Jump to content

Money laundering

From Wikipedia, the free encyclopedia
(Redirected from Dirty money)

Placing 'dirty' money in a service company, where it is layered with legitimate income and then integrated into the flow of money, is a common form of money laundering.

Money laundering is the process of illegally concealing the origin of money obtained from illicit activities (often known as dirty money) such as drug trafficking, underground sex work, terrorism, corruption, embezzlement, and treason, and converting the funds into a seemingly legitimate source, usually through a front organization. As financial crime has become more complex and financial intelligence is more important in combating international crime and terrorism, money laundering has become a prominent political, economic, and legal debate. Money laundering is ipso facto illegal; the acts generating the money almost always are themselves criminal in some way (for if not, the money would not need to be laundered).

In the past, the term "money laundering" was applied only to financial transactions related to organized crime. Today its definition is often expanded by government and international regulators such as the US Office of the Comptroller of the Currency to mean "any financial transaction which generates an asset or a value as the result of an illegal act," which may involve actions such as tax evasion or false accounting. In the UK, it does not need to involve money, but any economic good. Courts involve money laundering committed by private individuals, drug dealers, businesses, corrupt officials, members of criminal organizations such as the Mafia, and even states.

In United States law, money laundering is the practice of engaging in financial transactions to conceal the identity, source, or destination of illegally gained money. In United Kingdom law, the common law definition is wider. The act is defined as "the process by which the proceeds of crime are converted into assets which appear to have a legitimate origin, so that they can be retained permanently or recycled into further criminal enterprises".[1]

History

[edit]

While existing laws were used to fight money laundering during the period of Prohibition in the United States during the 1930s, dedicated Anti-Money Laundering legislation was only implemented in the 1980s.[2] Organized crime received a major boost from Prohibition and a large source of new funds that were obtained from illegal sales of alcohol. The successful prosecution of Al Capone on tax evasion brought in a new emphasis by the state and law enforcement agencies to track and confiscate money, but existing laws against tax evasion could not be used once gangsters started paying their taxes.

In the 1980s, the war on drugs led governments again to turn to money laundering rules in an attempt to track and seize the proceeds of drug crimes in order to catch the organizers and individuals running drug empires. It also had the benefit, from a law enforcement point of view, of turning rules of evidence "upside down". Law enforcers normally have to prove an individual is guilty to seize their property, but with money laundering laws, money can be confiscated and it is up to the individual to prove that the source of funds is legitimate to get the money back.[3] This makes it much easier for law enforcement agencies and provides for much lower burdens of proof. However, this process has been abused by some law enforcement agencies to take and keep money without strong evidence of related criminal activity, to be used to supplement their own budgets.[citation needed]

The 11 September attacks in 2001, which led to the Patriot Act in the U.S. and similar legislation worldwide, led to a new emphasis on money laundering laws to combat terrorism financing.[4] The Group of Seven (G7) nations used the Financial Action Task Force on Money Laundering to put pressure on governments around the world to increase surveillance and monitoring of financial transactions and share this information between countries. Starting in 2002, governments around the world upgraded money laundering laws and surveillance and monitoring systems of financial transactions. Anti-money laundering regulations have become a much larger burden for financial institutions and enforcement has stepped up significantly.

During 2011–2015 a number of major banks faced ever-increasing fines for breaches of money laundering regulations. This included HSBC, which was fined $1.9 billion in December 2012,[5] and BNP Paribas, which was fined $8.9 billion in July 2014 by the U.S. government.[6] Many countries introduced or strengthened border controls on the amount of cash that can be carried and introduced central transaction reporting systems where all financial institutions have to report all financial transactions electronically. For example, in 2006, Australia set up the AUSTRAC system and required the reporting of all financial transactions.[7]

With the surge in digital asset late 2010s, there's been a noticeable rise in money laundering and fraud tied to cryptocurrency. In 2021 alone, cybercriminals managed to secure US$14 billion in cryptocurrency through various illicit activities.[8]

Chinese organized criminal groups have become the principal money launderers for drug cartels in Mexico, Italy, and elsewhere.[9][10][11][12]

Features

[edit]

Definition

[edit]

Money laundering is the conversion or transfer of property; the concealment or disguising of the nature of the proceeds; the acquisition, possession or use of property, knowing that these are derived from criminal acts; the participating in or assisting the movement of funds to make the proceeds appear legitimate.

Money obtained from certain crimes, such as extortion, insider trading, drug trafficking, human trafficking, and illegal gambling is "dirty" and needs to be "cleaned" to appear to have been derived from legal activities, so that banks and other financial institutions will deal with it without suspicion. Money can be laundered by many methods that vary in complexity and sophistication.

Money laundering typically involves three steps: The first involves introducing cash into the financial system by some means ("placement"); the second involves carrying out complex financial transactions to camouflage the illegal source of the cash ("layering"); and finally, acquiring wealth generated from the transactions of the illicit funds ("integration"). Some of these steps may be omitted, depending on the circumstances. For example, non-cash proceeds that are already in the financial system would not need to be placed.[13]

According to the United States Treasury Department:

Money laundering is the process of making illegally-gained proceeds (i.e., "dirty money") appear legal (i.e., "clean"). Typically, it involves three steps: placement, layering, and integration. First, the illegitimate funds are furtively introduced into the legitimate financial system. Then, the money is moved around to create confusion, sometimes by wiring or transferring through numerous accounts. Finally, it is integrated into the financial system through additional transactions until the "dirty money" appears "clean".[14]

Methods

[edit]

List of methods

[edit]

Money laundering can take several forms, although most methodologies can be categorized into one of a few types. These include "bank methods, smurfing [also known as structuring], currency exchanges, and double-invoicing".[15]

