The **Financial Intelligence Unit (FIU)** is a critical source of actionable intelligence for the supervision of Non-Bank Financial Institutions (NBFIs), especially given their vulnerability to money laundering and illicit finance. This course provides a focused guide on leveraging the FIU's data and analysis to enhance the effectiveness of NBFI supervision. Participants will learn how to utilize Suspicious Activity Report (SAR) data for risk assessment, establish secure information exchange protocols, and coordinate supervisory and investigative actions. The program emphasizes the legal basis for information sharing, the ethical use of intelligence, and maximizing the collaboration between the prudential regulator and the FIU to combat financial crime across the non-bank sector.
The Role of Financial Intelligence Units (FIUs) in NBFIs Supervision
Financial Regulation and Operational Excellence
November 30, 2025
Introduction
Objectives
Upon completion of this course, participants will be able to:
- Understand the core functions, legal mandate, and **FATF requirements** for a Financial Intelligence Unit (FIU) and its role in the AML/CFT regime.
- Establish effective, secure, and legally compliant protocols for **information sharing** between the prudential/AML supervisor and the FIU.
- Utilize **Suspicious Activity Report (SAR) data** and FIU typologies to inform the risk rating and on-site examination planning for NBFIs.
- Develop a coordinated strategy for the referral of cases, **joint investigations**, and synchronized enforcement actions between the two agencies.
- Master the legal and ethical requirements for maintaining **confidentiality** and restricting the use of FIU-sourced intelligence.
- Analyze FIU-generated data (e.g., trend reports, sectoral analysis) to identify emerging money laundering risks in the NBFI sector.
- Formulate an internal policy to ensure that supervisory findings on AML control breakdowns are immediately and accurately shared with the FIU.
- Understand the role of the Egmont Group and international cooperation mechanisms relevant to FIU/supervisor information exchange.
Target Audience
- AML/CFT Supervisors and Examiners focused on NBFIs and MSBs.
- Financial Intelligence Unit (FIU) Analysts and Operational Staff.
- Regulatory Policy Developers specializing in AML/CFT and Information Sharing.
- Internal Auditors focused on AML/CFT Compliance.
- Law Enforcement and Investigative Authorities dealing with Financial Crime.
Methodology
- FIU/Supervisor Information Sharing Protocol Design Workshops
- Case Studies on Successful Joint Supervisory/Investigative Actions (FIU/Regulator)
- Group Activities on Utilizing SAR Data for NBFI On-Site Examination Planning
- Expert Lectures on FATF Information Sharing Guidelines and the Egmont Group
- Workshops on Confidentiality Requirements and the Legal Use of FIU Intelligence
- Individual Exercises on Analyzing FIU Typology Reports for Emerging NBFI Threats
Personal Impact
- Development of specialized expertise in financial intelligence, AML/CFT information sharing, and coordination.
- Enhanced ability to leverage the **FIU's intelligence** (SAR data, typologies) to perform risk-based supervision.
- Improved strategic understanding of the legal and procedural requirements for inter-agency cooperation and confidentiality.
- Acquisition of valuable skills in case referral, joint investigation planning, and intelligence-driven risk assessment.
- Increased professional credibility as a certified expert in AML supervision and financial crime fighting.
- Better decision-making on focusing resources based on hard intelligence.
Organizational Impact
- Significant strengthening of the **AML/CFT oversight** of the NBFI sector through better utilization of financial intelligence.
- Enhanced ability to detect, investigate, and prosecute illicit finance activity by leveraging coordinated resources.
- Establishment of a legally sound and operationally effective **information-sharing mechanism** with the FIU.
- Improved quality of **NBFI risk ratings** and supervisory focus based on intelligence-driven insights.
- Better compliance with mandatory **FATF requirements** for effective inter-agency cooperation.
- Reduced risk of regulatory gaps and undetected financial crime across the non-bank sector.
Course Outline
Unit 1: The FIU Mandate and Supervisory Interface
Intelligence Gateway:- Defining the FIU (Administrative, Law Enforcement, Judicial) and its core functions (receiving, analyzing, disseminating).
- The legal and policy basis for the FIU's relationship with the prudential/AML supervisor.
- Review of **FATF requirements** for effective cooperation and information exchange between the FIU and supervisory authorities.
- The value proposition: how FIU intelligence (SARs, typologies) enhances the supervisor's Risk-Based Supervision (RBS).
- The challenge of maintaining the FIU's independence while maximizing supervisory utility.
Unit 2: Information Sharing Protocols and Legal Basis
Confidentiality and Legality:- Establishing clear, secure, and legally defensible protocols for information exchange (e.g., secure portals, dedicated liaison).
- Protocols for sharing **FIU-generated intelligence** (e.g., analytical reports, trend typologies) with the supervisor.
- The supervisor's obligation to share information on AML control breakdowns and formal enforcement actions with the FIU.
- Mastering the legal requirements and restrictions on the use and further dissemination of FIU intelligence.
- The role of a formal **Memorandum of Understanding (MOU)** to govern the information sharing relationship.
Unit 3: Utilizing FIU Data for Risk Assessment
SARs and Early Warning:- Analyzing **Suspicious Activity Report (SAR) data** volumes, quality, and patterns reported by NBFIs.
- Using FIU typologies and trend analysis to update the NBFI risk assessment matrix and focus on-site examinations.
- Developing automated tools (SupTech) to cross-reference supervisory data with FIU intelligence for anomaly detection.
- Protocols for supervisory follow-up on specific institutions that are high reporters or subject of FIU analysis.
- The role of the FIU in providing feedback to NBFIs on SAR quality and reporting trends.
Unit 4: Coordination of Investigations and Enforcement
Joint Action:- Developing a coordinated strategy for the **referral of cases** from the supervisor to the FIU for criminal investigation.
- Protocols for coordinating and synchronizing **supervisory enforcement actions** with the FIU's investigative timeline.
- The role of joint task forces or working groups to address specific emerging threats (e.g., illegal remittances, fraud schemes).
- Legal requirements for the use of FIU intelligence as evidence in a supervisory enforcement case.
- Managing the challenge of overlapping jurisdictions and avoiding interference in ongoing criminal investigations.
Unit 5: International Cooperation and Future Trends
Egmont Group and Technology:- Understanding the role of the **Egmont Group** and the FIU's international cooperation channels (e.g., information requests, joint analysis).
- The relevance of international FIU cooperation to the supervision of cross-border MSBs and NBFIs.
- Future trends: using AI and big data analytics to enhance the speed and scope of FIU analysis for the NBFI sector.
- Strategies for enhancing the technical interoperability between the FIU and the supervisory IT systems.
- The impact of new payment technologies (e.g., virtual assets) on the need for updated FIU/supervisor coordination.
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