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***  "We can't be everywhere... but we can be anywhere"  ***

A behind the scenes look at the RGP’s Money Laundering Investigation Unit


Since 2016, the MLIU has helped seize or recover luxury yachts, apartments, watches and over £2 million in cash from organised crime. So what do these highly-skilled detectives get up to?


It’s a department that doesn’t often hit the headlines in the Royal Gibraltar Police.


However, the Money Laundering Investigation Unit (MLIU) is one of the busiest in the force and has helped recoup millions of pounds from organised crime over the past few years on the Rock.


Working closely with their Fraud Squad colleagues, the two teams form the RGP’s Economic Crime Unit (ECU).


At the helm of the ECU is Detective Chief Inspector Tunbridge, who has been an officer in the RGP for over 23 years, 17 of which in the ECU. 


So what’s it like being in charge of one of the RGP’s busiest teams?


“It’s rewarding, interesting and good to know that we are tackling organised crime at its heart,” said DCI Tunbridge.


He went on to joke: “I could also say that I have a headache morning to night, as it seems the criminality we are tackling has the economic resources to throw the kitchen sink at us.”


When asked if there was money laundering in Gibraltar, DCI Tunbridge explained that as long as drugs are going from Morocco to Spain, there will be people making a lot of money.


He continued: “Money laundering will happen wherever there is criminal activity. Gibraltar conducts a National Risk Assessment on money laundering and has identified foreign organised crime gangs laundering their proceeds of criminal conduct in Gibraltar as one of their top risks.


“So money laundering is an issue and it’s our job to stop that.” 


Under DCI Tunbridge’s command in the ECU are; an inspector, two detective sergeants, six detective constables, two retired police officers, one civilian administration officer and two accountants. 


As to what money laundering is, he said: “It’s where people have managed to get proceeds from criminal conduct, such as cash, a property, a watch, a boat, all of that is money laundering. However, it is also about the people who help those who have obtained criminal property to keep that property. But you don’t need a victim to start an investigation. Therefore, it’s a much more proactive side of policing. 


“We also work on intelligence that we receive from law enforcement agencies in other jurisdictions and from local agencies such as the Gibraltar Financial Intelligence Unit (GFIU) – who get reports, known as Suspicious Activity Reports from financial businesses, such as banks, online gaming companies, people who trade in high value goods and all other sectors of the finance industry. They then forward that information to us and we investigate it. 


“We can also get intelligence from arrests that other departments do, for example, the Drug Squad.”


DCI Tunbridge explained that in 2017 Drug Squad detectives arrested a local drug dealer for a small amount of cocaine. 


“After his arrest we investigated further and found that he had around £100,000 in the bank. It went to trial and he was convicted in relation to the drugs. So, from a few hundred pounds worth of cocaine, we were able conduct a confiscation investigation to look into the last six years of his life and seize all this money in the bank.


“We also look at when other jurisdictions request evidence from Gibraltar, for crimes that have happened in their country. It may be that the request triggers an investigation for money laundering here in Gibraltar. So we are very proactive in lots of different ways.”


DCI Tunbridge, went on to explain that the MLIU was established in 2016, to help enforce the new Proceeds of Crime Act. This in turn allows Gibraltar to show MoneyVal (a European body that monitors a country’s ability to stop money laundering and the financing of terrorism) that positive action is taken in these areas of policing.


He added: “MoneyVal is a mechanism to check you have strong laws, good law enforcement agencies and supervisory authorities – to stop money laundering. Basically, they come and inspect your effectiveness is using those systems.


“Irrespective of MoneyVal, the MLIU should exist anyway, because taking the profit out of crime reduces the benefit of taking the risks that committing the crimes entails. Money laundering is not victimless. Drug gangs will sell drugs to anyone they can to make money. If you take that money away, you can hurt them.” 



The work the MLIU takes on is complex with many cases taking years to complete. And with that in mind, does the ECU look for a certain type of police officer?


“Yes, an ECU detective needs to be ready and willing to keep going for a long time on the same thing,” said DCI Tunbridge.


“We have to go through large quantities of data from phones, computers, banks and hard copy documents. If you are easily distracted and looking for the excitement seen in the movies of breaking down doors or car chases, this isn’t the department for you. We will have a day of action, where we seize the evidence we need, but then we have to review that evidence and that takes a long time. 


“When we go into a property or building and seize items, that’s just the beginning. Then there’s a huge amount of investigation regarding what you’ve found and that takes a certain type of character to sit there day in and day out doing the same thing to get to the end result.” 


When asked if there is much cross border cooperation, DCI Tunbridge said: “The short answer is yes. It is a very important part of what we do in terms of targeting money laundering. Because of our geographical location between Morocco, one of the largest cannabis producing countries in the world and Spain, the gateway to one of the largest consumers of cannabis, being the whole of Europe, there is a lot of money generated. 


“The crime gangs that deal with that are not often operating from Gibraltar. The Spanish authorities have a lot of information about what’s going on in Spain and that information will be shared if it leads to money laundering in Gibraltar. Also, criminals know full well that if they commit a crime in one country and launder their money in a second country, it becomes harder for law enforcement on either side to take their money, as you need the evidence from the other country, which is not always easy or quick to obtain.


“We have a very good relationship with the Spanish law enforcement authorities in the local area and a number of money laundering cases that we’ve had and are currently ongoing are because of the collaboration between the two of us.”


Unfortunately, leaving the European Union has made cooperation between Gibraltar and European law enforcement agencies more challenging, as the RGP no longer has access to the European Investigative Order, which was an efficient tool for gathering evidence in cross border cases. And, although there are other tools available, requests for evidence now take longer.


Looking forward, DCI Tunbridge would like to see a bigger, stronger ECU with more investment. This would lead to more expertise being brought into the unit such as a dedicated legal counsel, data analysts and accountants. But in the meantime, he continues to fight organised crime where it hurts the most – by helping to seize their money and assets.