Lo visible, lo invisible y lo enunciable de la formación: Gobierno del discurso

terrorism finance?

This section supports the fourth objective of this study regarding suggestions to be proposed to SAFIU to emulate policies for combating financial crimes in a better way (six survey question). In addition, this section discusses the type of suggestions proposed to SAFIU to formulate policies that can better combat money laundering and terrorism financing whilst ensuring compliance with the 40+9 FATF Recommendations. The overall opinion of staff members is that 4.73 indicated a strong agreement with this notion.

Interestingly, the feedback from SAFIU staff indicated their strong agreement with the provision of financial and technical resources by the MOI (maximum average of 5.0). This is in support of FATF Recommendation 30 Article 1, which states that FIUs should be provided with technical and financial resources to perform their functions promptly. In 2010, SAFIU was well resourced with an annual budget of SAR100 million, a significant amount higher than AUSTRAC, which during the same year has an annual budget of A$21 million. By contrast, West African FIUs has been severely affected by inadequate financial resources to perform meritoriously (Shehu, 2010).

The feedback also indicated a strong agreement with increased cooperation and coordination between SAFIU and foreign FIUs by the signing of MOUs (an average of 4.95), suggesting that an increase in cooperation between SAFIU and other FIUs. FATF Recommendation 40 Article 1 echoes the importance of FIUs striving towards providing the widest possible support of international cooperation to their foreign counterparts. With the recent membership in Egmont Group, the effectiveness of SAFIUs cooperation has increased significantly with MOUs being signed with partner countries and therefore enabling prompt exchange of information and experience with partner FIUs. Upon gaining membership, SAFIU requested MOUs with 60 foreign FIUs.

The responses of SAFIU staff also reflect a strong agreement that SAFIU will improve its efficiency if direct access to financial information is granted (average of 4.81). This is due to SAFIU not having the authority to access financial information

directly, as it has to request this information from other supervising bodies as per Article 8.1 the of Saudi AML Law. In spite of superseding financial confidentiality and secrecy laws, SAFIU staff strongly felt that gaining direct access to financial information would eliminate delays in receiving information.

Other responses suggest that there is a strong agreement with guidance provided by SAFIU to businesses for monitoring and reporting STRs related to terrorism financing and money laundering (average of 4.59). This is accordance with FATF Recommendation 26 Article 2, which states that FIUs should provide guidance to the private sector regarding specifications and styles of reporting and procedures to be followed. The findings are inconsistent with the 2010 MENAFATF report, which identified private institutions lacking a clear understanding about transaction monitoring and differentiating between STRs. This was especially the case, since only one STR was received from non-bank entities in 2010, and indicates a lack of supporting, governance and training assistance being provided by the supervisory agency MOCI.

With regards to increasing participation of SAFIU staff in local and international seminars and conferences, the feedback indicated that the staff strongly agreed with this notion (average of 4.54). SAFIU staff suggested that an increase of participation in conferences would be a significant step towards combating and formulating policies for terrorism financing and money laundering. Participation in such forums also constitutes compliance to the World Bank who emphasised on the importance of participating in seminars.

Lastly, the responses from SAFIU staff reflect their strong agreement of operating their offices in major cities of KSA to streamline their processes and improve efficiency (average of 4.45). With a single local office currently located in Riyadh, staff proposed that SAFIU should expand its operations into other major cities by following the footsteps of the Prosecution Authority, which currently has offices across 13 provinces. Though this activity requires a large source of funds and expertise, it would enable SAFIU to pay greater attention by raising the level of awareness in AML and CTF risks regionally. It would also be a significant move towards combating terrorism financing, as Saudi Arabia has borders with several

countries and setting up offices across the country could complement SAFIUs efforts. This claim is also supported by the figures cited in the 2010 MENAFATF report regarding the number of cases related to money laundering according to city. Between 2004 and 2008, the second largest city, Jeddah, recorded the highest number of money laundering related cases - 105 cases. This approach is also evident in other FIUs such as AUSTRAC, which has offices operating across five major cities.

5.6. Chapter summary

This chapter discussed the quantitative and qualitative results of the respondents prior to discussing the similarities and differences between what other FIUs practice when complying with International Standards. The findings have generally identified that SAFIU is effective in receiving, analysing, disseminating and cooperating with external agencies in money laundering and terrorism finance activities. SAFIU was also generally deemed compliant with International Standards as set by FATF 40+9 Recommendations. Similarly, the findings were consistent with the MENAFATF Mutual Evaluation Report, which evaluated AML and CTF measures in place within the KSA. The following chapter (Chapter 6: Recommendations and Conclusions) provides a number of recommendations deduced from the study. These are presented in the following chapter.