The Gibraltar Financial Intelligence Unit (GFIU) has released its Annual Report which contains an overview of the work conducted by the unit during 2022. The report includes strategic analysis spanning from 2019 to 2022. Strategic analysis plays a crucial role to better understand the evolving methods and vulnerabilities exploited by criminals and terrorists. It can also assist in effective preventative measures that further help to mitigate risks and informs the development of future National Risk Assessments.
Writing in the Annual Report’s foreword, the GFIU’s Director, Edgar Lopez, reflects on the challenges the unit has been presented with during 2022 and how it has achieved results through innovation and technology. He further added, “We have learnt a lot during the FATF post observation period and we acted with agility to meet the recommendations. We took decisive steps to align our structure to meet demand and new challenges, particularly in strategic analysis and data quality analysis.”
The GFIU has leveraged technological advancements and new software applications to enhance internal processes, intelligence report productivity, and strategic analysis.
A significant milestone in the Report has been the successful establishment of the Financial Liaison & Intelligence Network (FLINT), Gibraltar's Public-Private Partnership aimed at combating Money Laundering, Terrorist Financing, and Proliferation Financing. This partnership has been further strengthened through a Memorandum of Understanding with the UK's Joint Money Laundering Intelligence Task Force (JMLIT+). This collaboration enhances cooperation, facilitates the exchange of information and intelligence, and harnesses collective knowledge and experience to create an inhospitable environment for criminals involved in serious and organised crime in both Gibraltar and the UK.
The Strategic Analysis Report highlights an increase in Suspicious Activity Reports (SARs), submitted by certain sectors, such as Banks and Trust and Corporate Service Providers (TCSPs), when compared to 2021. This increase may be attributed to the GFIU’s outreach program, Project Nexus, which recently won HMGoG’s Project Achievement Award. Additionally, the GFIU has expanded its workshops on various economic crime topics through an e-learning platform, boasting over 500 users.
Furthermore, there has been a noteworthy decrease in defensive reporting and an improvement in the percentage of SARs meeting the GFIU's standards. Money Laundering and Fraud persist as the most prevalent suspected criminal activities reported. Suspicion based on adverse open source information and inadequate due diligence or failure to provide due diligence, remain the leading grounds for suspicion.
The GFIU has also published its second 3-year Strategic Plan, which outlines the strategic objectives and priorities of the GFIU. It is based on four interconnected high-level priorities, known as the four E’s, which describe how it intends to achieve its vision. The plan, which has been developed in response to new challenges, also takes into account feedback from both public and private sectors.
Mr Lopez, commented in the Strategic Plan’s foreword, that, ‘the plan builds upon the current momentum shaped by the GFIU’s experience during Moneyval and the FATF processes’.
Minister for Justice, Samantha Sacramento MP, praised the high standard of the GFIU's work and its dedication to combating economic crime and expressed her satisfaction with its accomplishments in 2022, particularly in strategic analysis, international cooperation and outreach. She also recognises the achievements over the last 3 years through the GFIU’s strategic priorities and will continue to support the GFIU with its new road map.
The GFIU was established in January 1996 with the aim of facilitating the receipt, analysis, and dissemination of suspicious transaction reports or suspicious activity reports from financial and other institutions.
The two documents can be found on the following links:
Annual Report & Strategic Analysis 2022
Strategic Plan 2023-26