  • Structuring: Often known as smurfing, is a method of placement whereby cash is broken into smaller deposits of money, used to defeat suspicion of money laundering and to avoid anti-money laundering reporting requirements. A sub-component of this is to use smaller amounts of cash to purchase bearer instruments, such as money orders, and then ultimately deposit those, again in small amounts.[16]
  • Bulk cash smuggling: This involves physically smuggling cash to another jurisdiction and depositing it in a financial institution, such as an offshore bank, that offers greater bank secrecy or less rigorous money laundering enforcement.[17]
  • Cash-intensive businesses: In this method, a business is typically expected to receive a large proportion of its revenue as cash uses its accounts to deposit criminally derived cash. This method of money laundering often causes organized crime and corporate crime to overlap.[18] Such enterprises often operate openly and in doing so generate cash revenue from incidental legitimate business in addition to the illicit cash. In such cases, the business will usually claim all cash received as legitimate earnings. Service businesses are best suited to this method, as such enterprises have little or no variable costs and/or a large ratio between revenue and variable costs, which makes it difficult to detect discrepancies between revenues and costs. Examples are parking structures, strip clubs, tanning salons, car washes, arcades, bars, restaurants, casinos, barber shops, DVD stores, movie theaters, and beach resorts.
  • Trade-based laundering: This method is one of the newest and most complex forms of money laundering.[19] This involves under- or over-valuing invoices to disguise the movement of money.[20] For example, the art market has been accused of being an ideal vehicle for money laundering due to several unique aspects of art such as the subjective value of artworks as well as the secrecy of auction houses about the identity of the buyer and seller.[21] According to the National Crime Agency, one strategy that is favored by high-net-worth individuals is specialist storage facilities. Art kept in these spaces has been used by individuals to evade sanctions and launder the proceeds of crime.[22]
  • Shell companies and trusts: Trusts and shell companies disguise the true owners of money. Trusts and corporate vehicles, depending on the jurisdiction, need not disclose their true owner. Sometimes referred to by the slang term rathole, though that term usually refers to a person acting as the fictitious owner rather than the business entity.[23]
  • Round-tripping: Here, money is deposited in a controlled foreign corporation offshore, preferably in a tax haven where minimal records are kept, and then shipped back as a foreign direct investment, exempt from taxation. A variant of this is to transfer money to a law firm or similar organization as funds on account of fees, then to cancel the retainer and, when the money is remitted, represent the sums received from the lawyers as a legacy under a will or proceeds of litigation.[citation needed]
  • Bank capture: In this case, money launderers or criminals buy a controlling interest in a bank, preferably in a jurisdiction with weak money laundering controls, and then move money through the bank without scrutiny.
  • Invoice Fraud: An example is when a criminal contacts a company saying that the supplier payment details have changed. They then provide alternative, fraudulent details in order for you to pay them money.[24]
  • Casinos: In this method, an individual walks into a casino and buys chips with illicit cash. The individual will then play for a relatively short time. When the person cashes in the chips, they will expect to take payment in a check, or at least get a receipt so they can claim the proceeds as gambling winnings.[17]
  • Other gambling: Money is spent on gambling, preferably on high odds games. One way to minimize risk with this method is to bet on every possible outcome of some event that has many possible outcomes, so no outcome(s) have short odds, and the bettor will lose only the vigorish and will have one or more winning bets that can be shown as the source of money. The losing bets will remain hidden.
  • Black salaries: A company may have unregistered employees without written contracts and pay them cash salaries. Dirty money might be used to pay them.[25]
  • Tax amnesties: For example, those that legalize unreported assets and cash in tax havens.[26]
  • Transaction Laundering: When a merchant unknowingly processes illicit credit card transactions for another business.[27] It is a growing problem[28][29] and recognised as distinct from traditional money laundering in using the payments ecosystem to hide that the transaction even occurred[30] (e.g. the use of fake front websites[31]). Also known as "undisclosed aggregation" or "factoring".[32][33]
  • Online job marketplaces such as Freelancer.com and Fiverr, which accept funds from clients and hold them in escrow to pay freelancers. A money launderer can post a token job on one of these sites, and send the money for the site to hold in escrow. The launderer (or his associate) can then sign on as a freelancer (using a different account and IP address), accept and complete the job, and be paid the funds.[34]
  • Through Sports: Investigation teams have identified sport profits as a common way to launder money. In Latin America, in particular, drug traffickers are frequently found to own Soccer Clubs, and to launder money through their intermediate, by buying and selling players, selling tickets and merchandise[35]

Digital electronic money

[edit]

In theory, electronic money should provide as easy a method of transferring value without revealing identity as untracked banknotes, especially wire transfers involving anonymity-protecting numbered bank accounts. In practice, however, the record-keeping capabilities of Internet service providers and other network resource maintainers tend to frustrate that intention. While some cryptocurrencies under recent development have aimed to provide more possibilities of transaction anonymity for various reasons, the degree to which they succeed — and, in consequence, the degree to which they offer benefits for money laundering efforts — is controversial. Solutions such as ZCash and Monero ― known as privacy coins[36] ― are examples of cryptocurrencies that provide unlinkable anonymity via proofs and/or obfuscation of information (ring signatures).[37] While not suitable for large-scale crimes, privacy coins like Monero are suitable for laundering money made through small-scale crimes.[38]

Apart from traditional cryptocurrencies, Non-Fungible Tokens (NFTs) are also commonly used in connection with money laundering activities.[39] NFTs are often used to perform Wash Trading by creating several different wallets for one individual, generating several fictitious sales and consequently selling the respective NFT to a third party.[40] According to a report by Chainalysis, these types of wash trades are becoming increasingly popular among money launderers especially due to the largely anonymous nature of transactions on NFT marketplaces.[41][42] Auction platforms for NFT sales may face regulatory pressure to comply with anti-money laundering legislation.[43]

