As I was running some of the ideas I had for this blog to one of my colleagues, she looked at me with consternation and said âJefferson, that is a no-brainerâ. The âThatâ being my specific intention to begin this blog by focusing on Recommendation 19 of the FATF 40 Recommendations. I smiled at her and retorted âAha my point exactlyâ.Â
You see, in CFATF land, and by that I mean, in the 30 Countries which make up the membership of this FSRB, it appears that this no-brainer Recommendation is receiving all the attention it âdeservesâ. Did you detect a hue of sarcasm in that statement?  Then let me re-phrase it because it is not my intention to use hints in order to make my point but rather to be as blunt and as straightforward as possible in saying that I believe that CFATF land has dropped the ball on this issue.
I donât blame any of them though, because the ball was thrown in such a way so that for the purpose of obtaining full compliance, even those Members who were deemed to have caught it, and were rated accordingly, seem lost to the fact that potentially Recommendation 19 has the potential to be one of the most important tools in the arsenal of all Regional Financial Intelligence Units.
The approach to the implementation of Recommendation 19 is simple and all a country has to do is âconsiderâ the feasibility of implementing a system of mandatory currency transaction reporting above a fixed threshold. Well it appears that this is a rather easy way to obtain a rating of C, or this is what many Members believe. Many of them have âconsideredâ and then concluded that such a system is in no way feasible. Let me repeat something I said earlier. I donât blame them. Are they not complying with the essential criteria of this no-brainer Recommendation?
Certainly they are. But wait, is it just me, with my law enforcement biases, which I have taken so many years to hone, or isnât there a bigger picture here? Arenât the Recommendations just guidelines that are to be adopted and adapted in such a way so as to achieve the common objective of preventing money laundering and terrorist financing? Well excuse me but the 3rd Round Mutual Evaluation Reports detail that for Recommendation 19 the adaptation of it is aimed at obtaining the âgoldenâ compliant rating.
So, I have chosen a no-brainer to start this blog. In the coming posts I will continue to develop and expand on many issues surrounding Rec. 19. In the end I am certain all will agree, that brainer or no-brainer, a different approach is needed if Members are to succeed in utilizing all the tools possible in this ongoing foray.
