1. Moving Towards EXCELLENCE with FATF’s 40+9… THE COOK ISLANDS STORY Financial Supervisory Commission Cook Islands

2. The Story Teller: Louise Wittwer Manager - Offshore Services Financial Supervisory Commission Rarotonga Cook Islands Financial Supervisory Commission Cook Islands

3. Setting the Scene: “Cook Islands have emerged as a leader in the fight against money laundering and terrorism financing within the region.” Dr Gordon Hook Executive Secretary Asia/Pacific Group on Money Laundering July 2009 Financial Supervisory Commission Cook Islands

4. Setting the scene a little better … Lou’s back yard Financial Supervisory Commission Cook Islands

6. Western neighbours – Tokelau, Western + American Samoa, Niue

7. Eastern neighbour – Tahiti

8. Lies in the Tropic of CapricornFinancial Supervisory Commission Cook Islands

10. 1 of 15 islands scattered over 2 million square kilometres

11. Home to 12,000 people

12. Circular island, 32k in circumference

13. Mountain peaks backdrop to palm fringed shores of turquoise lagoonFinancial Supervisory Commission Cook Islands

14. Quiz Time: What is the most popular mode of transport in the Cooks? Train Helicopter Scooter Financial Supervisory Commission Cook Islands

15. Quiz Time: 2. What do Cook Islanders eat with? A knife and fork Chopsticks Their hands Financial Supervisory Commission Cook Islands

16. Quiz Time: 3. The majority of animals in Rarotonga are: Monkeys Pigs Cats Financial Supervisory Commission Cook Islands

17. Quiz Time: 4. The Cook Islands $2 coin is this shape: Square Triangle Circle Financial Supervisory Commission Cook Islands

18. Quiz Time: 5. The Cook Islands are in the same time zone as: Hawaii Antarctica New Zealand Financial Supervisory Commission Cook Islands

19. Quiz Answers: C - Scooter C - Hands B - Pigs B - Triangle A - Hawaii Financial Supervisory Commission Cook Islands

20. Setting the Scene: “Cook Islands have emerged as a leader in the fight against money laundering and terrorism financing within the region.” Dr Gordon Hook Executive Secretary Asia/Pacific Group on Money Laundering July 2009 Financial Supervisory Commission Cook Islands

21. Asia/Pacific Group on Money Laundering (APG) – 5 key roles: Robust Mutual Evaluation Programme Technical Assistance + Training International AML Network Research + Analysis Active Associate Member of FATF Financial Supervisory Commission Cook Islands

23. 40 Active Member Countries

24. 9 Members who are FATF members: Australia 6. Korea Canada 7. New Zealand China 8. Singapore Hong Kong 9. United States Japan Financial Supervisory Commission Cook Islands

26. AML Mutual Evaluation in Feb 2009

27. MER released in July 2009Very pleasing results … Financial Supervisory Commission Cook Islands

28. Key Result: Cook Islands is the only jurisdiction (in APG) that has NO NON COMPLIANT ratings against FATF’s40 AML Recommendationsand9 Special Recommendations (Against Terrorism Financing) Financial Supervisory Commission Cook Islands

29. Overall Result: Financial Supervisory Commission Cook Islands In summary, 60% C or LC and 40% PC.

30. Detailed Results: Financial Supervisory Commission Cook Islands

31. Comparative Results: Financial Supervisory Commission Cook Islands

32. So, how did we get there? Financial Supervisory Commission Cook Islands

33. Essentially with,‘Political + Jurisdictional WILL’ to be removed from FATF’s BLACKLIST(June 2000 to February 2005) Financial Supervisory Commission Cook Islands

35. Active involvement of Govt and Crown Agencies

36. Supervisory and Regulatory Change

37. Other Fundamental ChangesFinancial Supervisory Commission Cook Islands

38. Legislative ChangeSuite of AML legislation … Money Laundering Prevention Act 2000 Banking Act 2003 Crimes Amendment Act 2003 Extradition Act 2003 Financial Supervisory Commission Act 2003 Mutual Assistance in Criminal Matters Act 2003 Proceeds of Crimes Act 2003 Financial Transactions Reporting Act 2004 Narcotics and Misuse of Drugs Act 2004 Terrorism Suppression Act 2004 Financial Supervisory Commission Cook Islands

39. Active involvement ofGovernment and Agencies … Financial Intelligence Unit (Intel & Compliance) Financial Supervisory Commission (Regulation & Compliance) Cook Islands Police (Investigation & Prosecution) Customs (Movement of People & Goods) Crown Law (Prosecution) Along with Audit, Immigration, Justice, Foreign Affairs. Financial Supervisory Commission Cook Islands

40. Financial Supervisory Commission Cook Islands

41. Supervisory & Regulatory ChangeA few examples … Relicensing of all banks (domestic & international) by FSC Annual on-site examinations of all financial institutions (including trustee companies) Introduction of FIU’s reporting regime (STR, CTR, EFTR) Review of DNFBP’s (lawyers, accts, pearl dealers, mv dealers, real estate agents) Financial Supervisory Commission Cook Islands

42. Other Fundamental ChangesA few more examples … Establishment of the Co-ordinating Committee against Money Laundering & Terrorist Financing (CCAM) Getting the Offshore Industry ‘on board’ with the Regulators Active participation in AML forums (APG, Egmont) Sector Capacity Development (T & TA) Awareness Programmes for DNFBP’s Financial Supervisory Commission Cook Islands

43. By February 2004 the 2nd Cook Islands Evaluation Team observed: “Overall, the current AMLlegal, institutional, and supervisory framework provides a sound basis for the prevention, detection, and prosecution of ML offences, but implementation remains weak and FT is not addressed.” Financial Supervisory Commission Cook Islands

44. 3rd time round – Preparing for CI 2009 Mutual Evaluation Started planning early, after APG 2007 Plenary Outsourced preparation of ‘National Risk Assessment’ Heads of all key agencies – FIU, FSC, CLO and Police attended APG training workshop FIU dedicated resources to the ME Comprehensive completion of ME questionnaire Financial Supervisory Commission Cook Islands

45. 3rd MER Positive BUT… Still contained 112 !!! recommendations POCA, FTRA, Offshore, Insurance & DNFBP sectors… Financial Supervisory Commission Cook Islands

46. So, where are we going? Financial Supervisory Commission Cook Islands

47. Financial Supervisory Commission Cook Islands

49. Maintain co-operation between parties

50. Aim for nil PC, and a significant move from LC to C, for our 4th ME.Financial Supervisory Commission Cook Islands

51. AND we’ve already started… Revocation of two Offshore Bank Licences. Implementation of the Insurance Act 2008. Money Changers and Remitters Act passed in 2009. Steps underway to abolish the Offshore Banking Sector. Strategic Implementation Plan workshop held late March. Financial Supervisory Commission Cook Islands

52. MeitakiMaata Financial Supervisory Commission Cook Islands

53. Lou’s front yard … Financial Supervisory Commission Cook Islands