Additionally, cryptocurrency mixers have been increasingly used by cybercriminals over the past decade to launder funds.[44] A mixer blends the cryptocurrencies of many users together to obfuscate the origins and owners of funds, enabling a greater degree of privacy on public blockchains like Bitcoin and Ethereum.[45] Although not explicitly illegal in many jurisdictions, the legality of mixers is controversial.[46] The use of the mixer Tornado Cash in the laundering of funds by the Lazarus Group led the Office of Foreign Assets Control to sanction it, prompting some users to sue the Treasury Department.[47] Proponents have argued mixers allow users to protect their privacy and that the government lacks the authority to restrict access to decentralized software. In the United States, FinCEN requires mixers to register as money service businesses.[48]

In 2013, Jean-Loup Richet, a research fellow at ESSEC ISIS, surveyed new techniques that cybercriminals were using in a report written for the United Nations Office on Drugs and Crime.[49] A common approach was to use a digital currency exchanger service which converted dollars into a digital currency called Liberty Reserve, and could be sent and received anonymously. The receiver could convert the Liberty Reserve currency back into cash for a small fee. In May 2013, the US authorities shut down Liberty Reserve, charging its founder and various others with money laundering.[50]

Another increasingly common way of laundering money is to use online gaming. In a growing number of online games, such as Second Life and World of Warcraft, it is possible to convert money into virtual goods, services, or virtual cash that can later be converted back into money.[34]

To avoid the usage of decentralized digital money such as Bitcoin for the profit of crime and corruption, Australia is planning to strengthen the nation's anti-money laundering laws.[51] The characteristics of Bitcoin—it is completely deterministic, protocol-based and can be difficult to censor[citation needed]—make it possible to circumvent national laws using services like Tor to obfuscate transaction origins. Bitcoin relies completely on cryptography, not on a central entity running under a KYC framework. There are several cases in which criminals have cashed out a significant amount of Bitcoin after ransomware attacks, drug dealings, cyber fraud and gunrunning.[52] However, many digital currency exchanges are now operating KYC programs under threat of regulation from the jurisdictions they operate.[53][54]

Reverse money laundering

[edit]

Reverse money laundering is a process that disguises a legitimate source of funds that are to be used for illegal purposes.[55] It is usually perpetrated for the purpose of financing terrorism[56] but can be also used by criminal organizations that have invested in legal businesses and would like to withdraw legitimate funds from official circulation. Unaccounted cash received via disguising financial transactions is not included in official financial reporting and could be used to evade taxes, hand in bribes and pay "under-the-table" salaries.[57] For example, in an affidavit filed on 24 March 2014 in United States District Court, Northern California, San Francisco Division, FBI special agent Emmanuel V. Pascua alleged that several people associated with the Chee Kung Tong organization, and California State Senator Leland Yee, engaged in reverse money laundering activities.

The problem of such fraudulent encashment practices (obnalichka in Russian) has become acute in Russia and other countries of the former Soviet Union. The Eurasian Group on Combating Money Laundering and Financing of Terrorism (EAG) reported that the Russian Federation, Ukraine, Turkey, Serbia, Kyrgyzstan, Uzbekistan, Armenia and Kazakhstan have encountered a substantial shrinkage of tax base and shifting money supply balance in favor of cash. These processes have complicated the planning and management of the economy and contributed to the growth of the shadow economy.[58]

Magnitude

[edit]

Many regulatory and governmental authorities issue estimates each year for the amount of money laundered, either worldwide or within their national economy. In 1996, a spokesperson for the IMF estimated that 2–5% of the worldwide global economy involved laundered money.[59] The Financial Action Task Force on Money Laundering (FATF), an intergovernmental body set up to combat money laundering, stated, "Due to the illegal nature of the transactions, precise statistics are not available and it is therefore impossible to produce a definitive estimate of the amount of money that is globally laundered every year. The FATF therefore does not publish any figures in this regard."[60] Academic commentators have likewise been unable to estimate the volume of money with any degree of assurance.[13] Various estimates of the scale of global money laundering are sometimes repeated often enough to make some people regard them as factual—but no researcher has overcome the inherent difficulty of measuring an actively concealed practice.

Regardless of the difficulty in measurement, the amount of money laundered each year is in the billions of US dollars and poses a significant policy concern for governments.[13] As a result, governments and international bodies have undertaken efforts to deter, prevent, and apprehend money launderers. Financial institutions have likewise undertaken efforts to prevent and detect transactions involving dirty money, both as a result of government requirements and to avoid the reputational risk involved. Issues relating to money laundering have existed as long as there have been large-scale criminal enterprises. Modern anti-money laundering laws have developed along with the modern War on Drugs.[61] In more recent times anti-money laundering legislation is seen as an adjunct to the financial crime of terrorist financing in that both crimes usually involve the transmission of funds through the financial system (although money laundering relates to where the money has come from, and terrorist financing relating to where the money is going to). Finally, people, vessels, organisations and governments can be sanctioned due to international law-breaking, war (and of course tit-for-tat sanctions), and still want to move funds into markets where they are persona non grata.

