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

the Unit’s Financial Analysis Section during the last quarter
of 2010.
The figures indicating the outcome of the STRs and cases
analysed during the period from 2003 to 2011 as well as the
number of ongoing analyses as at the end of each year are
outlined in Table 4 on the previous page, which is divided
into three distinct sections. The first section provides data
on STRs and cases where an STR was received by the FIAU,
the second section provides figures of cases where an
analysis was carried out based on information in possession
of the FIAU that did not originate from a disclosure, 4 while
the third section amalgamates all the data.
Table 4 reveals that a total of 24 STRs received by the FIAU
resulted in the dissemination of information to the Police for
further investigation during 2011. These STRs gave rise to 18
different cases, half of which originated from STRs filed by
credit institutions, while the remaining nine cases originated
from STRs filed by seven different categories of reporting
entities. One other case was referred to the Police which did
not originate from the submission of a STR. Further details
on the cases forwarded to the Police are provided in the
next section of the report dealing with suspected predicate
offences.
4 It should be pointed out that in those cases where an analysis of a case is carried out on the basis of information in possession of the FIAU, although a
STR is not actually received in these cases, for statistical and record-keeping purposes these cases are recoded as FIAU-generated STRs.
5 The data for 2011 includes cases referred to the Police which did not result from STRs. The corresponding data for the period from 2003 to 2010 only
includes cases disseminated to the Police further to a receipt of a STR.
22
Annual Report 2011
The percentage of STRs which resulted in the dissemination
of information to the Police during 2011 as a proportion of
the STRs made experienced a significant drop in 2011 when
compared to the previous years with the ratio falling from
44 percent in 2010 to 23 percent in 2011. The main factor
contributing to this reduction was clearly a large proportion
of STRs originating from remote gaming companies which
did not have a strong basis of suspicion and which, upon
further analysis, did not lead to a reasonable suspicion of
ML/FT.
Suspected predicate offence
Table 5 provides data on the suspected predicate offence
from which the proceeds of crime was suspected to have
derived in relation to those cases forwarded to the Police
during the year under review on suspicions of ML/FT.
Similar patterns were observed to those noted in 2010
in that the suspected underlying criminal offence varied
considerably and there was no single offence that stood
out particularly. The foremost suspected underlying offence
during 2011 was corruption taking place in countries outside
Malta, with four cases being referred to the Police during
the year where the suspicion was laundering of funds
Table 55 : Suspected predicate offences in cases referred to Police on suspicion of ML/
FT FT (2003 – 2011)
Suspected Predicate Offence 2003 2004 2005 2006 2007 2008 2009 2010 2011 Total
% of
Total
Drug Trafficking 2 4 – 4 5 7 1 2 1 26 13%
Fraud 2 4 3 2 1 – 5 6 3 26 13%
Forgery – 1 1 3 – – – – – 5 3%
Usury 1 2 2 5 1 4 – – 1 16 8%
Undeclared Income – 2 4 – – 4 – 1 2 13 7%
Unlicensed Financial Services 4 4 1 – 3 3 – 3 – 18 9%
Organised Crime 5 2 1 – 2 2 1 1 1 15 8%
Human Trafficking – – 1 – 1 2 – – – 4 2%
Theft – – 4 – – – – – 2 6 3%
Illegal Gambling – – 1 2 – 1 – – – 4 2%
Identity Theft – – – 2 1 – – – – 3 2%
Living off the earnings of Prostitution – – – 2 – – 1 – – 3 2%
Phising – – – – 1 – – – – 1 1%
Corruption – – – – – – – 1 4 5 3%
Unknown 2 1 3 1 6 16 7 4 4 44 23%
Total 16 20 21 21 21 39 15 18 18 189 97%
Funding of Terrorism 1 – 1 – 1 – 1 1 – 5 3%
Grand Total 17 20 22 21 22 39 16 19 18 194 100%