Issue link: https://maltatoday.uberflip.com/i/1385129
maltatoday | SUNDAY • 20 JUNE 2021 13 COMMERCIAL based on internally established criteria. For the STRs that fulfil these criteria, we carry out an in- depth analysis and once this is concluded we determine wheth- er or not there is a reasonable suspicion of money laundering or terrorism financing. If there is reasonable suspicion, an analyti- cal report is formulated and sent the police." A great deal of information is also shared with foreign and national stakeholders. As Ms Aisthorpe Gauci explains, "You could have a situation where, for example, a report raises a cer- tain level of suspicion but it is more appropriate or applicable to share that report with another country, as opposed to our do- mestic police, and we carry out a lot of sharing of information in this sense." Mr Scicluna adds, "This is mostly determined based on a jurisdictional link. Sometimes we may receive an STR and the link to Malta is very remote. In these cases, we share the infor- mation with our foreign coun- terparts, who in turn, from feed- back received by the FIAU have achieved results because of the information shared by us." What the Intelligence Analy- sis Section looks for, Mr Sciclu- na explains, is not necessarily a significant monetary element in STRs but, whilst acknowledging amounts are taken into consid- eration, what is mostly impor- tant is the criminal element. With reports dealing with the financing of terrorism, for exam- ple, the actual monetary value of a suspicious transaction may not be all that high, but it is nonethe- less a very high priority report. Importance is also given to STRs where the underlying crim- inal activity is tax evasion. This gives rise to illicit gains made to the detriment of the country and its citizens, by diverting essen- tial funds away from necessary infrastructure, services, social benefits, education and health- care to mention just a few. In 2020, tax evasion was the main suspected predicate offense in 31% of the cases reported. The FIAU does its part to pre- vent the laundering of such gains and provides intelligence to the police not only to investigate the money laundering aspect but al- so, where the amount of evaded tax is significant, to enable them to take criminal action against whoever has evaded the pay- ment of tax. "We receive all kinds of infor- mation from multiple stakehold- ers, and we need to filter out the most important STRs – those in which we determine there is a reasonable suspicion of money laundering or terrorism financ- ing." Mr Scicluna elaborates further by explaining how, "Terrorism financing is even more diffi- cult to ascertain than money laundering because with mon- ey laundering the source of the funds is normally illegitimate, whereas with terrorism financ- ing it can be a legitimate source used for illegitimate purposes." In addition to the receipt and handling of suspicious reports, the section is also tasked with a number of other roles including the processing of national and international requests for infor- mation with stakeholders such as foreign FIUs, the Malta Gaming Authority, the Malta Financial Services Authority, the Com- missioner for Voluntary Organi- sations, and the Sanctions Moni- toring Board amongst others. It additionally conducts strate- gic analyses based on informa- tion held or obtained by the sec- tion. Depending on the nature of the analyses, some are shared publicly while others are shared with the relevant stakeholders. entails and why it pays to get it right The FIAU's Head of Intelligence Analysis Ruth Aisthorpe Gauci and Senior Manager William Scicluna