Transaction laundering is a massive and growing problem.[62] Finextra estimated that transaction laundering accounted for over $200 billion in the US in 2017 alone, with over $6 billion of these sales involving illicit goods or services, sold by nearly 335,000 unregistered merchants.[63] Money laundering can erode democracy.[64][65]

Notable cases

[edit]
1998 investigation, United States Senate, Contribution Laundering/Third-Party Transfers. Includes investigation of Gandhi Memorial International Foundation.
  • Bank of Credit and Commerce International: Unknown amount, estimated in billions, of criminal proceeds, including drug trafficking money, laundered during the mid-1980s.[66]
  • Bank of New York: US$7 billion of Russian capital flight laundered through accounts controlled by bank executives, the late 1990s.[67]
  • BNP Paribas, in June 2014, pleaded guilty to falsifying business records and conspiracy, having violated U.S. sanctions against Cuba, Iran, and Sudan. It agreed to pay an $8.9 billion fine, the largest ever for violating U.S. sanctions.[6][68]
  • BSI Bank, in May 2017, was shut down by the Monetary Authority of Singapore for serious breaches of anti-money laundering requirements, poor management oversight of the bank's operations, and gross misconduct of some of the bank's staff.[69]
  • BTA Bank: $6 billion of bank funds embezzled or fraudulently loaned to shell companies and offshore holdings by the bank's former chairman and CEO Mukhtar Ablyazov.[70]
  • Charter House Bank: Charter House Bank in Kenya was placed under statutory management in 2006 by the Central Bank of Kenya after it was discovered the bank was being used for money laundering activities by multiple accounts containing missing customer information. More than $1.5 billion had been laundered before the scam was uncovered.[71]
  • Danske Bank + Swedbank: $30 billion – $230 billion US dollars laundered through its Estonian branch.[72][73][74] This was revealed on 19 September 2018.[75] Investigations by Denmark, Estonia, the U.K. and the U.S. were joined by France in February 2019. On 19 February 2019, Danske Bank announced that it would cease operating in Russia and the Baltic States.[76][77] This statement came shortly after Estonia's banking regulator Finantsinspektsioon[78] announced that they would close the Estonian branch of Danske Bank.[79] The investigation has grown to include Swedbank, which may have laundered $4.3 billion.[80][81] More at Danske Bank money laundering scandal.
  • Deutsche Bank was accused in a vast money laundering scheme, dubbed the Global Laundromat, involving secret Russian accounts that were transferred from European Union banks in Estonia, Latvia and Cyprus between 2010 and 2014. Newspaper sources estimated the total value of laundered currency to be as high as $80bn. The bank is also under investigation for its involvement in Europe's biggest banking scandal through Denmark's Danske Bank, which laundered €200bn, also from Russian sources.[82]
  • United Arab Emirates' Dubai Islamic Bank was accused of "knowingly and purposefully" providing "financial services and other forms of material support to al-Qaeda operatives" when the terrorist group was planning the execution of the 11 September attacks against the United States.[83] In addition, the Sharjah branch of Standard Chartered Bank was also involved in opening the accounts of the terror operatives and allowing financial transactions to take place between them and Khalid Sheikh Mohammed, "the principal architect of the 9/11 attacks".[84]
  • FinCEN Files: On 21 September 2020, The International Consortium of Investigative Journalists (ICIJ) revealed FinCEN Files, about the involvement of about $2tn of transactions by some of the world's biggest banks.[85] FinCEN files also revealed that Dubai-based Gunes General Trading, based in Dubai funneled Iranian state money via UAE's central banking system and processed $142 million in 2011 and 2012.[86]
  • Fortnite: In 2018, Cybersecurity firm Sixgill[87] discovered that stolen credit card details may be used to purchase Fortnite's in-game currency (V-Bucks) and in-game purchases, for the account to then be sold online for "clean" money.[88][89] Epic Games, the makers of Fortnite, responded by urging customers to secure their accounts.[90]
  • HSBC, in December 2012, paid a record $1.9 Billion fine for money-laundering hundreds of millions of dollars for drug traffickers, terrorists and sanctioned governments such as Iran.[91] The money-laundering occurred throughout the 2000s.
  • Institute for the Works of Religion: Italian authorities investigated suspected money laundering transactions amounting to US$218 million made by the IOR to several Italian banks.[92]
  • Liberty Reserve, in May 2013, was seized by United States federal authorities for laundering $6 billion.[93][94][95]
  • Nauru: US$70 billion of Russian capital flight was laundered through unregulated Nauru offshore shell banks, the late 1990s[96]
  • Sani Abacha: US$2–5 billion of government assets laundered through banks in the UK, Luxembourg, Jersey (Channel Islands), and Switzerland, by the president of Nigeria.[97]
  • Standard Bank: Standard Bank South Africa London Branch – The Financial Conduct Authority (FCA) has fined Standard Bank PLC (Standard Bank) £7,640,400 for failings relating to its anti-money laundering (AML) policies and procedures over corporate and private bank customers connected to politically exposed persons (PEPs).[98]
  • Standard Chartered: paid $330 million in fines for money-laundering hundreds of billions of dollars for Iran. The money-laundering took place in the 2000s and occurred for "nearly a decade to hide 60,000 transactions worth $250 billion".[99]
  • Westpac: On 24 September 2020, Westpac and AUSTRAC agreed to an AUD $1.3 billion penalty over Westpac's breaches of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 - the largest fine ever issued in Australian corporate history.[100]

Individuals

[edit]
  • Jose Franklin Jurado-Rodriguez, a Harvard College and Columbia University Graduate School of Arts and Sciences Economics Department alumnus, was convicted in Luxembourg in June 1990 "in what was one of the largest drug money laundering cases ever brought in Europe"[101] and the US in 1996 of money laundering for the Cali Cartel kingpin Jose Santacruz Londono.[102] Jurado-Rodriguez specialized in "smurfing".[103]
  • Ng Lap Seng: The Chinese billionaire real estate developer from Macau was sentenced to four years in prison[104] in May 2018 for bribing two diplomats, including the former president of the United Nations General Assembly, John William Ashe, to help him build a conference center in Macau for the United Nations Office for South-South Cooperation (UNOSSC), headed by Director Yiping Zhou. The corruption case was the worst financial scandal for the United Nations since the abuse of the Iraqi oil-for-food program more than 20 years ago. Ng Lap Seng, 69, was convicted in Federal District Court in Manhattan on two counts of violating the Foreign Corrupt Practices Act, one count of paying bribes, one count of money laundering, and two counts of conspiracy.
  • Ferdinand Marcos: Unknown amount, estimated at US$10 billion of government assets laundered through banks and financial institutions in the United States, Liechtenstein, Austria, Panama, Netherlands Antilles, Cayman Islands, Vanuatu, Hong Kong, Singapore, Monaco, the Bahamas, the Vatican and Switzerland.[105]

