Whether it is profiling mid-league local drug dealers, raiding dental practices suspected of money laundering or investigating the findings of the Moriarty Tribunal, the mission of the Criminal Assets Bureau is the same, to disrupt criminal activity by stripping away the rewards of crime.

It is a narrow remit but the reach of the Cab has been profound since its inception in 1996 following the gangland murders of Detective Garda Jerry Mc Cabe and journalist Veronica Guerin. 

To put it into hard currency terms, the agency returned a total of €13.8 million to the exchequer in the past three years. In 2019, the value of assets confiscated by the Cab hit a record high of €62 million, mostly as a result of a drug dealer forfeiting €52 million in bitcoin.

I recently met with the new head of the Bureau, Detective Chief Superintendent Michael Gubbins to talk asset profiling, cash seizures, international money laundering and cryptocurrency. I wanted to find out if criminals are becoming more astute when it comes to hiding the proceeds of crime and whether there is more corporate crime on the Cab’s radar given the technological advances of recent years.

In the interview we discuss

• Why cash remains king for criminals in the Covid era
• Disrupting crime from the ground up
• New areas of sharp practice from CEO fraud to invoice redirect
• The Criminal Assets Bureau’s international connections
• The rise of cryptocurrencies

My curiosity is partly fuelled by Gubbins’s own policing background in cybercrime. He was appointed to the Cab top spot five months ago when his predecessor Pat Clavin was promoted to the rank of acting Assistant Commissioner of An Garda Siochana. 

Originally from Limerick, Gubbins initially went to train as an accountant after school. When that didn’t work out for him, he tried for the law but didn’t get the exam. So instead he joined the guards in 1989. His interest in figures helped steer him towards the fraud squad early on in his policing career. Then in 1995, he took a night course in Microsoft Office and Take 5 accounting software. On the back of that, he was asked to join the computer crime unit where he began to beef up his credentials obtaining, among other qualifications, a Masters in Forensic Computing & Cybercrime Investigation from UCD. He recently obtained a postgraduate certificate in corporate governance.

Over the years, his expertise in computer forensics has been called upon in such high profile trials as the case of “Lying Eyes” Sharon Collins who hired a hitman over the internet to kill her partner, and the 2004 murder of Dublin mother Rachel O’Reilly.

Gubbins’ last garda posting was as head of the Clare garda division where he oversaw the policing operation put in place last year for the visit of President Donald Trump to Doonbeg.

I meet the new Bureau chief in early October at the offices of the Cab at Harcourt Square, a nondescript suite of 1980s red brick buildings earmarked for demolition in 2023 as Hibernia Reit moves in to redevelop this prime slice of real estate into offices. The elite garda units currently housed there, and the multi-agency Cab, are destined to move to the new €80 million Garda command and control centre on Military Road near Heuston Station which is currently under construction.

The interior of Gubbins’ office would appear to be of nineties or early noughties vintage with chunky cable trunking breaking up the magnolia coloured walls. There is some personal memorabilia dotted around the room, which is generous in size, including a collection of garda baseball caps. Pinned to the wall behind his desk, below his framed third level qualifications, is a tablet of the Apollo 13 space mission with its motto “Failure is not an option”. 

The Chief Superintendent ushers me in. He is personable and generous with his time but veers towards caution in some of his replies. 

Living beyond one’s means

Francesca Comyn (FC): You are coming from cybercrime. Is that an intentional thing in terms of the direction Cab might be going in?

Chief Superintendent Michael Gubbins (MG): I joined the guards in 1989 and I went to fraud. So the computer crime unit would have been part of the Garda Bureau of Fraud Investigation (since renamed the Garda National Economic Crime Bureau) for a good number of years. It was 2016 when it became the Garda National Cyber Crime Bureau. So at that point, then I would have been familiar with money laundering and various frauds. There is an overlap with some of the fraud types and cybercrime we would see such as invoice redirection, CEO fraud, business email compromise. So I would have been familiar with money laundering and the financial investigation unit in the GBFI.

FC: I suppose I’m asking is it a growing trend that would be relevant to Cab?

MG: My history would have been in national units. My history would have been working with Europol and I’ve a history of working with the banks, with the Banking & Payments Federation (BPFI), the high tech crime unit and of knowing people in the insurance industry. It’s a small network and they all overlap at some stage. I would have done a few jobs with the Criminal Assets Bureau over the years. But this is my first time working for them. 

