I. Background:
Wildlife crime is a complex, global problem that needs to be addressed through various strategies. To move, hide and launder illicit money generated from illegal wildlife trade (IWT), transnational organized crimes exploit weaknesses in the financial and non-financial sectors, enabling further wildlife crimes and damaging financial integrity. Financial investigation is an important step/part in identifying revenues, property sources, money flows and uses; however, it has not been applied in investigating illegal wildlife trade flows 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 risk. Thus, lack of required knowledge, resources and cooperation mechanism prevent the law enforcement agencies (LEAs) from properly assess and combat the threat of money laundering. The limited focus on the financial side of IWT has largely prevented jurisdiction from being able to identify and sanction IWT networks.
International organizations/units worked on financial investigation such as Financial Action Task Force (FAFT), Egmont Center of Financial Intelligence Units (FIUs) Excellence & Leadership (ECOFEL) have recently conducted a series of research and analysis to assess money laundering aspects of wildlife crime and provided suitable methodology and tools that jurisdictions should apply to combat IWT in the aspects of linked illicit financial transaction.
Despite the power of performing financial investigation in uncovering the wider network of criminals involved in an illicit wildlife supply chain, Vietnamese police have never conducted a financial investigation as part of an IWT case or investigated and prosecuted any money laundering case related to wildlife crime as a predicate offense. Training evaluations previously conducted by WCS revealed that police lack understanding of money laundering, financial information and have insufficient intelligence products provided by FIU, while prosecutors and judges do not have sufficient information to prepare for the development of money laundering crime cases. Those together with weak inter-agency coordination lead to hesitation in undertaking financial investigations or pursuing money laundering cases, especially at the district levels, where most (wildlife) investigations take place.
WCS Viet Nam program believes that by increasing the capacity and awareness of FIUs, banks and financial service providers, LEAs, prosecutors and judges, they can pay greater attention to IWT cases and effectively utilize financial investigative tools. Furthermore, providing Intelligence products (IPs) highlighting areas of potential financial risks in wildlife supply chains, locations, and companies vulnerable to be exploited by wildlife traffickers to with the relevant LEAs, FIU, concerning banks, and financial service providers will contribute to improving their analytical process and integration of the databases to receive and analyze the suspicious transaction reports, early detect money laundering risks related to illegal wildlife trade and identifying other relevant illegal activities.
At this stage, we aim at increasing the awareness and capacity of FIU, banks, financial service providers on these issues and supporting them with intelligence products (IPs). Therefore, we are seeking consultant service to support us to realize the mentioned goal.
II. Objectives:
WCS will hire a consultant(s) to:
1. Assess the current awareness/perception of FIU and banks in Viet Nam on money laundering risks related to IWT, their current risks mitigation and management, their cooperation with LEAs, and their needs on capacity building, intelligence support to identify potential gaps, loopholes in the legal framework and practice from which interventions are recommended;
2. Develop a standard template for wildlife-related financial risks gathering and monitoring, tools for financial risks analysis and identification of high-risk areas; as well as provide technical training/guidance on using these templates, tools to WCS Viet Nam.
III. Activity, Expected outputs/deliverables and tentative deadline
| Activities | Outputs/ deliverables | Deadline/ Work timeline (Tentatively) | Allotted time (# of days) |
| Task 1: Assess the current situation of preventing and combating money-laundering risks related to IWT in the banking sector in Viet Nam |
| Activity 1.1: Design tools (survey forms, questionnaires, methodology guidance, and report structure) for conducting an assessment on the current situation of preventing and combating money money-laundering risks related to IWT in the banking sector in Viet Nam | Developed assessment tools (survey forms, questionnaire, methodology guidance, and report structure) | Middle of Sept 2021 | Based on the proposal of the consultant and WCS’s approval |
| Activity 1.2: Provide instruction on using the assessment tools to WCS Viet Nam and its national consultant team, including: · Brief WCS Viet Nam and its national consultant team on survey forms, questionnaires, methodology, and report structure; · Revise and finalize the survey forms, questionnaires, methodology, and report structure, if any, upon agreement. | WCS Viet Nam and the national consultant team is instructed to use the assessment tools | Early Oct 2021 | Based on the proposal of the consultant and WCS’s approval |
| Activity 1.3: Provide technical inputs and comments to the draft assessment report on the current situation of preventing and combating money money-laundering risks related to IWT in the banking sector in Viet Nam; provide relevant recommendations about policy and legal reform; capacity building activities; Inter-agency coordination and cooperation… | Inputs, comments and recommendations are incorporated into the assessment report | After completion of the assessment coordinated by WCS and its partner, around Feb 2022 | Based on the proposal of the consultant and WCS’s approval |
| Activity 1.4: Participate as an international expert/keynote speaker in briefing/workshop events with FIU, banks and/or relevant government agencies | Relevant international experiences shared; and the need of banking sector identified and discussed | After having a final assessment report, May 2022 | Based on the proposal of the consultant and WCS’s approval |
| Task 2: Develop tools and templates to identify, collect and analyze information on money laundering risks related to IWT and provide guidance to WCS Viet Nam |
| Activity 2.1: Provide technical inputs and comments to the IWT-related financial risk indicators and red flags developed by WCS Viet Nam, and make sure that they are in line with international practice | Inputs and comments to the risk indicators and red flags | Sept 2021 | Based on the proposal of the consultant and WCS’s approval |
| Activity 2.2: Develop standard forms and templates for monitoring IWT-related financial risks that are in line with international practice and would be used by WCS to submit/share to FIU, banks, and financial service providers | Draft standard forms and templates for monitoring IWT-related financial risks | Sep 2021 | Based on the proposal of the consultant and WCS’s approval |
| Act 2.3: Lead the consultation session with national experts from the Anti-Money Laundering Department of the State Bank of Viet Nam and relevant commercial banks to ensure the forms and templates are suitable with the risk management system of the banks | Forms and templates for monitoring IWT-related financial risks will be revised and finalized | Oct – Nov 2021 | Based on the proposal of the consultant and WCS’s approval |
| Activity 2.4: Provide technical coaching and support to WCS Viet Nam in using these tools and templates | Potential high-risk areas, sources of information, data collection and analysis methodology identified and trained | Oct – Nov 2021 | Based on the proposal of the consultant and WCS’s approval |
IV. Fee:
The estimated cost will be provided by the independent consultant based on the proposal of the working day for each activity mentioned in item III. Activity, Outputs/deliverables and work timeline and approved by WCS in compliance with WCS Vietnam's norms. Total working days must not exceed 28 working days.
V. Consultant Requirements:
1. Master degree in banking and finance, commerce, economics, criminology or relevant fields;
2. A member of the Association of Certified Anti-Money Laundering Professionals (ACAMS) is required;
3. At least 10 years of experience in tackling financial crime (e.g. forensic accounting, financial crime intelligence and investigation, anti-money laundering) in a FIU, commercial banks, financial service providers, law enforcement agencies, or international organizations, and NGOs;
4. Extensive knowledge of, and demonstrates skills in providing mentorship and coaching on AML related to IWT;
5. Understanding the current situation of money laundering crime and wildlife trafficking in Viet Nam is an advantage.
VII. Application procedure:
Interested candidate(s) are invited to send their i) Technical proposal; ii) Resume(s) and iii) Expected fees and expenses to vietnamconsulting@wcs.org before 17:00 of 23 August 2021.
Note: Only shortlisted candidates will be contacted.