Laws by country

[edit]
  • United Kingdom: Implemented the Proceeds of Crime Act (POCA) to establish money laundering offenses and facilitate asset recovery.
  • United States: Enacted the Corporate Transparency Act (CTA) requiring companies to disclose their beneficial owners to the Financial Crimes Enforcement Network (FinCEN), effectively banning anonymous shell corporations and enhancing transparency in corporate ownership.
  • Australia: Introduced the Anti-Money Laundering and Counter-Terrorism Financing Act (AML/CTF Act) to regulate financial transactions and enhance transparency.
  • Singapore: Established the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act to confiscate proceeds from serious crimes.
  • Switzerland: Strengthened its anti-money laundering framework through the Swiss Anti-Money Laundering Act (AMLA), which mandates due diligence and reporting requirements for financial institutions.

Statistics

[edit]

Below table shows the annual reported money laundering cases per 100,000 population for individual countries for the last available year according to the United Nations Office on Drugs and Crime.[106] Proportion of unreported money laundering and definition of money laundering might differ between countries.

See also

[edit]

References

[edit]
  1. ^ "Money Laundering Offences". The Crown Prosecution Service (CPS). Archived from the original on 15 May 2024. Retrieved 15 May 2024.
  2. ^ "History of Anti-Money Laundering Laws". Financial Crimes Enforcement Network (FINCEN). Archived from the original on 28 May 2024. Retrieved 15 May 2024.
  3. ^ "Russian oligarchs in UK told to explain luxury lifestyles". BBC News. 3 February 2018. Archived from the original on 14 December 2020. Retrieved 17 February 2021.
  4. ^ Morris-Cotterill, Nigel (1999). "A brief history of money laundering". Archived from the original on 24 February 2016. Retrieved 17 February 2016.
  5. ^ "HSBC agrees $1.9bn US penalties". BBC News. 11 December 2012. Archived from the original on 7 July 2014. Retrieved 5 October 2020.
  6. ^ a b Protess, Ben; Silver-Greenberg, Jessica (30 June 2014). "BNP Paribas Admits Guilt and Agrees to Pay $8.9 Billion Fine to U.S." The New York Times. Archived from the original on 30 June 2014. Retrieved 1 July 2014.
  7. ^ "AUSTRAC at a glance". AUSTRAC. Archived from the original on 28 August 2016. Retrieved 18 August 2016.
  8. ^ Kerr, David S.; Loveland, Karen A.; Smith, Katherine Taken; Smith, Lawrence Murphy (March 2023). "Cryptocurrency Risks, Fraud Cases, and Financial Performance". Risks. 11 (3): 51. doi:10.3390/risks11030051. ISSN 2227-9091.
  9. ^ Rotella, Sebastian; Berg, Kirsten (11 October 2022). "How a Chinese American Gangster Transformed Money Laundering for Drug Cartels". ProPublica. Archived from the original on 14 July 2023. Retrieved 13 July 2023.
  10. ^ Parodi, Emilio (6 April 2023). "Italian drugs cartels conceal payments via Chinese shadow banks". Reuters. Archived from the original on 14 July 2023. Retrieved 14 July 2023.
  11. ^ "Italy police arrest 40 mafia suspects for drug smuggling via Chinese money brokers". Reuters. 30 May 2023. Archived from the original on 14 July 2023. Retrieved 14 July 2023.
  12. ^ "How Chinese networks clean dirty money on a vast scale". The Economist. 22 April 2024. ISSN 0013-0613. Archived from the original on 23 April 2024. Retrieved 23 April 2024.
  13. ^ a b c Reuter, Peter (2004). Chasing Dirty Money. Peterson. ISBN 978-0-88132-370-2.
  14. ^ "History of Anti-Money Laundering Laws". United States Department of the Treasury. 30 June 2015. Archived from the original on 8 December 2016. Retrieved 30 June 2015.
  15. ^ Lawrence M. Salinger, Encyclopedia of white-collar & corporate crime: A – I, Volume 1, page 78, ISBN 0-7619-3004-3, 2005.
  16. ^ National Drug Intelligence Center (August 2011). "National Drug Threat Assessment" (PDF). p. 40. Archived (PDF) from the original on 6 October 2011. Retrieved 20 September 2011.
  17. ^ a b "National Money Laundering Threat Assessment" (PDF). December 2005. p. 33. Archived from the original (PDF) on 17 October 2010. Retrieved 3 March 2011.
  18. ^ "Organized Crime Module 1 Key Issues: Similarities & Differences". www.unodc.org. Archived from the original on 4 January 2023. Retrieved 18 December 2022.
  19. ^ Naheem, Mohammed Ahmad (5 October 2015). "Trade based money laundering: towards a working definition for the banking sector". Journal of Money Laundering Control. 18 (4): 513–524. doi:10.1108/JMLC-01-2015-0002. ISSN 1368-5201.
  20. ^ Baker, Raymond (2005). Capitalism's Achilles Heel. Wiley. ISBN 9780471644880.
  21. ^ Has the Art Market Become an Unwitting Partner in Crime? (19 February 2017). "Has the Art Market Become an Unwitting Partner in Crime?". The New York Times. Archived from the original on 6 May 2018. Retrieved 5 May 2018.
  22. ^ "UK warns of criminal sanctions evasion through artwork storage facilities". National Crime Agency. Retrieved 14 July 2024.
  23. ^ Financial Action Task Force. "Global Money Laundering and Terrorist Financing Threat Assessment" (PDF). Archived from the original (PDF) on 26 July 2011. Retrieved 3 March 2011.
  24. ^ Burton, Tom. "Fraudulent invoices the new trend in business scams". Financial Review. Archived from the original on 28 October 2021. Retrieved 28 October 2021.
