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An external view of Labuan & Malaysia in the
Global AML context

Sam Gibbins
Director, International Compliance Association
Introduction


Born in UK, living in Singapore for nearly 4 years

Studied at King¡¯s College, University of London

Background in recruitment and sales/marketing

Spent 3 years working in the City (London)
before moving to Asia)
Introduction

International Compliance Association ¨C global body dedicated to the
professionalisation of compliance, AML and financial crime
prevention professionals

Offices in UK, Dubai, and Singapore. Regional operations in Russia
and Hong Kong

Localised training courses for AML offered in Malaysia. Compliance
coming soon¡­
Increasing Money Laundering Sophistication


Increasing global sophistication of money laundering

More difficulty in preventing money laundering?

Higher level of global scrutiny of jurisdictions and their money
laundering effectiveness; how effective are fines as deterrents?
Monday 19 November 2012
Left Foot Political
Blog, November 9 2012
Human Nature?
Increased Competition
Is Labuan a serious alternative?




Singapore, Hong Kong, Australia

Is Labuan seen as a ¡®layering¡¯ option?

FATF Members; perceived to have higher level of sophistication
Is Labuan a serious alternative?


Helping to become a more recognised player in the international
scene

Moving ahead of middle ground players, for example those in
Central/South America

Striving towards the ¡®Premier Centre status; is this achieved yet?
Business Times
(Malaysia),
13 July 2009
Importance of Shariah finance


Huge potential growth area into the future
¡®This is further evident in the increase of Islamic private funds in the Labuan IBFC
from USD 1.4 billion in 2007 to USD 2.8 billion in 2008; while in the same
period, the Islamic reinsurance business ¨C re-takaful ¨C saw gross contributions
increase by 48% to USD 162 million¡¯ (Labuan IBFC)

¡®There are currently six Islamic Banks and nine Islamic windows which
collectively reported an 87% increase in banking assets from 2009 to 2011¡¯
(Labuan IFC)
Do People understand AML in relation to Shariah
Finance?
Shariah Finance Watch Blog,
25 September 2012
Impact of linkage with Malaysia?


Inherent risk of being linked with Malaysia and all ¡®bad¡¯ news

How do people view the ability of financial services firms in Labuan
to verify procedures, documentation and information?

What is the risk of loss of doing business in Labuan?
Sanctions


How much of a threat does this pose here in Labuan?

Increasing evidence of sanctions breaches

Very negative impact in many different business
scenarios¡­
Reuters,
12 September 2012
Bruno Manser Fund,
4 June 2012
Sanctions and the PR Machine



People depositing their funds in Labuan do so because
they do not want to be attracting publicity

Higher international awareness of Labuan is a double
edged sword
Conclusions


Labuan's position on the borders of Asia and
Australasia provides ready access to and from the
World's fastest developing economies and also to the
greatest population densities on the planet

        Mondaq.com, 21 July 2011
        Callum Beaton
Conclusions



 Labuan must continue to build on it¡¯s strengths:
        Location
        Shariah finance
        Lack of global exposure
Conclusions



 Labuan is on the rise along with the rest of SE Asia

 MUST avoid the same fate of other jurisdictions with
 relation to the money laundering trap, and stay our of
 the headlines
Any questions?

  Thank You!

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Labuan conference presentation 1 - 19.11.2012

  • 1. An external view of Labuan & Malaysia in the Global AML context Sam Gibbins Director, International Compliance Association
  • 2. Introduction Born in UK, living in Singapore for nearly 4 years Studied at King¡¯s College, University of London Background in recruitment and sales/marketing Spent 3 years working in the City (London) before moving to Asia)
  • 3. Introduction International Compliance Association ¨C global body dedicated to the professionalisation of compliance, AML and financial crime prevention professionals Offices in UK, Dubai, and Singapore. Regional operations in Russia and Hong Kong Localised training courses for AML offered in Malaysia. Compliance coming soon¡­
  • 4. Increasing Money Laundering Sophistication Increasing global sophistication of money laundering More difficulty in preventing money laundering? Higher level of global scrutiny of jurisdictions and their money laundering effectiveness; how effective are fines as deterrents?
  • 6. Left Foot Political Blog, November 9 2012
  • 9. Is Labuan a serious alternative? Singapore, Hong Kong, Australia Is Labuan seen as a ¡®layering¡¯ option? FATF Members; perceived to have higher level of sophistication
  • 10. Is Labuan a serious alternative? Helping to become a more recognised player in the international scene Moving ahead of middle ground players, for example those in Central/South America Striving towards the ¡®Premier Centre status; is this achieved yet?
  • 12. Importance of Shariah finance Huge potential growth area into the future ¡®This is further evident in the increase of Islamic private funds in the Labuan IBFC from USD 1.4 billion in 2007 to USD 2.8 billion in 2008; while in the same period, the Islamic reinsurance business ¨C re-takaful ¨C saw gross contributions increase by 48% to USD 162 million¡¯ (Labuan IBFC) ¡®There are currently six Islamic Banks and nine Islamic windows which collectively reported an 87% increase in banking assets from 2009 to 2011¡¯ (Labuan IFC)
  • 13. Do People understand AML in relation to Shariah Finance?
  • 14. Shariah Finance Watch Blog, 25 September 2012
  • 15. Impact of linkage with Malaysia? Inherent risk of being linked with Malaysia and all ¡®bad¡¯ news How do people view the ability of financial services firms in Labuan to verify procedures, documentation and information? What is the risk of loss of doing business in Labuan?
  • 16. Sanctions How much of a threat does this pose here in Labuan? Increasing evidence of sanctions breaches Very negative impact in many different business scenarios¡­
  • 18. Bruno Manser Fund, 4 June 2012
  • 19. Sanctions and the PR Machine People depositing their funds in Labuan do so because they do not want to be attracting publicity Higher international awareness of Labuan is a double edged sword
  • 20. Conclusions Labuan's position on the borders of Asia and Australasia provides ready access to and from the World's fastest developing economies and also to the greatest population densities on the planet Mondaq.com, 21 July 2011 Callum Beaton
  • 21. Conclusions Labuan must continue to build on it¡¯s strengths: Location Shariah finance Lack of global exposure
  • 22. Conclusions Labuan is on the rise along with the rest of SE Asia MUST avoid the same fate of other jurisdictions with relation to the money laundering trap, and stay our of the headlines
  • 23. Any questions? Thank You!

Editor's Notes

  • #5: Increasing use of various technology to aid money launderers?Examples such as:
  • #8: Do deterrents work?Or will the money laundering criminals always find ways around the barriers you try and erect?Is this simply a case of human nature?
  • #11: Location helping to become a more recognised player in the global scene
  • #21: Global positioning is key and an essential component of Labuan¡¯s growth