Page 96 - ACAMS-Today-V20N3

[ STAFF NOTES ]
The AML investigation will distinguish the “normal” and “usual” wire remittances to the Philippines from the potential instances where the customer may have paid for CSAE using wire remittances. A SAR should be filed by the bank setting out the data analytics and the AML investigation that was undertaken.
Case study 2: Detect and report potential terrorist financing
From May to October 2017, Marawi, Philippines’s principal Islamic city, was besieged by hundreds of heavily armed local and foreign gunmen with the intention to establish a Southeast Asian base for the Islamic State group. In the five months of house-to-house fighting between troops and the Islamists from the Abu Sayyaf and Maute groups, large parts of the southern city were destroyed and about 1,200 people were killed.5
The Maute network analysis
In 2018, a multilateral analyst exchange program (MAEP) was undertaken among the FIUs of the Philippines, Australia, Indonesia and Malaysia.6 Initially, the aim of the MAEP was to determine the financing related to the Maute Group. The focus expanded to identify and understand the flow of funds, fighters and material support to the Maute Group and associated groups in the Philippines in relation to the 2017 Marawi siege. The MAEP identified associations with other international terrorist groups, financiers and foreign terrorist fighters including a prominent financier. It also identified probable modes of terrorist financing and money movement channels, including remittance agencies and the use of hawalas.
The data analytics by a bank
A retail bank with a sizeable remittance activity with the Philippines could undertake an analysis of its outgoing wire remittances to the Philippines by running a data request based on the following criteria:
• Defined time scope: May-October 2017 plus two months before and after
• Defined types of wire remittances: All outgoing wire remittances to the Philippines from retail customers7 with one of the following address attributes in the beneficiary information:
—— City: Marawi
—— Province: Lanao del Sur
—— Blanks in address fields for city,
province and country
• Defined amount: Equal to or less
than $1,000 (single or aggregate)
• Defined keyword search in Field 70/
purpose of the MT103s such as:
—— Support —— Donation —— Gift
—— Freedom —— Funds
AML investigation
The extracted data is first reviewed and then the information is added to complete the wire remittance infor- mation. For a blank or incomplete beneficiary address, the retail bank can determine if the beneficiary address is in Marawi or its province and not elsewhere in the Philippines (e.g., with reference to the location of the beneficiary bank).
The completed data is then reviewed against the retail bank customers’ profiles on file. A quick counterparty check is also undertaken to identify if any of the beneficiaries are operating as remittance agencies in the Philippines. Please refer to Table 2 for a list of scenarios warranting further review.
96 [ JUNE–AUGUST 2021 ]
The AML investigation will distinguish the “normal” and “usual” wire remittances to the Philippines from the potential instances where the customer may have paid for CSAE using wire remittances