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a competence almost exclusively carried out   over five years. Here, it's very different: we   elements, we send a report to the courts and
          by the SICCFIN.                     don't expect a country to put everyone on   the public prosecutor's office.
          SP: To illustrate this cooperation, we are in   the gallows in one year! On the other hand,   Eric Bergesi : International cooperation
          the process of acquiring a tool, along with   it will be necessary to show that cases are   between FIUs is carried out via the Egmont
          the Police Department (DSP), to analyse the   very advanced in terms of resolution, to show   group . We are therefore subject to common
                                                                                        *
          movements of funds in blockchain, from   international cooperation and that we have   exchange rules, supplemented by bilateral
          2024. In real terms, we will be able to check   advanced by two or three squares on the   agreements with other jurisdictions. The FIU
          whether an association which collects funds   board on all subjects - and that the dynamic   has the ability to question its counterparts to
          in Bitcoin for a just cause does not actually   is beyond doubt.         gather intelligence wherever it is located. At the
          fund Al Qaeda. We have built a partnership                               same time, we receive more than 100 requests
          with the DSP to align our methodologies and   Is the AMSF the Principality’s corruption   each year for clarification on accounts, a
          speak the same language. The objective is   representative?              natural or legal person, a transaction, or a
          also to save 30% of time in processing files.  LD: Corruption is an important undercurrent   property. For example, if a foreign FIU tells us
                                              of money laundering, second only in Monaco   that it has received reports about company X
          How do you see the future for the Moneyval   to fraud in terms of threat. Monaco has not   domiciled in Monaco, it can ask us if we have
          and Financial Action Task Force (FATF)   yet ratified or signed the Merida Convention.   information about it. We have the ability to get
          monitoring?                         This step will lead to the establishment of an   closer to the Business Development Agency
          LD: First step, Monaco must produce a report   anti-corruption agency which does not exist to   (DDE) and we can then analyse information
          for the FATF, the Post Observation Period   date. At the AMSF, in the near future we will be   on the actual beneficiaries, for example - and
          Report (POPR). This is the report resulting   setting up training and awareness raising on   vice versa. We therefore provide some insight.
          from the observation period, written by the   corruption in particular. However, this is not   If there is a criminal element, the information
          country's authorities. Monaco was placed   the most immediate area of concern, even if   passes through the judicial channel.
          under monitoring by the FATF in March 2023,   we must make progress in the coming years.
          following the report by Moneyval, which is                               Are you in great demand?
          the armed wing of the FATF for the Council of   Are your checks unexpected?  EB: In Monaco, there are still many people who
          Europe (a mini FATF in a way). We therefore   SP: We generally give notice the week before,   have accounts without being resident here.
          had a period of one year to report what was   mainly to ensure that the establishment will be   We are therefore in great demand. In some
          done following Moneyval's recommendations.   able to receive us. What is new in bank controls   countries that do not have this characteristic,
          In summary, over 100 pages, the authorities   is the possibility of using FICOBAM beforehand.   we are much less so than in Monaco. The
          will have to explain what has been put in place.   However, if accounts are reported to us with   requests received are very varied but mainly
          Following this report, the FATF will ask us   false information, we will be required to identify   European. The spectrum is, however, very
          questions in writing and in May 2024 it will be   them and sanction them. A textbook case that   broad.
          time for the vital viva exam. Finally, in June,   we have never encountered and that we do not
          Monaco's case will be examined during the   wish to encounter: a bank which voluntarily   How much of this information arises from
          FATF plenary.                       conceals 100 account lines out of 100,000. In   legal proceedings?
                                              this case, we would observe and sanction the   EB: It is very difficult to answer that question
          This is when we will know if Monaco will   establishment via the Sanctions Department   because there is a time lag between the
          be on the grey list. Your prediction? How to   of the AMSF. We have to be uncompromising.  suspicious transaction reports received, the
          avoid this grey list?                                                    reports sent to the prosecuting authorities
          LD: Anything is possible. Above all, we must                             and the legal proceedings initiated on the
          demonstrate that we have not just repainted the                          basis of them. In 2022, the number of releases
          facade but that, on the contrary, everything that                        corresponds to 11% of suspicious transaction
          has been done places us on a trajectory, that                            reports received; but this is only a matter of
          there is a fundamental desire and a strategy.                            proportion, because if a declaration reaches
          The important thing is also to show that this                            us, it is not uncommon that it only contributes
          desire is shared by the public and private                               to a transmission to the judicial authorities
          sectors. Our meetings, practical guides and  © Michael Alesi / Direction de la communication  years later. It is often only in the light of
          webinars with remarkable audience results                                several facts or pieces of information that it
          show that we have succeeded in getting   Eric Bergesi, Cellule de Renseignement Financier  is possible to produce a report. However, the
          professionals on board. This public/private   Financial Intelligence Unit  trend in recent years has been upwards and
          partnership has been built to last and we will                           the improvement in the quality of suspicious
          have to convince our evaluators of this.  In terms of international cooperation, what   transaction reports that we are targeting,
                                              goes through the FIU or the justice system?  thanks to goAML, will undoubtedly make it
          To show effectiveness, will it also be   LD: The FIU is the receptacle for everything to   possible to increase their number.
          necessary to show sanctions and convictions   do with suspicious transaction reports from
                                                                                    The  Egmont  Group  is  an  international  organisation  whose
          for money laundering?               the private sector. Its work is intelligence. Once   * mission is to combat money laundering and the financing of
          LD: An evaluation of Moneyval takes place   we have determined or noted the probative   terrorism.  To  this  end,  it  sets  up  training  and  mechanisms
                                                                                   intended to strengthen FIU cooperation on a global scale.
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