FIA U ANN U AL REPOR T 2011 - Financial Intelligence Analysis Unit

A comparative table placing these figures alongside the
corresponding numbers registered in previous years is
marked as Table 1 below. At face value, such an increase
in the receipt of STRs might seem to suggest a marked rise
from the previously stable level of STRs filed during the
preceding years which averaged 68 STRs per year during
the period between 2003 and 2010. Nevertheless, it should
be noted that the sharp rise in STRs received by the FIAU
during 2011 is not cross-sectoral. Rather, the increase is
mainly attributable to a sudden wave of disclosures made
by remote gaming companies which, it should be noted, are
not covered by the definition of “subject person” under the
PMLFTR but are required to report ML/FT suspicions by the
standard licence conditions issued by the LGA. Indeed, STRs
filed by this category of persons during the year amounted
to 37, which is a staggering rise in comparison to the figure
of only four STRs filed by remote gaming companies during
2010.
Table 1: STRs and cases (2002 – 2011)
2002 2003 2004 2005 2006 2007 2008 2009 2010 2011
STRs made by subject persons 11 76 46 75 78 63 69 63 73 107
Cases subject to analysis following
STR submission
11 58 43 62 72 55 67 53 55 91
Cases subject to analysis on the basis of other
information received by the FIAU
- 1 2 5 10 13 3 13 8 11
Total number of cases subject to analysis 11 59 45 67 82 68 70 66 63 102
The 37 disclosures by remote gaming companies were made
by seven different companies operating within this sector. It
is worth noting that one particular remote gaming company
filed a total of 23 STRs which represents 62% of the STRs
received from the remote gaming sector and 21% of the
total STRs received by the FIAU in 2011. As explained in
more detail later on in this report, the quality of reporting
Chart 1: Annual STR disclosures (1995 – 2011)
16
120
100
80
60
40
20
Annual Report 2011
0
1995
1996
1997
1998
1999
2000
2001
2002
in this sector is still not as developed as in other sectors and
the incidence of premature reporting and cases where the
suspicion of ML/FT does not have a clear basis was relatively
high. Therefore any conclusion that the increase in the
number of STRs from operators within this sector necessarily
implies an increase in risk of ML/FT is clearly unfounded.
Indeed, the only risk factor identified by the FIAU to have
contributed to the rise in the number of STRs submitted by
operators within this sector is the increase in the use of prepaid
cards as a method of payment for the deposit of funds
to access remote gaming services. This interesting trend
emerging from an appreciable number of STRs is explained
further in the section dealing with typologies on page 23 of
this report.
For comparative purposes, Chart 1 presents two data series
to illustrate the effect the large number of disclosures made
by remote gaming companies has had on the total figures
for 2011. Interestingly, STRs filed by all persons and entities
other than remote gaming companies during 2011 amounted
to 70, which is just one STR more than the comparable figure
for the previous year. The chart covers the period from 1995
to 2011, thus including the initial eight-year period during
which subject persons were required to make disclosures
directly to the Police.
2003
Total STRs received (including Remote Gaming Companies) STR Reports per year (excluding Remote Gaming Companies)
2004
2005
2006
2007
2008
2009
2010
2011