  25. ^ "Underground Economy Issues. Ontario Construction Secretariat". Archived from the original on 16 December 2010.
  26. ^ "Tax amnesties turn HMRC into 'biggest money-laundering operation in history'". Archived from the original on 28 November 2011. Retrieved 14 June 2013.
  27. ^ "Merchant-based money laundering Part 3: The medium is the method - ACFCS | Association of Certified Financial Crime Specialists | A BARBRI, Inc. Company". www.acfcs.org. Archived from the original on 1 April 2019. Retrieved 8 January 2019.
  28. ^ "The Growing Threat of Transaction Laundering | Legal Solutions". store.legal.thomsonreuters.com. Archived from the original on 8 January 2019. Retrieved 8 January 2019.
  29. ^ "Transaction laundering in 2019 – time to review the monitoring strategy | The Paypers". www.thepaypers.com. Archived from the original on 14 July 2020. Retrieved 9 January 2019.
  30. ^ "Transaction Laundering: Growing Fraud Risk for Merchants". ThreatMetrix. 26 April 2018. Archived from the original on 8 January 2019. Retrieved 8 January 2019.
  31. ^ "Exclusive: Fake online stores reveal gamblers' shadow banking system". Reuters. 22 June 2017. Archived from the original on 9 January 2019. Retrieved 8 January 2019.
  32. ^ "G2 Transaction Laundering Detection". G2 Web Services. Archived from the original on 8 January 2019. Retrieved 8 January 2019.
  33. ^ raytodd2017 (17 September 2018). "Transaction laundering and high-risk payment processors". raytodd.blog. Archived from the original on 9 January 2019. Retrieved 8 January 2019.
  34. ^ a b Solon, Olivia (21 October 2013). "Cybercriminals launder money using in-game currencies". Wired. Archived from the original on 24 October 2013. Retrieved 22 October 2013.
  35. ^ Sieff, Kevin (18 July 2024). "As a trafficker pursued dreams of soccer glory, investigators closed in". Washington Post. 'They buy a Colombian player from a very low-level soccer team and then take him to play in the Croatian Soccer League. But they sell him for 100 times or 200 times more than what he cost,' said a Colombian police official
  36. ^ Larkin, Charles; Pearce, Nick; Shannon, Nadine (2022). "Criminality and cryptocurrencies: Enforcement and policy responses – Part II". In Corbet, Shaen (ed.). Understanding Cryptocurrency Fraud. The challenges and headwinds to regulate digital currencies. Boston/Berlin: De Gruyter. pp. 141 f. ISBN 978-3-11-071688-7.
  37. ^ Cf. Kethineni, Sesha; Cao, Ying (2020). "The Rise in Popularity of Cryptocurrency and Associated Criminal Activity". International Criminal Justice Review. 30 (3): 334. doi:10.1177/1057567719827051. S2CID 150755683.
  38. ^ Hou, Greg (2022). "Cryptocurrency money laundering and exit scams: Cases, regulatory responses and issue". In Corbet, Shaen (ed.). Understanding Cryptocurrency Fraud. The challenges and headwinds to regulate digital currencies. Boston/Berlin: De Gruyter. p. 88. ISBN 978-3-11-071688-7.
  39. ^ Owen, Allison; Chase, Isabella (2 December 2021). NFTs: A New Frontier for Money Laundering? (Report). Royal United Services Institute. Archived from the original on 16 January 2022. Retrieved 12 January 2023.
  40. ^ Study of the Facilitation of Money Laundering and Terror Finance Through the Trade in Works of Art (PDF) (Report). United States Department of the Treasury. 2022. p. 27. Archived (PDF) from the original on 13 April 2022. Retrieved 12 January 2023.
  41. ^ Quiroz-Gutierrez, Marco (4 February 2022). "A handful of NFT users are making big money off of a stealth scam. Here's how 'wash trading' works". Fortune. Archived from the original on 15 December 2022. Retrieved 12 January 2023.
  42. ^ "Crime and NFTs: Chainalysis Detects Significant Wash Trading and Some NFT Money Laundering In this Emerging Asset Class". Chainalysis. 2 February 2022. Archived from the original on 6 December 2022. Retrieved 12 January 2023.
  43. ^ Cf. Study of the Facilitation of Money Laundering and Terror Finance Through the Trade in Works of Art (PDF) (Report). United States Department of the Treasury. 2022. p. 26. Archived (PDF) from the original on 13 April 2022. Retrieved 12 January 2023.
  44. ^ Team, Chainalysis (14 July 2022). "Mixer Usage Reaches All-time Highs in 2022". Chainalysis. Archived from the original on 23 April 2023. Retrieved 23 April 2023.
  45. ^ Team, Chainalysis (23 August 2022). "Crypto Mixers and AML Compliance". Chainalysis. Archived from the original on 23 April 2023. Retrieved 23 April 2023.
  46. ^ Yaffe-Bellany, David (8 September 2022). "Investors Sue Treasury Department for Blacklisting Crypto Platform". The New York Times. ISSN 0362-4331. Archived from the original on 23 April 2023. Retrieved 23 April 2023.
  47. ^ Yaffe-Bellany, David (8 September 2022). "Investors Sue Treasury Department for Blacklisting Crypto Platform". The New York Times. Archived from the original on 23 April 2023. Retrieved 22 April 2023.
  48. ^ Network, Financial Crimes Enforcement (9 May 2019). "Application of FinCEN's Regulations to Certain Business Models Involving Convertible Virtual Currencies". fincen.gov. Archived from the original on 23 April 2023. Retrieved 22 April 2023.
