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C O N F I D E N T I A L LIMA 000099 
 
SIPDIS 
 
E.O. 12958: DECL: 2020/01/28 
TAGS: ASEC EFIN SNAR PE KCRM KTFN
SUBJECT: Peruvian Banking Superintendent Talks about Future of FIU 
and GAFISUD Priorities 
 
CLASSIFIED BY: kathy schleigh, OMS, ...

id: 246091
date: 1/28/2010 20:52
refid: 10LIMA99
origin: Embassy Lima
classification: CONFIDENTIAL
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C O N F I D E N T I A L LIMA 000099 

SIPDIS 

E.O. 12958: DECL: 2020/01/28 
TAGS: ASEC EFIN SNAR PE KCRM KTFN
SUBJECT: Peruvian Banking Superintendent Talks about Future of FIU 
and GAFISUD Priorities 

CLASSIFIED BY: kathy schleigh, OMS, State, NAS; REASON: 1.4(B) 

Peruvian Banking Superintendent Talks about Future of FIU and 
GAFISUD Priorities 



¶1. (SBU) Summary: Peru's Superintendent of Banking Felipe outlined 
his vision for the Financial Intelligence Unit (FIU) moving forward 
and discussed his priorities as the new chairman of GAFISUD (spell 
out first usage) in a January 22 meeting with Emboffs. Accompanied 
by International Affairs Manager Jorge Yumi, and new FIU Director 
Sergio Espinosa, Tam emphasized that the investigative priorities 
for the FIU remain unchanged despite the recent change in 
leadership and that they are looking forward to continued 
cooperation with the U.S. Embassy. Tam said he will continue to 
support proposed legislation to strengthen anti-money laundering 
investigations and modernize the FIU as well as push at the highest 
levels to ensure that anti-money laundering is a priority in the 
GOP. End 

Summary. 



The FIU - Enrique Salvidar Steps Down, New Head Appointed 



¶2. (SBU) On December 2nd, Enrique Salvidar resigned his position as 
head of the FIU citing personal and family reasons. At the time, 
there was intense speculation that he had stepped down at the 
request of Superintendent of Banking Felipe Tam as a result of an 
information leak scandal (REF A). No formal charges have been filed 
against Salvidar or Tam, but the Public Ministry is looking into 
the matter and how to ensure better control of investigative 
information. On December 8th, Sergio Espinosa was appointed as the 
new FIU Director. No other staff changes have occurred - the Deputy 
Director remains in place as do the section heads. For the time 
being, Espinosa will be wearing two hats as he is also head of 
Superintendency of Banking's (SBS) legal department. Espinosa has 
worked in the SBS for over 15 years in various departments. 



FIU - Looking Forward 



¶3. (U) Tam explained that the FIU will be implementing a new 
software system that will allow the FIU to receive Suspicious 
Activity Reports (SARs) electronically and is looking to 
restructure the organization to give more authority to the FIU 
Director. Tam is also looking to relocate the FIU offices to a 
larger, more secure building.  When asked about his plans for 
strengthening the day-to-day work of the FIU, Tam said he is 
pushing proposed legislation in Congress that would grant FIU 
access to any type of financial information such as banking and tax 
information that is currently considered secret or restricted. Tam 
and Espinosa both said the priorities and the training needs of the 
FIU remain unchanged and they expect things to move forward 
smoothly, despite the leadership change.  Tam's View on Money 
Laundering in Peru 



¶4. (C) Tam feels that the highest levels of the GOP need to have a 
deeper understanding of the connections between money laundering 
and drug trafficking. He also acknowledged that the money exchange 
houses are a black hole in the FIU's understanding of how money 
moves through the Peruvian financial sector. (NOTE: most of the 
money exchange houses operate in the informal sector and thus there 
is little-to-no official reporting to the FIU, though it is legally 
required).   It is Tam's opinion that although addressing the role 
of exchange houses is difficult, it is not impossible because, 
according to Tam, all the money must go through a bank at some 
point. Tam also said that there needs to be more coordination on 
the gaming sector between the SBS and the Ministry of Tourism (REF 
B). He feels that if they can get at the gaming sector, the money 


exchange houses, and the construction sector, they will have 
tackled the greatest part of the money laundering problem in Peru. 




¶5. (C) Tam also explained the challenges in working with the Public 
Ministry. Espinosa agreed and said they are working to maintain 
open communication with the prosecutors who work money laundering 
cases. One change they will be making this year, at the request of 
the Public Ministry, is that the FIU will begin filtering Financial 
Intelligence Reports (FIR) sent to the Prosecutor's Office for 
further investigation. The Public Ministry has asked that, rather 
than sending everything over, the FIU prioritize and focus on 
prosecutable cases. This is a significant change from the past 
modus operandi because it will give the FIU more authority and 
ability to prioritize cases. Tam said that one of his personal 
challenges with the Public Ministry is convincing the attorney 
general that anti-money laundering work is priority work across the 
board and especially in counter narcotics. Currently, the SBS pays 
salaries for two financial analysts in the Public Ministry and has 
an agreement with the Magistrates Academy to support anti-money 
laundering and terrorist financing courses. Tam said his vision is 
to advance anti-money laundering work in Peru more so than ever 
before. 



Priorities for GAFISUD 



¶6. (SBU) With Peru chairing GAFISUD this year, Tam said his 
priorities include improving the professionalism of the GAFISUD 
Secretariat and supporting the intentions of Costa Rica and Panama 
to join GAFISUD. At the GAFISUD meeting in July, Tam said, he plans 
to discuss the inclusion of Costa Rica and Panama as well as the 
need to develop a series of meetings with Bolivia, Ecuador, and 
Paraguay which are struggling to implement the 40+9 recommendations 
established by GAFI-FATF (Financial Action Task Force) and adopted 
by GAFISUD. Tam said he is also looking to push micro-finance as a 
major tool for GAFISUD countries to address the informal sectors - 
a serious issue in Peru. Tam believes that by reducing the informal 
sector, governments can reduce avenues of money laundering, 
increase access to credit for lower income individuals and families 
and better regulate the financial sector. 





National Anti-Money Laundering and Terrorism Financing System 



¶7. (SBU) Tam explained that another of his top priorities for the 
SBS is to launch a national anti-money laundering and terrorist 
financing system (SILAFIT), an interagency task force led by the 
Ministry of Economy and Finance with the SBS as the Technical 
Secretariat. Tam said there is political support for this idea and 
the Minister has agreed in principle to the SILAFIT structure. 
However, Tam feels that international support, especially from the 
U.S., would help with this priority. 



Comment 



¶8. (SBU) The transition of leadership in the FIU seems to be going 
smoothly and post is encouraged by the commitment of Espinosa to 
maintain the FIU priorities developed under Salvidar. Tam expressed 
several times his hope that NAS will continue with cooperation and 
assistance to the FIU and said he may be looking to the U.S. 
Embassy for support on policy issues related to anti-money 
laundering. We will continue to support the FIU and seek ways 


encourage improvements in prosecutions and convictions of money 
launderers. 
McKinley 

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