Gubbins notes that people don’t always realise the Cab is a separate legal entity from the guards with Revenue staff, officers from the Department of Employment Affairs and Social Protection, forensic accountants, analysts, an IT department, legal officers and an executive chief superintendent that sits at the top of the organisation.

FC: When it comes to profiling suspects and following assets, what most typically sparks an investigation. Is it a garda probe, a tip-off?

MG: It can be any number of things but one of the most important assets to us in identifying targets is the use of divisional asset profilers. These are trained guards, they’ve been trained by the Criminal Assets Bureau. And they go back to their district or their division and they identify people that they think should become targets of the Criminal Assets Bureau.

FC: What are the red flags?

MG: The red flag is you’re looking at somebody who is living beyond their means. It could be the ostentatious extensions, the big cars, the multiple holidays, the jewellery, there’s a lifestyle that isn’t in keeping with their known income.

FC: Would they sometimes come to garda attention through their associates.

MG: And their known activities. They would be known criminals. The majority of targets would be engaged in the sale and supply of drugs. And that is throughout the whole country. They are not just the names or people you’d read about in the headlines on a Sunday or during the week. These are criminals that maybe for a town or county or a number of counties, they would have control of that. And they would be known to the local guards and the local citizens from their actions. We also get anonymous phone calls, letters, emails. You might get a history of what to look at or what to consider there. Based on that we might go for a profiler request. See, can we get a bit more information and see if they are worthy of becoming a target.

FC: The fact you mentioned the word drugs there, that would suggest that the typical profile of the kind of person whose assets you might be going after may not have changed that much. Is that the truth since the Cab was formed or has there actually been a shift in the type of crime you’re witnessing?

MG: You’d get people that would be engaged in burglaries, thefts, maybe shoddy workmanship around roofing, guttering, that type of stuff. People involved in the second-hand car trade, which is also used to launder money and transfer assets into the country and out of the country as well. You have all those illicit fuel laundering, cigarette smuggling, all those areas as well.

FC: What about the type of assets? Maybe I’m wrong but typically I would have thought it might have been property and cars and things like that. Has there been a shift away from that as criminals become more sophisticated?

MG: No, I’m here five months and there are a couple of consistent things that I’ve seen. So, our targets will probably have at least one if not a number of high-value cars. They will have an extension done to their house that is in the keeping of the area or locale, probably without planning permission. They will also have watches, jewellery. They will have gone on holidays, maybe not just one but a couple of holidays throughout Europe or America for a week, two weeks at a time, way above and beyond what their own income can support. And again clothing, expensive clothing, runners. jeans, jackets, handbags.

FC: Would those you profile usually have jobs? 

MG: Some of them would have employment, but they’d be on the record for paying maybe not a huge amount?  Some of them will be claiming social welfare. Some may never have to claim social welfare. Some will also invest in property that they rent out.

Some of them will get mortgages and pay them off with the proceeds of crime.

FC: Okay. So that’s a bit more sophisticated than cash and consumable goods. How many would put money overseas or try and get it out of the country? I know that may not be common but if it happens what sort of mechanisms would be used?

MG: We just can’t give you figures for how much goes abroad. We know that money has to leave the island. Sometimes it’s as simple as it’s hidden in vehicles that are either personal or commercial that go by ferry.

FC: Cash?

MG: Yeah, it’s cash. And if you look at the amounts of cash that have been seized by ourselves recently, we had one there somewhere around a million euro seized. Our colleagues in the garda national drugs and organised crime bureau, they had €4 million seized down in Kerry there. So that shows you the amount of cash that’s floating around. 

FC: In the Coronavirus era, cash is not what most normal people are using but that’s not something you’re noticing in criminal circles in the last few months? 

MG: Just that there is an abundance of actual cash in the system. If you think about it, if you want to buy drugs, you pay with cash. Laser cards don’t really work for that business.

If you look at our Twitter feed, if you look at the garda Twitter feed, it’ll tell you the amount of substantial cash seizures. There were often drugs with them. Sometimes it’s just purely cash. 

When we do the searches we find money. It’s hidden in cars, glove boxes, in the boots of cars. It is literally – it’s just lying there. It’s in drawers. It’s in concealments in the houses. We’ve also found encrypted phones in some of the searches. 

