The Law Enforcement Panel, "Beyond Filing: What Happens After You Submit a SAR?", was a lively and insightful session of the conference. Moderated by Adenike Sicard, Legal Chairperson of BVIACO and Managing Partner of Sinclairs (BVI), the discussion brought together representatives from the Financial Investigation Agency, the Royal Virgin Islands Police Force, the Immigration Department and the Office of the Director of Public Prosecutions for a practical look behind the scenes at how SARs are assessed, shared by authorities, and transformed into intelligence, investigations and, where appropriate, enforcement action.
Mr. Errol George, Director of the Financial Investigation Agency, explained their central role in connecting intelligence, regulators and law enforcement both locally and internationally, noting that formal information-sharing arrangements among competent authorities enabled information to be exchanged and acted upon swiftly.
From a law enforcement perspective, Mr. Kenrick Davis, Acting Deputy Commissioner of the Royal Virgin Islands Police Force, observed that the quality of SARs has improved significantly in recent years. He discussed the evolving nature of financial crime, particularly in an increasingly technological and cross-border environment. He shared a practical example of intelligence-led cooperation assisting in the rapid recovery of most of the virtual assets stolen from an individual's digital wallet, attributed to an effective and timely submitted SARs.
The Director of Public Prosecutions, Ms. Tiffany Scatliffe, relayed the importance of collaboration among the Territory's competent authorities, noting that the authorities had entered into a Memorandum of Understanding formalising their relationship in the fight against crime. She also emphasised the importance of compliance officers taking their responsibilities seriously, noting that this assists her office in carrying out its functions effectively. Ms Scatliffe noted that one of the biggest challenges faced by her office arises when industry participants do not fulfil their role as gatekeepers and, in some instances, are reluctant to act as witnesses.
Ms. Krestel Collins, Enforcement Officer in the Department of Immigration, highlighted that information identified through CDD, EDD and SARs become significantly more valuable when combined with immigration intelligence relating to identity, immigration status and cross-border movements. She explained that, from a strategic standpoint, the Department of Immigration is not only a border control agency, but that it is a key intelligence partner in the fight against illicit finance. She emphasised that effective collaboration is the process through which intelligence from the private sector and government agencies is brought together to support investigations, inform decision-making and strengthen enforcement outcomes.
During the Q&A segment, the audience quickly became part of a lively and interactive discussion, with questions, observations and personal experiences contributing to a dynamic exchange, with several moments of laughter along the way.
By the end of the session, attendees had gained a clearer picture of what happens after a SAR is submitted and the importance of their role in preparing and submitting an effective and timely SAR, not just defensively, but as an important contributor in combatting illicit finance and protecting the reputation of the BVI as a jurisdiction evidencing a robust AML/CFT regime followed by each and every sector.