  49. ^ Richet, Jean-Loup (June 2013). "Laundering Money Online: a review of cybercriminals methods". arXiv:1310.2368 [cs.CY].
  50. ^ Zetter, Kim (May 2013). "Liberty Reserve founder indicted on $6 billion money-laundering charges". Wired. Archived from the original on 26 October 2013. Retrieved 20 October 2013.
  51. ^ "Bitcoin one step closer to being regulated in Australia under new anti-money laundering laws". ABC News. 22 October 2017. Archived from the original on 17 December 2017. Retrieved 18 December 2017.
  52. ^ "Hackers have cashed out on $143,000 of bitcoin from the massive WannaCry ransomware attack". CNBC. 3 August 2017. Archived from the original on 27 January 2018. Retrieved 18 December 2017.
  53. ^ "Bitcoin Island: cleaning up the crypto currency". BBC News. 23 April 2015. Archived from the original on 9 April 2021. Retrieved 17 February 2021.
  54. ^ Bharathan, Vipin. "Central Bankers And Crypto-Twitter Perennially In Opposition; Analysis Of Scale Of Crypto-Crime And The Prospect For Regulation". Forbes. Archived from the original on 25 February 2021. Retrieved 17 February 2021.
  55. ^ International Federation of Accountants. "Anti-Money Laundering" (PDF). Archived from the original (PDF) on 28 March 2014. Retrieved 27 March 2014.
  56. ^ Cassella, S.D. (2003). "Reverse money laundering". Journal of Money Laundering Control. 7 (1): 92–94. doi:10.1108/13685200410809814.
  57. ^ Zabyelina, Yuliya (2015). "Reverse money laundering in Russia: Clean cash for dirty ends". Journal of Money Laundering Control. 18 (2): 202–221. doi:10.1108/JMLC-10-2014-0039.
  58. ^ EAG. "Money laundering and terrorist financing with use of physical cash and bearer instruments Archived 13 October 2017 at the Wayback Machine", 17th Plenary Meeting of the Eurasian Group on Combating Money Laundering and Financing of Terrorism, 28 December 2012, New Delhi.
  59. ^ "Money Laundering: the Importance of International Countermeasures--Address by Michel Camdessus". IMF. Archived from the original on 23 May 2018. Retrieved 2 March 2018.
  60. ^ Financial Action Task Force. "Money Laundering - Financial Action Task Force". Archived from the original on 23 May 2018. Retrieved 26 October 2018.
  61. ^ For example, under UK law the first offences created for money laundering both related to the proceeds from the sale of illegal narcotics under the Criminal Justice Act 1988 and then later under the Drug Trafficking Act 1994.
  62. ^ "Transaction laundering should be a top priority for regulators in 2018". Financial Times. 27 September 2017. Archived from the original on 10 January 2019. Retrieved 10 January 2019.
  63. ^ "Online Payments-the Blind Spot in the AML Regime". Finextra Research. 17 July 2017. Archived from the original on 10 January 2019. Retrieved 10 January 2019.
  64. ^ Demetriades, Panicos; Vassileva, Radosveta (17 August 2020). "Money Laundering and Central Bank Governance in The European Union". Journal of International Economic Law. 23 (2): 509–533. doi:10.1093/jiel/jgaa011. ISSN 1369-3034.
  65. ^ Walker, Christopher; Aten, Melissa (2018). "The Rise of Kleptocracy: A Challenge For Democracy". Journal of Democracy. 29 (1): 20–24. doi:10.1353/jod.2018.0001. ISSN 1086-3214.
  66. ^ "The Dictator-Run Bank That Tells the Story of America's Foreign Corruption". Foreign Policy. Retrieved 29 October 2024.
  67. ^ O'Brien, Timothy L. (9 November 2005). "Bank of New York Settles Money Laundering Case". The New York Times. Archived from the original on 18 June 2024. Retrieved 3 March 2011.
  68. ^ "FBI — Bank Guilty of Violating U.S. Economic Sanctions". Fbi.gov. Archived from the original on 15 July 2014. Retrieved 14 July 2014.
  69. ^ "MAS directs BSI Bank to shut down in Singapore". www.mas.gov.sg. Archived from the original on 29 July 2016. Retrieved 23 January 2019.
  70. ^ "[2014] EWHC 2788 (Comm)". BAILII. Archived from the original on 9 July 2018. Retrieved 31 July 2018.
  71. ^ Bagnoli, Lorenzo; Bodrero, Lorenzo (16 April 2015). "Charter House Bank: A Money Laundering Machine". CORRECTIV. Archived from the original on 17 July 2018. Retrieved 2 October 2017.
  72. ^ "Danske Bank reveals Estonian branch may have laundered $230 billion as CEO steps down - ACFCS | Association of Certified Financial Crime Specialists | A BARBRI, Inc. Company". www.acfcs.org. Archived from the original on 23 January 2019. Retrieved 23 January 2019.
  73. ^ PYMNTS (23 October 2018). "Danske Handled $1T Plus In X-Border Payments". PYMNTS.com. Archived from the original on 23 January 2019. Retrieved 23 January 2019.
  74. ^ "Danske Bank, Estonia – a technical review of the latest leak of data". GrahamBarrow.com. 15 October 2018. Archived from the original on 13 February 2019. Retrieved 12 February 2019.
  75. ^ "Investigations into Danske Bank's Estonian branch | Danske Bank". danskebank.com. Archived from the original on 11 July 2018. Retrieved 8 February 2019.
  76. ^ Rubenfeld, Samuel; Chopping, Dominic (19 February 2019). "Danske Bank to Shut Estonia Branch". The Wall Street Journal. ISSN 0099-9660. Archived from the original on 20 February 2019. Retrieved 20 February 2019.
  77. ^ "Danske Bank pulls out of Russia, Baltics after money-laundering backlash". Reuters. 19 February 2019. Archived from the original on 20 February 2019. Retrieved 20 February 2019.
