Summary: Booz Allen Hamilton provided essential technical assistance through a program to bolster the resiliency of an Asian financial system. As a result, the country continued to experience economic growth but its financial markets became tougher for criminals and terrorists to exploit.
Client Challenge: The country lacked a modern legal and institutional framework compliant with post-9/11 international requirements for detecting and prosecuting Anti-Money Laundering/Counter-Terrorist Financing (AML/CTF) cases. Additionally, the government agencies responsible for AML/CTF crimes were hampered by a lack of cooperation and collaboration. As a result, the country ended up on the Financial Action Task Force's (FATF) list of non-compliant countries.
How Booz Allen Helped: Booz Allen wrote a comparison study on the practice of establishing a predicate offense as part of a money laundering prosecution, comparing this government to other countries, and developed a case study of a major international AML prosecution for the country’s leading law enforcement official.
Booz Allen also developed a guidebook on standardized financial investigative techniques for the government agencies involved in AML/CTF cases and worked with each to help incorporate best practices. As a follow-on, Booz Allen standardized the procedures for the preparation and use of suspicious transaction reports (STR) from the Financial Intelligence Unit (FIU) to police to prosecutors for use in court.
Results Achieved: As a result of this technical assistance program, the country was removed from the FATF list of non-compliant countries within the program’s first year.
Booz Allen’s comparison study was actively used by the government agencies during deliberations on whether state prosecutors must establish a predicate offense under the country's AML law. The case study proved instructive to law enforcement and provided them with guidance for complex cases. The government agencies incorporated several of the best practices highlighted in the Booz Allen guidebook for money laundering prosecutions and government prosecutors have used it as a practical investigative/trial tool. The central bank now employs standardized steps in the STR process, resulting in consistency.
