Activity name (as stated in the original proposal):
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Improve institutional capacity and inter-agency cooperation in using anti-money laundering (AML) tools to investigate, prosecute and convict wildlife crime
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Service (to be performed):
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Develop content for a training module on AML in wildlife trafficking for banks, the financial intelligence unit (FIU) and law enforcement agencies (LEAs) in Viet Nam
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Location of Service provided:
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Remote and in person, with prior mutual agreement
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Duration of Service’s performance:
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February – May 2023
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I. Background
Wildlife crime is a complex, global problem that needs to be addressed through a variety of strategies. To move, hide and launder illicit money generated from the illegal wildlife trade (IWT), transnational organized crime groups exploit weaknesses in financial and non-financial sectors, enabling further wildlife crimes and damaging financial integrity. Financial investigation is an important step in ensuring those involved with IWT are identified and prosecuted fully. Using the tools and techniques available to investigate financial crime will aid in identifying revenues, property sources, money flows and the use of illicit funds in IWT. However, these tools have not been widely applied in investigating IWT and jurisdictions rarely investigate the financial trail left by this crime. To date, jurisdictions have not prioritized combatting the financial flows connected to IWT in line with the level of risk posed by this crime. A lack of required knowledge, resources and cooperation mechanisms often prevents law enforcement agencies (LEAs) from properly assessing and combating the threat of money laundering resulting from IWT.
In Viet Nam, despite wildlife crime being considered a predicate offence for money laundering crime (Supreme Court’s Judge Council’s Resolution 03/2019), and the fact that LEAs have made some significant seizures of illegal wildlife products, even during 2021 - 2022 when COVID-19 heavily affected global transport systems, there has not been any money laundering cases arising out of IWT investigations. The Asia/Pacific Group on Money Laundering (APG)-Mutual-Evaluation-Report-Viet Nam-2022 identified that “LEAs made minimal use of financial intelligence when tracing proceeds of crime, investigating money laundering and associated predicate offences like wildlife crimes. Challenges with the availability and quality of suspicious transaction reports (STRs) and weaknesses with FIU analytical systems and capabilities limit the volume and quality of FIU’s analytical products''
WCS’s training assessment and evaluations in Viet Nam have also identified that police lack an understanding of money laundering, and financial information in relation to wildlife trafficking and receive insufficient intelligence products from the FIU, while prosecutors and judges do not have sufficient information to prepare AML related cases. There is also very limited exchange of financial intelligence between the banking sector, LEAs, and judiciary. These constraints, together with weak inter-agency coordination, have led to hesitation in undertaking financial investigations or pursuing AML cases, especially at the district level, where most (wildlife) investigations take place.
Following the APG mutual evaluation, the APG also recommended that Viet Nam (i) enhance the quality and quantity of its financial intelligence products; (ii) prioritize proactive financial investigations, including increasing the development and use of financial intelligence; (iii) promote inter-agency and international cooperation to trace criminal proceeds.
WCS Viet Nam collaborates with national partners to co-host training events to enhance IWT-related investigation and AML capacity of banks, FIUs, and LEAs in Viet Nam. Therefore, we are seeking an international consultant to support this work.
II. Objective
To develop and deliver, as appropriate, a training program (agenda, materials and handouts) on AML in wildlife trafficking for banks, FIUs, and LEAs.
III. Description of work:
The selected international consultant will work closely with WCS Viet Nam’s Program Manager and other relevant staff members to execute the following activities and deliverables within the identified timeline.
Actities
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Outputs/ deliverables
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Completed by
(Tentatively)
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- Design training programs
- Work with WCS to identify and select relevant topics on using AML tools to fight IWT that focus on the intelligence stage and investigation stage.
- Develop training agendas including two parts which can be a stand-alone program for each group of participants -- Part I for banks and FIU, Part II for LEAs -- in agreement with WCS Viet Nam.
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- Training agendas, including identification of relevant topics.
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Feb. 2023
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- Develop training materials
- Develop training content and materials for the selected topics suitable for two groups of participants, including financial sector compliance, AML staff, FIU staff, and police officers.
- Prepare session plans, PowerPoint presentations, handouts, participants’ assessments, and reading lists.
- Develop IWT case studies that can be used throughout the training program.
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- Training materials (e.g., session plans, trainer notes, PowerPoint presentations, handouts, list of reading documents)
- IWT case studies
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March 2023
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Deliver the training courses to representatives of banks and FIU, and LEAs in Viet Nam
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- 02 training courses delivered
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May 2023
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Details of this task will be discussed and agreed between WCS and consultant once WCS receives approval on organizing these trainings from national partners. A separate contract shall be signed for this task.
Total allotted time (total working days): To be determined according to the consultant's proposal and agreed upon by WCS.
IV. Requirements (selection criteria)
- Experience in instructional management and development of training programs.
- Demonstrated profiles in training bank and FIU staff, law enforcement and judicial officials, preferably those with experience in Asia.
- Excellent coordination, communication, and facilitation skills.
- Experience working at the interface of NGO and Government on law enforcement.
- Knowledge of wildlife trafficking, anti-money laundering and financial investigation to support prosecution and conviction of wildlife crime is an advantage.
- Understanding of AML regimes in Viet Nam and previous AML experience with banks, FIU and LEAs in Viet Nam an advantage.
V. Application procedure:
- Interested candidate(s) are invited to send to vietnamconsulting@wcs.org before 17:00 of Feb. 28, 2023
- A technical proposal including methodology, personnel plan, CVs, link to or soft copies of related products
- Financial proposal (in USD, the estimated total number of working days and daily rates, field trip costs, if any, including all taxes and fees such as personal income tax, VAT, etc.)
- Note: Only shortlisted candidate(s) will be contacted