Encrypted phones have been seized all around Europe in recent months. Earlier this year police forces managed to infiltrate the EncroChat network, widely used by organised crime figures, in an operation led by French police.

A bottom up deterrent

FC: On a different note, is there an issue with criminal funds coming into Ireland maybe from China, from Russiam from a different type of criminal enterprise? Is this something that you would come across in the Cab? Have there been investigations around that?

MG: There was a search recently in Tipperary where we believe the proceeds of a crime elsewhere were invested in the second-hand car trade in Ireland.  So that’d be an example – it’s part of a whole money laundering process. A crime is committed, cars are bought, they are brought here to Ireland and sold for the funds to be repatriated at some future stage. I’m sure there are other ways but currently the second hand car trade appears to be a favoured medium for money laundering and getting assets and funds back and forth at the minute.

FC: Sure. So I suppose scandals on the corporate level, like Wirecard, that is in the sights of the economic crime unit, maybe more than the Cab.

MG: The economic crime bureau would deal with that, business email compromise, they would deal with that.

People sometimes forget that the Criminal Assets Bureau is based on civil forfeiture. We need criminality and we need assets whereas the Economic Crime Bureau would go after the crime itself. We’re ‘in rem’, the legal term, we go after the property. You’re a criminal, what assets have you got that came from criminality. Our whole mission is to deny and deprive you of the assets that you have acquired resulting from criminality.

FC: What do you think have been the big successes of late?

MG: Well, in the last few years the Criminal Assets Bureau has increased the number of Section 2 orders before the High Court, which means cases that are taken by the Bureau, we’ve gone after our targets, we’ve been able to make a case to the courts and convince them that we’ve done our work properly, that there is criminality there and that the assets have come from that. But it’s not just the headliners, it’s the smaller criminals as well because the amount was reduced from €13,000 to €5,000 so we’ve looked at people who have assets over €5,000. That’s having an impact locally, in local communities. And it wouldn’t be unusual for us during the course of a search to have local citizens pass by and say, ‘well done, good job”

And these wouldn’t be household names that we’ve targeted in that town or that village, but it does have an impact, a real impact for the local community to see the Criminal Assets Bureau coming in.

FC: As you mentioned there, under legislation introduced in 2016, the threshold for invoking the Proceeds of Crime Act was reduced from €13,000 to €5,000, significantly extending CAB’s reach. It was introduced for that purpose but does it stretch resources because it kind of puts a whole different level of criminal within the ambit of the Bureau?

MG: No, because in tandem with that we had the local profilers trained up. So they are our eyes and ears on the ground. So they help us to identify the local criminals and the assets and they assist us then on the morning of the search with our further enquiries. And it helps the local community, the local guards, the local joint policing committee as well. It all works together quite well. I suppose policing like everywhere else – and the Criminal Assets Bureau – you’ll never have enough resources but we have what we have. And we do quite well with it.

FC: Do any of those smaller investigations, do they ever open up anything larger?

MG: You’ll often find that they are tied in to maybe another element of criminality, that mightn’t be immediately obvious but can become so subsequently.

Because if you think about it, your street dealer gets the drugs from somebody else higher up the food chain, and  the local person who’s big in the small town, they have to get them from somewhere else. So there is connectivity between the most remote parish and some of the bigger names.

“I’ve no doubt, in time, people engaged in CEO fraud, invoice redirect, romance fraud will become targets of the Criminal Assets Bureau because those crimes are being committed here in Ireland.”

Detective Chief Superintendent Michael Gubbins

FC: The watchdog for global money laundering, the Financial Action Task Force, in its 2017 Mutual Evaluation of Ireland, noted that while asset confiscation initiatives have strong political and national support, the value of criminal proceeds confiscated and forfeited appeared modest. Did you think that was fair criticism and has it been addressed? 

MG: Again, it goes back to the local community. So Francesca is a local street dealer. Everybody knows you are dealing drugs. You probably just bought a fancy car, and a watch.  You may not have the complete trappings but that can have as big an impact locally as taking down one of the big headline people. And it’s important to let the communities know, the Criminal Assets Bureau is as interested in those people as I suppose the people that fill the headlines occasionally.

FC: As a deterrent?

MG: Absolutely as a deterrent it nips it in the bud. Because if you don’t go after them when they are small or medium, before anybody knows it they could be a much bigger player in the game. And then somebody will be asking, where did they come from. We now have a tool to go after them. So that’s why it can be a deterrent. And also, it gives some level of support to the local community. 

