After three years of successfully training thousands of people on Anti Money Laundering and Counter Financing of Terrorism (AML-CFT), the AML-THB Project in the Greater Horn of Africa has come to an end. We are now transitioning into a new third phase, set up as an immediate next step to build on the positive gains that have been achieved. This third phase will consolidate the support provided to stakeholders in the Greater Horn of Africa region while also expanding to cover 18 new countries of East, Southern, Central Africa & Yemen. The project team is focused on launching the third phase of this initiative and will soon be providing new support to the region’s stakeholders in countering Illicit Financial Flows generated by Transnational Organised Crimes and Terrorist Groups.
After three years of successfully training thousands of people on Anti Money Laundering and Counter Financing of Terrorism (AML-CFT), the AML-THB Project in the Greater Horn of Africa has come to an end. We are now transitioning into a new third phase, set up as an immediate next step to build on the positive gains that have been achieved. This third phase will consolidate the support provided to stakeholders in the Greater Horn of Africa region while also expanding to cover 18 new countries of East, Southern, Central Africa & Yemen. The project team is focused on launching the third phase of this initiative and will soon be providing new support to the region’s stakeholders in countering Illicit Financial Flows generated by Transnational Organised Crimes and Terrorist Groups.
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Financial intelligence a powerful tool in successful prosecution of organised crime

By Neil Bennett

It cannot be gainsaid that Trafficking in Human Beings (THB) is a dreadful and abhorrent crime. One that is predicated on the motive of profit by one human being exploiting another. This so-called trade is conducted by organised crime gangs that have recognised that THB (and Smuggling of Migrants) is currently a high profit, low risk endeavor.

The application of every appropriate investigative tool should be an obligation, not a choice. Any successful approach focused on the identification and prosecution of organised crime groups, as well as their supporters and networks, requires a multi-faceted investigation strategy. A key strand of that strategy needs to focus on the identification and acquisition of financial intelligence, financial information and in due course, financial evidence. Quite simply, the Financial Action Task Force (FATF) determines that a ‘financial investigation means an enquiry into the financial affairs related to criminal conduct’.

My own experience, leading complex financial investigations on terrorist groups, terrorists and extremists over two decades, leaves me in no doubt that financial intelligence and financial evidence is an extremely powerful tool. Its application by professional investigators, prosecutors and other relevant agencies should be a cornerstone of every proactive or reactive investigation into criminal conduct.

Equally, an effective financial investigation needs to be underpinned by an effective training and the development of a national curriculum that reflects the needs and requirements of all stakeholders in the process, particularly the partnership between investigators and prosecutors.

The Importance of building relationships, understanding and trust amongst Law enforcement agencies in-country and across borders. 

From a personal perspective, I am pleased to have been associated with the previous project -EU ‘Anti-Money Laundering and Countering the Financing of Terrorism in the Greater Horn of Africa Region’ (AML-CFT in the GHoA) – which concluded in 2019 prior to the inception of this project – ‘Disrupting Criminal Trafficking and Smuggling networks through increased ‘Anti-Money Laundering and Financial Investigation capacity in the Greater Horn of Africa’ (AML-THB in the GHoA).

There are several features of both the AML-CFT and AML-THB projects which I believe are unique and for which the key elements of style, method and content of delivery have benefited from a significant element of continuity from one project to the next. Those facets are not the data-driven metrics of perceived achievements, but rather a recognition that organisational change is also dependent on recognising the benefits of a collective understanding, a positive learning culture, as well as a focus on sharing – both information and experience in equal measure. A focus on these elements, going beyond the numbers, has and is a strength of the AML-THB project to deliver a more informed and dynamic response.

As a regional project, one of the key challenges is to blend and adjust delivery to meet the subtle differences across the GHoA in domestic culture, legal frameworks, processes and indeed how the crime manifests itself in any particular jurisdiction across the region. The basis for any common or regional approach has to be a shared understanding, not just in terms of the activities and nuances of the behaviour of organised crime groups but also of our ability to effectively apply our capabilities to deal with criminal activity.

Understanding is defined as: the perception and interpretation of a particular situation in order to provide the context, insight and foresight required for effective decision-making. Understanding helps us to make decisions; it also helps us to manage any associated risks and any subsequent effects. As such, part of any project needs to recognise that we need to build and support the pathway from individual to collective to common understanding.

The goal is to achieve a common understanding when countries, institutions, professions, communities and other groups cooperate for a purpose, in this case to counter THB.

Undoubtedly, different groups may have different kinds of collective understanding that involves potentially divergent interpretations of the problem and how to address it. Prior to the inception of the AML-THB in the GHoA in November 2019, the project team coordinated a series of project pre-kick-off meetings at Kenya School of Monetary Studies (KSMS) in Nairobi. A group of participants from diverse professions, representing each jurisdiction covered by the project, came together to build an initial ‘understanding’ across the project’s three specific objectives. I was proud to be involved in this process, not least to work with a group of professionals focused on developing a detailed response towards an understanding of how project-specific objectives should be visualised and delivered.

Importantly, the process also identified several overlapping strands that, if focused upon, would deliver benefit across the whole of the project as core themes. That collective work was then presented by different national representatives to senior representatives from Kenya, the European Union and Civipol.

The project has, at its core, a proactive approach to encouraging and easing the sharing of information. The process of ‘understanding’ depends on access to information and knowledge, but access is often problematic, particularly so in a regional project focused on a transnational criminal enterprise. Networking is important to generate understanding and offers significant benefits including the potential for greater objectivity, burden-sharing and innovation. Networking also serves to build trust and helps us identify common risks.

Successful networks combine the knowledge and experience of those that contribute and help to establish and maintain personal relationships. As part of the structure of the project, the aim has been to support the development of networks both naturally and through a deliberate process. A key driver of this project has been the mantra to keep fostering stronger partnerships, or if you like, ‘relationships, relationships, relationships’.

The training delivery that colleagues I and have supported is very much influenced by reflective learning. Reflection in a trusted environment is an opportunity to use a framework for examining experiences and using such as the basis to understand specific areas which may require improvement – getting ‘just a little bit better.

This approach to learning is firmly situated in a ‘reflective cycle’ to give structure to learning from experiences. Given its cyclic nature, it lends itself particularly well to repeated experiences, allowing learning from things that either went well or didn’t go well. Knowledge and skills are critically important but as part of that process facilitating an opportunity for participants and groups to evaluate, analyse and form action plans to deal with similar situations in the future, or general changes that might be appropriate. Reflection is part of a learning cycle where others are drawn into the learning process giving meaning to experience. This approach embeds and encourages a learning culture, which includes the encouragement for participants to learn and reflect on their work, proactively influence strategy and process change. From the perspective of my own involvement and that of colleagues, it is clear that the AML-THB project has adapted to the challenges presented by the current pandemic to maintain momentum, engagement and deliver high-quality events.

For more information about this article and Neil Bennett, Please see Newsletter 009