In this edition, Mr. Justino SA, President of the Financial Intelligence Unit (FIU) of Guinea-Bissau, presents the money laundering and terrorist financing risks specific to his country, and the work undertaken by his FIU to tackle them. He also talks about OCWAR-M’s support for the FIU’s application to join the Egmont Group.
- Can you tell us about the ML/FT risks in Guinea-Bissau and the efforts made by your FIU to mitigate them?
The results of the National Risk Assessment (NRA) of money laundering and terrorist financing (ML/FT) carried out in 2020 by the country, which was based on a factual analysis and on the data collected, showed that the risk of money laundering in Guinea-Bissau is high, while that of terrorist financing is low to medium.
Several factors can explain this increased vulnerability, such as the porosity of the land borders or the difficulties to control the country’s island areas, which facilitates illicit financial flows.
Prosecutions for underlying offences, which were likely to lead to ML-related prosecutions, were not proactive enough to trigger a parallel financial investigation.
The analysis of the results of the assessment of the national AML control factors and the overall vulnerability to ML of the main financial sectors places the national vulnerability at a high level. This high level of overall vulnerability to ML is mainly due to deficiencies in the political, economic, social and technological fields.
With regard to ML/FT risks, they depend on the type of activity prevailing in a given sector. In general, the sectors most likely to be used for ML/TF purposes are non-profit organisations, legal professions and the banking sector. On a national scale, the ML threat is materialised by greater underlying offences: some offences are committed inside the country, but others are committed outside, and still have an impact on our territory.
Data collected by the NRA has repeatedly revealed the presence of suspected terrorists and sleeper cells of terrorist organisations operating in the West African sub-region on the territory of Guinea-Bissau. We have information on Guinean nationals who have been recruited by a cell and trained in other countries of the sub-region. However, no terrorist acts or financing of terrorism cases have been recorded in the country. Based on these elements, the overall threat of TF in Guinea-Bissau has been assessed as medium to low.
The overall vulnerability to TF is mainly determined by factors such as the level of criminalisation of terrorist financing, the country’s capacity to investigate, prosecute and convict those who finance terrorism, the effectiveness of the implementation of targeted financial sanctions, and the contextual factors of Guinea-Bissau’s vulnerability to TF, discussed above.
Based on the findings of the NRA, the FIU developed an action plan to mitigate the identified risks. This plan was developed with the support of the Government and technical and financial partners, including UNODC, and its implementation is already underway.
- OCWAR-M supports your application for the Egmont Group. Can you tell us about the work done and the status of your application?
In the framework of our application to the Egmont Group, OCWAR-M’s support contributed significantly to the achievement of the following results by FIU:
- Updating of the decree establishing the FIU
- Adoption of FIU‘s internal rules of procedure
- Effective administrative and financial autonomy of the FIU
- Preparation and adoption of the FIU internal and external security policy and procedures
- Implementation of the strategic analysis
In this application process, we worked on meeting the necessary requirements and then formalised the application file, which was duly sent to the Egmont Group.