FC: And I suppose then you don’t feel that it has in any way hampered you from progressing  bigger investigations.

MG: If you look at our annual reports, we still take on a number of substantial targets every year that go before the courts. Bear in mind that some of those could take a while. A lot of work goes into getting them before the courts. They are not forgotten about. That’s the important message there. We’re trying to manage both sides. 

FC: Are there any hindrances in that whole court process? It’s a phased process and are there any, I suppose, impediments in the process that you think it would be wise to review at this point.

MG: No. I suppose the beauty of the Criminal Assets Bureau and the proceeds of crime act as it moves through the High Court is that if somebody makes an anonymous call here to us, they don’t have to make a witness statement. They don’t have to go to court. So if somebody rings in about Francesca, we take it from there.  We never go back to them. And then the burden of proof is on the civil level, it’s on the balance of probability they are the proofs that we work towards – it’s probably nearer the criminal end than the civil end.

FC: And that’s based on a whole load of judgments that have sort of built up. 

MG: Yeah but also the quality of work that’s put in by the individual team rooms here. Don’t forget your team room is led by a detective sergeant but it is made up of detectives, guards, Revenue customs, Revenue taxes and Social Welfare, supported by our forensic accountants, our analysts and the Bureau legal officer and the rest of the team.

FC: Would you be able to give me a flavour of maybe one of the more sophisticated asset hiding schemes that you’ve encountered or that you’d be aware about?

MG: Most of these guys will actually buy physical assets; jewellery, watches, clothes, houses, cars. It’s lifestyle. It’s holidays. You may have seen the one there where there was a guy engaged with cryptocurrency.

Chief Superintendent Gubbins is referring to a case from earlier this year where a drug dealer amassed and then lost a €55 million bitcoin fortune when he hid the codes for the cryptocurrency accounts with his fishing rod which then went missing. The Bureau’s seizure of the cryptocurrency ‘Ethereum’ last year was the first of its kind by any law enforcement agency worldwide.  But the Cab chief plays it down. “There is some of that but it is not as prevalent as people might think,” he says.

FC: Do you always know that to be the case though? Do you feel that you might be missing stuff because maybe criminals are becoming more sophisticated? I mean, if people go down that route but don’t lose their account codes would that be something you’d be confident that you’d have the wherewithal to pursue? 

An international network

MG: I would be yeah. We have the team. We engage with Interpol, Europol, the CARIN (Camden Assets Recovery Interagency Network) and the ARO (Asset Recovery Offices) network, other law enforcement agencies and with revenue throughout Europe. Interpol gives us access to another 194 countries of expertise and communication. If we need help we can get it, we have our own in-house people as well who are actually very clever when it comes to cryptocurrency, who have their own experience and they actually teach on some courses in relation to this.

FC: What about money laundering in Ireland? Is Ireland a target for international money laundering? Are there legitimate businesses in Ireland that you believe are targeted? What is the state of play?

MG: That’s the whole purpose of criminality. It is to make money, launder it and make it clean. But when you begin to spend the money people know that’s not right because your job is X and you can’t have that source of income. The second-hand car trade is the most popular one that I’ve encountered for putting money through. I’m not saying there isn’t others. Maybe some fitness centres as well.

Any cash business has the potential to become a facility to launder and we’ll deal with them as they come but as I said since I’ve come here it’s been the second hand car trade.

FC: Obviously we’ve been hearing internationally, and at home, there’s an overlap between some big crime figures and the world of sport. Is that something that you’ve had any dealings with or had cause to investigate?

MG: No.

FC: Looking at some of the international press, there has been talk about whether there should be more targeting of people who may not be part of a criminal gang per se, but they would offer their professional expertise. Do you think that would be helpful?

MG: I suppose as part of our investigations, we’d often do what we call a professional search which is maybe somebody providing legal services or an accountant. It doesn’t necessarily mean that that person is part and parcel of the crime or the money laundering. They are there because they helped with conveyancing or they can help provide returns on tax or whatever.  Again, I’m not familiar with the fact that there’s ever been a solicitor or an accountant being a target of the Criminal Assets Bureau. I’m not here long enough to say that.

FC: Fair enough, it was raised on an international level. 

MG: I’ve no experience to answer that for you. I could sit here and speculate with you. But that’s no good.