  78. ^ "Finantsinspektsioon | Avaleht". www.fi.ee (in Estonian). Archived from the original on 20 February 2019. Retrieved 20 February 2019.
  79. ^ "Estonia shuts Danske Bank branch at heart of money laundering saga". CNBC. Reuters. 19 February 2019. Archived from the original on 20 February 2019. Retrieved 20 February 2019.
  80. ^ "Swedbank May Have Handled More Than $4.3 Billion in Dirty Money". Bloomberg.com. 20 February 2019. Archived from the original on 20 February 2019. Retrieved 20 February 2019.
  81. ^ "Estonia investigates alleged Swedbank link to money laundering scandal". Reuters. 20 February 2019. Archived from the original on 20 February 2019. Retrieved 20 February 2019.
  82. ^ Deutsche Bank faces action over $20bn Russian money-laundering scheme Archived 18 June 2024 at the Wayback Machine. The Guardian. Retrieved 2 August 2019
  83. ^ Malnick, Edward; Heighton, Luke (21 June 2017). "UAE warned US it could end intelligence cooperation over 9/11 victims claims". The Telegraph. The Daily Telegraph. Archived from the original on 11 January 2022. Retrieved 21 June 2017.
  84. ^ "The Guantanamo Docket". The New York Times. 18 May 2021. Archived from the original on 30 July 2019. Retrieved 25 July 2019.
  85. ^ "Inside scandal-rocked Danske Estonia and the shell-company 'factories' that served it". International Consortium of Investigative Journalists. 21 September 2020. Archived from the original on 22 September 2020. Retrieved 21 September 2020.
  86. ^ "FinCEN Files: UAE central bank failed to prevent Iran sanctions evasion". BBC News. 20 September 2020. Archived from the original on 24 March 2021. Retrieved 21 September 2020.
  87. ^ Evdokimova, Tamara (24 January 2019). "Criminals Are Using Fortnite to Launder Money". Slate. Archived from the original on 4 August 2023. Retrieved 4 August 2023.
  88. ^ Cuthbertson, Anthony (13 January 2019). "How children playing Fortnite are helping to fuel organised crime". The Independent. Archived from the original on 14 January 2019. Retrieved 21 January 2019.
  89. ^ "Red Envelopes, Fortnite, Micro Money Laundering". PYMNTS.com. 8 February 2019. Archived from the original on 1 April 2019. Retrieved 8 February 2019.
  90. ^ Shanley, Patrick (16 January 2019). "Epic Games Responds to 'Fortnite' Money Laundering Accusations". The Hollywood Reporter. Archived from the original on 17 January 2019. Retrieved 21 January 2019.
  91. ^ "HSBC to Pay Record Fine to Settle Money-Laundering Charges". The New York Times. 11 December 2012. Archived from the original on 15 January 2013. Retrieved 24 January 2013.
  92. ^ Josephine McKenna (7 December 2009). "Vatican Bank reported to be facing money-laundering investigation". The Times. Archived from the original on 10 February 2021. Retrieved 12 June 2010.
  93. ^ "U.S. accuses currency exchange of laundering $6 billion". Reuters. 29 May 2013. Archived from the original on 23 January 2019. Retrieved 23 January 2019.
  94. ^ Zetter, Kim (28 May 2013). "Liberty Reserve Founder Indicted on $6 Billion Money-Laundering Charges". Wired. ISSN 1059-1028. Archived from the original on 23 May 2018. Retrieved 23 January 2019.
  95. ^ "Secret Service busts $6 billion money laundering scheme". Fox News. 25 March 2015. Archived from the original on 23 January 2019. Retrieved 23 January 2019.
  96. ^ Hitt, Jack (10 December 2000). "The Billion Dollar Shack". The New York Times. Archived from the original on 18 November 2011. Retrieved 3 March 2011.
  97. ^ "Sani Abacha". Asset Recovery Knowledge Center. Archived from the original on 2 May 2013. Retrieved 3 March 2011.
  98. ^ "Standard Bank PLC fined £7.6m for failures in its anti-money laundering controls". FCA. 23 January 2014. Archived from the original on 23 January 2019. Retrieved 23 January 2019.
  99. ^ "Standard Chartered to Pay $330 Million to Settle Iran Money Transfer Claims". The New York Times. 6 December 2012. Archived from the original on 15 January 2013. Retrieved 24 January 2013.
  100. ^ "AUSTRAC and Westpac agree to proposed $1.3bn penalty". AUSTRAC. 24 September 2020. Archived from the original on 27 January 2021. Retrieved 31 December 2020.
  101. ^ McGee, Jim (18 June 1995). "FROM RESPECTED ATTORNEY TO SUSPECTED RACKETEER: A LAWYER'S JOURNEY". The Washington Post. Archived from the original on 15 September 2017. Retrieved 11 September 2017.
  102. ^ RASHBAUM, William K. (12 April 1996). "HE ADMITS LAUNDERING DRUG CASH". New York Daily News. Archived from the original on 3 April 2019.
  103. ^ Kochan, Nick (2011). The Washing Machine. Gerald Duckworth & Company. ISBN 9780715642030.[permanent dead link]
  104. ^ Chan, Sewell (11 May 2018). "Macau Tycoon Gets 4 Years in Prison for Bribing U.N. Diplomats". The New York Times. Archived from the original on 11 May 2020. Retrieved 5 May 2020.
  105. ^ Dunlap, David W. (13 January 1991). "Commercial Property: The Bernstein Brothers; A Tangled Tale of Americas Towers and the Crown". The New York Times. Archived from the original on 14 November 2013. Retrieved 12 June 2010.
  106. ^ a b "United Nations Office on Drugs and Crime, Corruption & Economic Crime, Category "Money laundering"". Retrieved 17 August 2024.
[edit]