money. In Trinidad and Tobago, art dealers are regulated by the Financial Intelligence Unit and must appoint a compliance officer, create a compliance program, attend anti-money laundering training and conduct anti-money laundering audits.

I am Antoinette Sydney, LLB LEC CAMLFC CFRMP the first Online Lawyer based in Trinidad and Tobago. I specialise in Corporate Law and Financial Crimes.

http://asydneygroup.com

CONNECT WITH ME: Email: asydneysolutions@gmail.com

Blog: https://sydneygroupblog.wordpress.com/

Linked In: https://tt.linkedin.com/in/antoinette-sydney-77093550

Instagram: @asydneygrouptt

Facebook: https://www.facebook.com/sydneygrouptt/

Youtube: https://www.youtube.com/channel/UC8-sUa8WMDJM8w5_Q3nhQ5w

I am a Certified Professional in the following areas:

Taxation;

Corporate Training;

Anti-Money Laundering and Financial Crimes;

Fraud Risk Management;

Graphic Design.

Get my Ebooks now!!!  only $100TTD !

Payment through Paywise and Paypal!

Ebooks on Sale:

  • How to Change the Business Name of a Sole Trader
  • How to De-Register a Sole Trader Business
  • How to Register a Partnership
  • How to Change from a Sole Trader Business to a Limited Liability Company
  • How to Register a Limited Liability Company
  • How to Change the name of a Limited Liability Company
  • How to Dissolve a Limited Liability Company
  • How to Register an External Company
  • How to prepare Annual Returns for an External Company

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When to file Quarterly Terrorist Report (QTR 1) VS Quarterly Terrorist Report (QTR2 )?

According to section 33 (3) of the Anti-Terrorism Act (ATA), Financial Institutions (FIs) must report to the Financial Intelligence Unit (FIU) every three (3) months:

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(a)if it is not in possession or control of terrorist property via Quarterly Terrorist Report (QTR) 1;

(b)if it is possession or control of terrorist property; and the particulars relating to the persons, accounts and transaction involved and the total value of the property, via Quarterly Terrorist Report (QTR) 2.

As seen above only Financial Institutions must file the QTR1 and QTR2. Listed Businesses do not file QTR1 and QTR2.

I am Antoinette Sydney, LLB LEC CAMLFC CFRMP the first Online Lawyer based in Trinidad and Tobago. I specialise in Corporate Law and Financial Crimes.

http://asydneygroup.com

CONNECT WITH ME: Email: asydneysolutions@gmail.com

Blog: https://sydneygroupblog.wordpress.com/

Linked In: https://tt.linkedin.com/in/antoinette-sydney-77093550

Instagram: @asydneygrouptt

Facebook: https://www.facebook.com/sydneygrouptt/

Youtube: https://www.youtube.com/channel/UC8-sUa8WMDJM8w5_Q3nhQ5w

I am a Certified Professional in the following areas:

Taxation;

Corporate Training;

Anti-Money Laundering and Financial Crimes;

Fraud Risk Management;

Graphic Design.

Get my Ebooks now!!!  only $100TTD !

Payment through Paywise and Paypal!

Ebooks on Sale:

  • How to Change the Business Name of a Sole Trader
  • How to De-Register a Sole Trader Business
  • How to Register a Partnership
  • How to Change from a Sole Trader Business to a Limited Liability Company
  • How to Register a Limited Lability Company
  • How to Change the name of a Limited Lability Company
  • How to Dissolve a Limited Lability Company
  • How to Register an External Company
  • How to prepare Annual Returns for an External Company

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New $50,000 Source of Funds Declaration (SOFD) threshold in Trinidad and Tobago

In Trinidad and Tobago, for the purposes of completing a Source of Funds Declaration (SOFD)  a large transaction is now $50,000TTD according to Legal Notice No. 356 of 2019.

The Miscellaneous Provisions (Proceeds of Crime and Central Bank) Act No 22, 2019 has amended Section 55 (3C) of the Proceeds of Crime Act Chap. 11:27 (POCA) and Regulation 11 (1) of the Financial Obligations Regulations (FORs), 2010. 

It follows that your Anti-Money Laundering/Countering the Financing of Terrorism Proliferation Financing Compliance Program must be updated to reflect this change. A suspicious transaction can also be below this $50,00 threshold and reporting entities can file Suspicious Transaction Reports for transactions that fall below this amount.

I am Antoinette Sydney, LLB LEC CAMLFC CFRMP the first Online Lawyer based in Trinidad and Tobago. I specialise in Corporate Law and Financial Crimes.

http://asydneygroup.com

CONNECT WITH ME: Email: asydneysolutions@gmail.com

Blog: https://sydneygroupblog.wordpress.com/

Linked In: https://tt.linkedin.com/in/antoinette-sydney-77093550

Instagram: @asydneygrouptt

Facebook: https://www.facebook.com/sydneygrouptt/

Youtube: https://www.youtube.com/channel/UC8-sUa8WMDJM8w5_Q3nhQ5w

I am a Certified Professional in the following areas:

Taxation;

Corporate Training;

Anti-Money Laundering and Financial Crimes;

Fraud Risk Management;

Graphic Design.

Get my Ebooks now!!!  only $100TTD !

Payment through Paywise and Paypal!

Ebooks on Sale:

How to Register a Sole Trader;

How to De-Register a Sole Trader;

How to Register a Partnership;

How to Change from a Sole Trader to a Limited Liability Company Trinidad;

How to Dissolve a Limited Liability Company;

How to Incorporate a Limited Liability Company

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