FC: Would it be more effective if there was a united EU wide criminal assets system? 

MG: It would be useful to have something like the mutual assistance agreement in place around assets. Currently how it would operate is if we have a criminal here and they’ve got assets abroad, we would provide the criminality report in support of the equivalent criminal assets bureau taking an action in another jurisdiction.

Yes, it would be better. We have the CARIN and the ARO network, which allow for the sharing of knowledge and information in relation to these matters. But absolutely. Something like a mutual assistance agreement would help our job.

FC: Speed things up?

MG: It’d make it easier. There would be a process which is easier to follow.  It would  get over the issue of ‘what do we do, who do we call?’. If there is a process in place, then you know, right I want to do that so. If you follow the mutual assistance, it goes through to the DPP’s office, the Department of Justice, comes down the other side through the courts. If someone has to get a warrant or information to the other side, it will take time.

“You can be sitting in your bedroom. You can use bitcoin or whatever cryptocurrency you want of your choice and you can move it seamlessly and invisibly to somewhere else.”

Detective Chief Superintendent Michael Gubbins

The Criminal Assets Bureau is involved in what are called joint investigation teams (JIT). That’s ourselves, the guards and other law enforcement agencies working together on a number of matters. So if we had something like a mutual assistance act to help with getting assets abroad, that would help.

On occasion, some of our targets may have disposed of assets abroad to pay their liabilities to the Criminal Assets Bureau here. But we’ve no coercive power to do that.  If it’s a Revenue matter that’s within Cab, they have a mutual assistance that can help collect some of those revenues abroad within Europe but not when it comes to the seizure of assets.

FC: At the beginning, we were talking about things like CEO fraud. Are you seeing more of that these days, crime in the corporate sphere?

MG: I’m aware of it but it hasn’t really impacted here, which is not to say that it won’t. Our targets here are primarily around the sale and supply of drugs, theft, burglaries the usual. I’ve no doubt, in time, people engaged in CEO fraud, invoice redirect, romance fraud will become targets of the Criminal Assets Bureau because those crimes are being committed here in Ireland. And there are people resident in Ireland committing those crimes, therefore, they are bound to have assets here that are going to become targets of the Criminal Assets Bureau.

FC: Would you feel there may be a lag? Would that be fair to say?

MG: There would be a lag.

FC: So in your previous role you would have been at the coalface of that.

MG: Yes. I’d have seen that in my previous role but it may take a while. If you think about it, somebody commits romance fraud, CEO fraud, invoice redirects, the victims are hit. So then you have a problem; do the victims report everything to the guards? They’ve got better in relation to it. Now the guards have to identify who the suspects are. If they are outside the jurisdiction, we have to find if there is somebody that’s Irish, then there’s probably a money-laundering investigation, and maybe a Criminal Assets Bureau investigation in parallel. That’s where we would come in so that’s why there would be a bit of a time lag. But we do have a good working relationship with the Economic Crime Bureau, the Drugs and Organized Crime Bureau and the financial investigation unit.

Sometimes we’ll go on searches and we bring resources from the Cyber Crime Bureau, the Economic Crime Bureau, the Drugs Crime Bureau because the person that we’re after is in their sphere. And they’d be best placed to help us. 

I ask him what’s happening with the Cab’s investigation into the findings of the Moriarty Tribunal which looked at the awarding of the state’s second mobile phone license to Denis O’Brien’s Esat Digifone in 1995 but Gubbins won’t be drawn. He makes no comment.

When I ask him if there are many investigations that go beyond drugs and theft into the business sphere, he responds that there would be. He cites the recent High Court proceeds of crime case against disqualified US doctor William Porter, based in Co Clare, who took money from terminally ill patients for alternative therapies, like using crystals.

He tells me in the course of our conversation that most Cab targets allow their assets to be forfeited without putting up a fight in court. They simply walk away.

Cross border cooperation

FC: What about the whole Brexit scenario – traditionally there have been concerns around diesel laundering and cigarette smuggling. Are you satisfied there will be sufficient cross-border cooperation? 

MG: There’s already in place a joint action task force, which is based with our colleagues in the PSNI,  HMRC, the National Crime agency, the guards, the Criminal Assets Bureau.

