An external view of Labuan & Malaysia in the

Global AML context

Sam Gibbins

Director, International Compliance Association

Introduction

Born in UK, living in Singapore for nearly 4 years

Studied at King’s College, University of London

Background in recruitment and sales/marketing

Spent 3 years working in the City (London)

before moving to Asia)

Introduction

International Compliance Association – global body dedicated to the

professionalisation of compliance, AML and financial crime

prevention professionals

Offices in UK, Dubai, and Singapore. Regional operations in Russia

and Hong Kong

Localised training courses for AML offered in Malaysia. Compliance

coming soon…

Increasing Money Laundering Sophistication

Increasing global sophistication of money laundering

More difficulty in preventing money laundering?

Higher level of global scrutiny of jurisdictions and their money

laundering effectiveness; how effective are fines as deterrents?

Monday 19 November 2012

Left Foot Political

Blog, November 9 2012

Human Nature?

Increased Competition

Is Labuan a serious alternative?

Singapore, Hong Kong, Australia

Is Labuan seen as a ‘layering’ option?

FATF Members; perceived to have higher level of sophistication

Is Labuan a serious alternative?

Helping to become a more recognised player in the international

scene

Moving ahead of middle ground players, for example those in

Central/South America

Striving towards the ‘Premier Centre status; is this achieved yet?

Business Times

(Malaysia),

13 July 2009

Importance of Shariah finance

Huge potential growth area into the future

‘This is further evident in the increase of Islamic private funds in the Labuan IBFC

from USD 1.4 billion in 2007 to USD 2.8 billion in 2008; while in the same

period, the Islamic reinsurance business – re-takaful – saw gross contributions increase by 48% to USD 162 million’ (Labuan IBFC)

‘There are currently six Islamic Banks and nine Islamic windows which

collectively reported an 87% increase in banking assets from 2009 to 2011’

(Labuan IFC)

Do People understand AML in relation to Shariah

Finance?

Shariah Finance Watch Blog,

25 September 2012

Impact of linkage with Malaysia?

Inherent risk of being linked with Malaysia and all ‘bad’ news

How do people view the ability of financial services firms in Labuan

to verify procedures, documentation and information?

What is the risk of loss of doing business in Labuan?

Sanctions

How much of a threat does this pose here in Labuan?

Increasing evidence of sanctions breaches

Very negative impact in many different business

scenarios…

Reuters,

12 September 2012

Bruno Manser Fund,

4 June 2012

Sanctions and the PR Machine

People depositing their funds in Labuan do so because

they do not want to be attracting publicity

Higher international awareness of Labuan is a double

edged sword

Labuan's position on the borders of Asia and

Australasia provides ready access to and from the

World's fastest developing economies and also to the

greatest population densities on the planet

Mondaq.com, 21 July 2011

Callum Beaton

Conclusions

Conclusions

Labuan must continue to build on it’s strengths:

Location

Shariah finance

Lack of global exposure

Conclusions

Labuan is on the rise along with the rest of SE Asia

MUST avoid the same fate of other jurisdictions with

relation to the money laundering trap, and stay our of

the headlines

Any questions?

Thank You!