With funding from the US Department of State Bureau of International Narcotics and Law Enforcement Affairs, Office of Global Programs and Policy (INL/GPP), the American Bar Association Rule of Law Initiative (ABA ROLI) implemented the Transnational Anti-Money Laundering Assistance Program – Training to Leverage Big Data Analytics (AML Big-Data program) in Malaysia, the Maldives, and Thailand in Southeast Asia and Tunisia in North Africa through September 30, 2023. The program, which started in 2020, delivered an integrated training approach for Financial Intelligence Units (FIUs) and money laundering investigators to provide analytical frameworks, strategies, and skills for using opensource intelligence (OSINT). ABA ROLI, through this program, developed a cross-regional OSINT training course to increase FIUs’ and investigators’ capacity to use available OSINT data to identify money laundering (ML) trends, detect ML, and bolster investigations and prosecutions.
Transnational Anti-Money Laundering Assistance Program – Training to Leverage Big Data Analytics
With a vision to foster a stronger and more interconnected AML presence in Southeast Asia, ABA ROLI expanded the program to include the Maldives as part of the jurisdictions. In alignment with the successful OSINT trainings already conducted for Malaysia, Thailand, and Tunisia, ABA ROLI aimed to enhance the effectiveness of the Maldivian FIU by building upon the existing Big-Data framework. As of December 2023, ABA ROLI completed the onboarding of at least 40 officials (drawn from various key government agencies in the Maldives including the entirety of the FIU, and five from the Anti-Corruption Commission, among others) to partake in a four-module e-learning OSINT course, as well as other tailored trainings covering more advanced big-data/OSINT, to bring them up to speed with the other three jurisdictions.
ABA ROLI has achieved an impressive completion rate of over 75% for the OSINT e-learning course in Malaysia, Thailand, and Tunisia, respectively. The e-learning course, hosted on Moodle, is a user-friendly guide for AML regulators, investigators, and LEAs. It teaches effective use of big data analytics to extract financial intelligence from OSINT in money laundering investigations. The four modules cover the basics of big data, data analytics, defining OSINT, and data management.
ABA ROLI hosted a three-day, joint-Advanced Training of Trainers (ToT) for the FIUs of Malaysia and Thailand in Bangkok in June 2023. The ToT was organized to enhance capabilities of these attendees in data analytics and OSINT. Throughout the course, the 30 financial investigators and analysts received in-depth instructions and practical hands-on experiences on various aspects such as on the creation and utilization of virtual machines to safeguard investigators’ identities while tracking malign actors. Participants gained practical expertise in installing Virtualbox, managing Tracelabs Linux and Snapshots, and mastering techniques to evade tracking through the Tor (The Onion Router) Network. Moreover, they were introduced to advanced searching methods, specifically targeting money laundering-related sites. These cutting-edge skills equipped these investigators and analysts with the necessary tools to conduct more efficient and thorough financial investigations. The training achieved its objectives, providing participants with valuable OSINT data analysis skills and strengthening their capacities as financial investigators. Overall, the positive feedback received from the participants reinforced the significance of such initiatives in combating financial crimes in the region effectively.
In Tunisia, ABA ROLI worked with the Tunisian Financial Analysis Committee (French, La Commission Tunisienne des Analyses Financières - CTAF) to identify money laundering trends using readily available data sources and identify sanctioned entities to investigate crimes with better accuracy, make recommendations for prosecution, as well as freeze and confiscate assets. ABA ROLI conducted a virtual training session for CTAF analysts and investigators on the use of OSINT in asset recovery. ABA ROLI’s AML expert, a former FBI Special Agent with specialization in AML investigation and founder of the FBI’s Kleptocracy Initiative, facilitated several training sessions with CTAF throughout this program.