That’s in place. We regularly have operations that involve constabularies in the UK, the national crime agencies and again our colleagues in the PSNI

We have also had operations in the past with our colleagues in the US like Phantom Secureties. This guy set up a company where he had BlackBerry phones and he encrypted them. And they were used by the drugs trade basically, to support their communications.

A couple of years ago, there was well over half a million seized from two bank accounts here. That would have come about because of our cooperation with our colleagues in the US.

FC: But might there be an uptick in border activity? Would that be anticipated in a no-deal scenario? Is this being looked at in a proactive way? 

MG: If you look at the second-hand car trade, you see a lot of cars coming back and forth. You’d have to wonder.

FC: Do you see a lot of carousel fraud going on as well?

MG: There would be some Vat carousel but again I can’t quantify it for you but there is an element of it.

FC: I know you’re in the job for a short period of time, but I suppose in terms of institutional knowledge, would you be aware of any shifts or trends in recent times? Or would you anticipate what might be more prevalent in the coming years?

MG: I think we will see a shift towards the use of cryptocurrencies to move funds around.

While we’ve seen some of it, I think we’ll come across more of it because it’s a convenient anonymous manner in which to transfer funds around globally. You can be sitting in your bedroom. You can use bitcoin or whatever cryptocurrency you want of your choice and you can move it seamlessly and invisibly to somewhere else. Somebody can have their credit card attached to it. They can use it to make purchases. It’s just so easy to move it around.

FC: And in terms of traceability, as you just said there, if it’s linked to a credit card, I suppose nothing’s invisible. Is there truth to that too?

MG: Every contact leaves a trace. But you have to figure out how did the money got into that account, who controls it, where does the money go. You’ve got to identify where’s the wallet that I’m interested in? 

So there’s a lot of work and a need for a lot of further cooperation, more cooperation between law enforcement. You asked me about cybercrime earlier. If you think about cybercrime, it is a truly global crime. It knows no boundaries. Your injured party is in Ireland, the infrastructure behind it is in the UK, the person who did the deed could be somewhere in Europe and the funds maybe for that crime or the people behind it could be anywhere. So you need full cooperation between law enforcement agencies. 

I think it’s there. I think it’s going to have to increase and improve in speed. Speed is of the essence when you’re tracking that information.

FC: Because a lot of these transactions can happen in a matter of seconds, less.

MG: A matter of seconds. And the data may not be there to support your investigation. Hence the need for speed.

FC: Why isn’t it there?

MG: Because of data protection. It’s just not there. You have bulletproof hosting companies that don’t hold the data. You’ve heard of the concept of crime-as-a-service. [Crime-as-a-service is where an experienced cyber criminal develops a suite of tools or services that can be sold on for use to other criminals]. That will facilitate the monies being moved. Law enforcement is up against that. How do we track it? How do we trace it? Who is behind it? Sometimes we come up against a brick wall.

But law enforcement has made good advances in some of these areas and a lot of it is down to continued cooperation between the various law enforcement agencies.

If you look at Europol they are very good at coordinating member states and external members in relation to the investigation of cyber crime. They’ve worked with the US, Australia and New Zealand in relation to take down of sites and the investigation of the dark web.

You can’t do it on your own. It’s a bit of a cliché but it takes a network to take down a network.

Asked about the private sphere and corporate investigators like Kroll, Gubbins says private industry has a huge role to play in the reporting of crime in general, particularly cyber crime. 

“If a cyber incident happens the victim is probably going to call their solicitor first, then their HR, they’ll call their IT department. Then they’ll probably call their cyber insurance people. They’ll call everybody. The last person they’ll call is law enforcement. But if law enforcement isn’t told what’s happening, we can’t investigate it and we can’t provide preventative advice to other injured parties and it becomes difficult to get to the suspects. 

It’s the same with money laundering. Again we are totally anonymous. Ring us, call us, email us. You don’t have to go to court. You don’t have to make a witness statement. We take on the investigation. That’s the beauty of the Criminal Assets Bureau model.

FC: I suppose time is of the essence.

MG: It’s no more than with some of those romance frauds where people have been blackmailed online, they’re reluctant to tell their family, they’re reluctant to tell law enforcement. There is an embarrassment about it. With some of the cyber incidents, they don’t realise it’s a crime. They may not be aware that the local law enforcement has a capability around that and is interested in investigating those matters.

It’s the same with money laundering and with asset seizures. Don’t presume everybody knows what you know. Tell us.