Financial Intelligence / Crime

Summary

A request for financial crime statistics, budget allocations, and staff numbers was partially fulfilled by the Isle of Man Financial Intelligence Unit, which provided detailed Suspicious Activity Report data for late 2018 but withheld current asset values and 2019 budget figures.

Key Facts

• The FIU does not hold data on the value of suspected criminal assets linked to civil forfeiture cases, referring the requester to the International Co-operation and Asset Recovery Team.
• Budget allocation for 2019/20 was withheld under section 41 of the Act as it was scheduled for future publication on 19th February 2019.
• Detailed statistics for Suspicious Activity Reports (SARs) were provided for Q2, Q3, and Q4 of 2018, totaling 1,391 reports.
• The majority of SARs in Q3 2018 originated from Virtual Currency Services (189 reports) and Banks/Building Societies (166 reports).
• Links to 'Pink Books' containing budget breakdowns for 2017/18 and 2018/19 were provided.

Data Disclosed

• 1391
• Q2 2018
• Q3 2018
• Q4 2018
• 387
• 554
• 450
• 189
• 166
• 164
• 162
• 19th February 2019
• 2017/18
• 2018/19
• 2019/20
• section 41

Exemptions Cited

• Section 41 of the Act (Information intended for future publication)

Original Request

Dear Financial Intelligence Unit I am writing to request information under the Freedom Of Information Act My request is regarding how the Isle of Man (and other Crown Dependencies) are tackling financial crime. Specifcally, can you please provide details of: What is the value of suspected criminal assets linked to civil forfeiture cases currently being pursued by the Financial Intelligence Unit/ICART? How much money has been allocated to the unit for 2019, and in the previous three years? How many members of staff are currently employed to pursue suspected criminal assets which have been frozen? In addition, can you please provide the most recent break down of the number of Suspicious Activity Reports received by the Unit, by quarter? (Including Q2, Q3 and Q4 2018 The most recent I can find online provides a breakdown from Q2 2017 ' Q1 2018 - https://www.gov.im/media/1363854/fiu-annual-report-2017-18.pdf )

Data Tables (4)

Data Tables (reformatted)

Full Response Text

2018 Q2 / Q3 / Q4 Statistics – Legislation under which disclosure was received.
Legislation Name Count Qtr2 387 Anti-Terrorism and Crime Act 2003 (Terrorism) 3 Financial Intelligence Unit Act 2016 (section 24) 103 Proceeds of Crime Act 2008 (All Crimes) 281 Qtr3 554 Financial Intelligence Unit Act 2016 (section 24) 241 Proceeds of Crime Act 2008 (All Crimes) 313 Qtr4 450 Anti-Terrorism and Crime Act 2003 (Terrorism) 2 Financial Intelligence Unit Act 2016 (section 24) 168 Proceeds of Crime Act 2008 (All Crimes) 280 Grand Total 1391

Disclosing Institution Type Disclosing Institution Type Count Qtr2 387 Accountant 4 Bank/Building Society 164 Estate Agent 1 Financial Advisor 6 Investment/Fund Manager 7 Lawyer 7 Life Assurance/Insurance 33 Money Service 6 Offline Gaming 4 Online/eGaming 89 Post Office 1 Regulator 3 TCSP's 22 Virtual Currency Service 40 Qtr3 554 Accountant 8 Bank/Building Society 166 Estate Agent 1 Financial Advisor 9 Investment/Fund Manager 11 Lawyer 8 Life Assurance/Insurance 31 Money Service 2 Online/eGaming 93 Other 1 Payroll Service 1 Regulator 1 TCSP's 33 Virtual Currency Service 189 Qtr4 450 Accountant 5 Bank/Building Society 162 Estate Agent 2 Financial Advisor 18 Investment/Fund Manager 12 Lawyer 10 Life Assurance/Insurance 32 Money Service 4 Online/eGaming 43 Post Office 1 Regulator 5 TCSP's 36 Virtual Currency Service 120 Grand Total 1391

PO Box 51 Douglas Isle of Man IM99 2TD Tel: +44 (0)1624 686000 Email: fiu@gov.im Website: www.fiu.im

Our ref: 675471

28th January 2019

Dear ##

We write further to your request which was received on 9 January 2019 and which states:

"Dear Financial Intelligence Unit

I am writing to request information under the Freedom Of Information Act

My request is regarding how the Isle of Man (and other Crown Dependencies) are tackling financial crime.

