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Objectives

• Define money laundering


• How AML supports anti-corruption

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“After foreign exchange and the
oil industry, the laundering of
dirty money is the world’s third-
largest business.”
Jeffrey Robinson, The Laundrymen

How Much Is Laundered?


IMF ESTIMATE = 2-5% Global GDP

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What is Money Laundering?
• Definition: The process of disguising the
proceeds of crime in an effort to conceal their illicit
origins and legitimize their future use.
• Objective: To conceal true ownership and origin of
the proceeds, a desire to maintain control, a need
to change the form of the proceeds.
• Techniques: They can be simple, diverse,
complex, subtle, but secret.
Proceeds = any economic advantage
derived directly or indirectly from criminal
offenses

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Money Laundering Cycle 1.
Predicate Crimes
• Corruption and Bribery
• Fraud
• Organized crime
• Drug and human trafficking
• Environmental crime
• Terrorism
• Other serious crimes…

4. 2.
INTEGRATION PLACEMENT
• The last stage in the laundering
• Initial introduction of criminal
process.
proceeds into the stream of
• Occurs when the laundered
commerce
proceeds are distributed back to
• Most vulnerable stage of money
the criminal.
laundering process
• Creates appearance of
legitimate wealth.

3.
LAYERING
• Involves distancing the money
from its criminal source:
• movements of $ into
different accounts
• movements of money to
different countries
• Increasingly difficult to detect

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Money is laundered through…

Banks
Financial services
Brokerage firms

Other Examples: Insurance companies,


Money remitters,
Cash intensive businesses,
Brokerage firms,
Realtors
Crooked LAWYERS and ACCOUNTANTS
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Simple Bribe and Money Laundering Transaction
Country 3
Country 1

Company owned by Minister’s cousin


Company A
• Needs to generate
$1 million for bribe to
Finance Minister.
• Uses invoices from
company in Country
2

Company Bank Account $500,000 - Purchase $500,000 - Purchase


of Real Estate of Bearer Share

Country 4
Country 2
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What Are The Benefits Of Money
Laundering Laws?

• Money Laundering is a separate offense which carries


additional jail time. Allows for seizure and confiscation of
proceeds of crime.
• Allows law enforcement access to bank and other financial
institution records.
• Requires financial institutions to file suspicious and sometimes
cash transaction reports, and to identify the beneficial owners of
legal entities.
• Requires establishment of Financial Intelligence Units which
receive reports from financial institutions and can provide new
channels for international exchange of information.

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The Case of Switzerland
• Originally known for its extreme bank secrecy

• Evolution of reputational risk assessment of


Swiss financial sector. Began to freeze
assets.

• Recent Cases with Swiss Banks:


– Marcos: returned $700 million
– Abache: returned $200 million
– Montesinos: returned $77.5 million

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