Agencia worked on delivery of a project, one Component of which assisted in meeting recommendations which originated with Financial Action Task Force (FATF) and Moneyval reviews. Bosnia and Herzegovina (BiH) had been placed in the FATF High Risk Country list, which can prevent the free flow of goods and funds in and out of the country. The implications to BiH were enormous.
The Component focused on tackling high level corruption, organised crime and money laundering, specifically looking to implement the recommendations of the European Commission Peer Review, the Organisation for Security and Co-operation in Europe (OSCE) and the Group of States Against Corruption (GRECO) recommendations which followed the FATF and Moneyval reviews. Countering corruption, interrupting illicit money flows and money laundering activities are key to addressing the relative ease with which organised crime uses countries with weak rule of law infrastructures to move illicit cash and goods across borders.
The overall project team was an alliance between Agencia, PwC and Lucid Linx. PwC provided project leadership and project management support, and primed the contract; Agencia provided the Project Manager, David Greensmith, and international subject matter expertise; Lucid Linx, a Bosnian consultancy, provided on-the-ground leadership for each of the project's three components. Agencia’s Director for Serious Organised Crime, Tim Holt, and a Senior Expert, Angus Naismith worked with local experts from Lucid Linx to ensure the technical implementation of the anti-corruption Component: both Tim and Angus are former senior financial investigators with the UK’s National Crime Agency and have held policy level posts, working extensively overseas in differing regulatory structures.
The team completed a needs analysis examining BiH’s capacity to manage financial investigations. The State Prosecution Service (SPO) and the State Investigation and Protection Agency (SIPA) needed to double its FI personnel, to meet the recommendations from FATF. Working with the SPO and SIPA, the team designed a project to develop organisational capacity and personnel to international FI standards with local experts enabling a solution that was fit for purpose within BiH and not a ‘one size fits all’ solution. The transformational programme developed the capacity to effectively complete financial investigations, including managing complex FI cases, to seize, freeze, manage and dispose of assets, countering illicit financial flows with a focus on terrorism and organised crime.
The Component enables a transfer of knowledge to both policy makers and implementers through stakeholder engagement and training. The team are writing a manual of guidance and have worked with Sarajevo University to deliver training through a focussed Winter School on financial investigations. This work will be further supported through an online training programme which is being developed for newly appointed prosecutors or investigators. The capacity of the SPO and SIPA has doubled in size and is now working to international FI standards. The sustainability of the Component is built into future support through the manual, continuing engagement with Sarajevo University and the online training. BiH has been taken off the FATF High Risk Country watch list, and has met most of the recommendations from the country reviews, but work is still required across the region to ensure international standards in FI are met.
The project is being funded by HMG’s Conflict Stability and Security Fund.
Resulting from direct approaches by national Governments, Agencia has developed similar projects in East Africa and the Caribbean. In November 2020, Agencia was also invited to chair a 3-day conference in Malaysia, covering Corporate Crime Intelligence focusing on financial crime and the fight against corruption.