Specifcally, can you please provide details of:

What is the value of suspected criminal assets linked to civil forfeiture cases currently being pursued by the Financial Intelligence Unit/ICART?

How much money has been allocated to the unit for 2019, and in the previous three years?

How many members of staff are currently employed to pursue suspected criminal assets which have been frozen?

In addition, can you please provide the most recent break down of the number of Suspicious Activity Reports received by the Unit, by quarter? (Including Q2, Q3 and Q4 2018

The most recent I can find online provides a breakdown from Q2 2017 ' Q1 2018 - https://www.gov.im/media/1363854/fiu-annual-report-2017-18.pdf )

Kind Regards, ##"

While our aim is to provide information whenever possible, in this instance the Financial Intelligence Unit (FIU) does not hold some of the information that you have requested.
Please find responses to your questions raised, as follows: Q1. What is the value of suspected criminal assets linked to civil forfeiture cases currently being pursued by the Financial Intelligence Unit/ICART?
R1. The Financial Intelligence Unit (FIU) does not hold this information. This information will be held by the International Co-operation and Asset Recovery Team who can be found at:

www.gov.im/about-the-government/offices/attorney-generals-chambers/prosecutions- division/international-co-operation-and-asset-recovery-team/

HM Attorney General Attorney General’s Chambers 2nd Floor Belgravia House Circular Road Douglas Isle of Man IM1 1AE

Telephone: +44 1624 685452

Q2. How much money has been allocated to the unit for 2019, and in the previous three years?
R2. While our aim is to provide information whenever possible, in this instance the information in relation to the budget allocation for 2019/20 is exempt from disclosure under section 41 of the Act as it is held with a view to being published at a future date. This information is due to be published on 19th February 2019 and in all the circumstances it is reasonable that the information be withheld from disclosure until that time.
A full breakdown of budget figures for 2017/18 and 2018/19 can be found in the ‘Pink Books’ published by Isle of Man Government and links to the documents are detailed below for your convenience:

https://www.gov.im/media/1355349/isle-of-man-budget-2017-18-v2.pdf

https://www.gov.im/media/1360554/pink-book-final-2018.pdf

Q3. How many members of staff are currently employed to pursue suspected criminal assets which have been frozen?
R3. Please see response to Q1.

Q4. In addition, can you please provide the most recent break down of the number of Suspicious Activity Reports received by the Unit, by quarter? (Including Q2, Q3 and Q4 2018 R4. Statistics, broken down by Legislation and Sector for Q2, Q3 and Q4 2018 are attached to this response. Please quote the reference number 675471 in any future communications.

Your right to request a review

If you are unhappy with this response to your freedom of information request, you may ask us to carry out an internal review of the response, by completing a complaint form and submitting it electronically or by delivery/post.

An electronic version of our complaint form can be found by going to our website at https://services.gov.im/freedom-of-information/Review . If you would like a paper version of our complaint form to be sent to you by post, please contact me and I will be happy to arrange for

this. Your review request should explain why you are dissatisfied with this response, and should be made as soon as practicable. We will respond as soon as the review has been concluded.

If you are not satisfied with the result of the review, you then have the right to appeal to the Information Commissioner for a decision on; 1. Whether we have responded to your request for information in accordance with Part 2 of the Freedom of Information Act 2015; or 2. Whether we are justified in refusing to give you the information requested.
In response to an application for review, the Information Commissioner may, at any time, attempt to resolve a matter by negotiation, conciliation, mediation or another form of alternative dispute resolution and will have regard to any outcome of this in making any subsequent decision. More detailed information on your right to a review can be found on the Information Commissioner’s website at www.inforights.im. Should you have any queries concerning this letter, please do not hesitate to contact me. Further information about freedom of information requests can be found at www.gov.im/foi. I will now close your request as of this date.

Yours sincerely