Showing papers in "Journal of Money Laundering Control in 2019"

The use of cryptocurrencies in the money laundering process

Abstract: This paper aims to analyze the money laundering process itself, how cryptocurrencies have been integrated into this process, and how regulatory and government bodies are responding to this new form of currency.,This paper is a theoretical paper that discusses cryptocurrencies and their role in the money laundering process.,Cryptocurrencies eliminate the need for intermediary financial institutions and allow direct peer-to-peer financial transactions. Because of the anonymity introduced through blockchain, cryptocurrencies have been favored by the darknet and other criminal networks.,Cryptocurrencies are a nascent form of money that first arose with the creation of bitcoin in 2009. This form of purely digital currency was meant as a direct competitor to government-backed fiat currency that are controlled by the central banking system. The paper adds to the recent discussions and debate on cryptocurrencies by suggesting additional regulation to prevent their use in money laundering and corruption schemes.

Determining the nexus between financial inclusion and economic development in Pakistan

Abstract: This paper aims to evaluate the relationship between financial inclusion and economic development in Pakistan based on available sources of detailed data and assess its outcome of financial inclusion on basic standards of life, then accord relevant recommendations to prompt economic growth and development.,The research design selected for data analysis was meta-analysis, besides, data analysis over the period 2010-2015 was performed by using a descriptive statistical approach, regression and correlation analysis, i.e. the Pearson correlation matrix.,The authors find a positive relationship between financial inclusion and economic development, resultantly; increase in financial inclusion may lead to an increase in economic development. In detail, the number of the number of bank accounts (per 1,000 adult population) and the number of bank branches (per 100,000 people) have a positive relationship with human development index (HDI). Where else the amount of automated teller machines per 1,000 km2 (per cent) reveals a negative relationship.,The study has shown that expand financial access such as strengthen the establishment of bank accounts and bank branches can increase economic development in Pakistan. That is the government should focus on the financial inclusion policies as a means of ameliorating poverty, through a participation of all economic agents in the financial system. There is an utmost need for the Government of Pakistan to prioritize the importance of financial inclusion.,The novelty of the study is taken HDI and three representative indicators as a measurement of economic growth and financial inclusion, respectively, meanwhile, meta-analysis, multivariate regression model sum up that poverty alleviation is connected with the development of a more inclusive financial services sectors.

Control of fraud on mobile money services in Ghana: an exploratory study

Abstract: Fraud is a global economic menace which threatens the survival of individuals, firms, industries and economies, and the mobile money service is no exception. This paper aims to explore the main causes of fraud in the mobile money services in Ghana and the measures to combat the menace by the key stakeholders connected to the mobile money services. The paper is motivated by recent reports of numerous fraudulent transactions on the mobile money platform, and the need to clamp down these nefarious transactions with effective and practical measures to sustain the service.,A thorough review of existing studies on fraud risk relating to mobile money services was done revealing a paucity of literature on the subject. Primary data were gathered using an interview guide to explore the magnitude of the problem based on the views of employees of mobile money operators, mobile money agents, banking supervisors from Bank of Ghana, employees of partnering banks, employees of National Communications Authority and mobile money subscribers.,The study revealed that fraud in mobile money services is caused by weak internal controls and systems, lack of sophisticated information technology tools to detect the menace, inadequate education and training and the poor remuneration of employees. These factors disrupt the growth, and the smooth-running of the services. To curb this menace, a detailed legal code and internal fraud policy should be developed and used by mobile money operators and partner banks. Adequate training for mobile money agents should be encouraged coupled with public awareness campaigns to educate stakeholders especially the mobile money subscribers on the tricks of the fraudsters.,With the chosen research methodology and limited sample size, the findings may not reflect the views of all the stakeholders connected to the mobile money services. Therefore, future studies on this subject are entreated to use research methods which embrace larger samples to get more details about this menace.,The study will assist in tackling the mobile money fraud to sustain the service in the foreseeable future.,This paper contributes to scanty literature on fraud relating to the mobile money services by drawing lessons from a middle-income country.

Exploring the role of risk and corruption on bank stability: evidence from Pakistan

Abstract: This paper aims to explore the impact of liquidity risk, credit risk, funding risk and corruption on bank stability of the banking system in Pakistan.,The empirical analysis is confined to 24 retail banks, which include 5 Islamic and 19 conventional banks during the period of 2007-2015.,The findings of this study suggest that bank size, liquidity risk, funding risk and corruption exert a positive impact on bank stability. Additionally, the authors find a negative relationship between credit risk and bank stability.,As per the knowledge of the authors, the present research is the first attempt that discusses the issues of bank stability related to risk and corruption faced by the banking system.

Evaluating cryptocurrency laundering as a complex socio-technical system: A systematic literature review

Abstract: The purpose of this paper is to present the findings from a literature review, which aimed to identify previous studies evaluating cryptolaundering from a systems thinking perspective. The aim of this paper is to first confirm that cryptolaundering systems can indeed be defined as complex socio-technical systems and second to present the findings from a systematic review of the literature to determine the extent to which previous research has adopted a systems thinking perspective.,The study involved a SLR of studies published in the peer-reviewed literature between 2009 and 2018. Rasmussen’s risk management framework (Rasmussen, 1997) was used to evaluate the extent to which a systems thinking perspective had been adopted.,The cryptolaundering process is considered to be a complex socio-technical system. The review demonstrates that no previous studies have defined cryptolaundering as a complex socio-technical system or used systems thinking framework approach to evaluate how criminals, regulatory bodies or law enforcement entities understand processes and assess risk within cryptolaundering systems. It is argued that using such an approach to the cryptolaundering process would likely improve assessing criminal risk analyses of cryptolaundering and assist law enforcement and regulatory bodies with understanding risk management during the laundering of cryptocurrencies.,Future assessments of cryptolaundering using socio-technical system analytical processes may afford law enforcement and regulatory bodies the opportunity to improve intervention techniques and identify gaps in regulations and enforcement.

Exploring the links between AML, digital currencies and blockchain technology

Abstract: This paper aims to explore the implications of the 2014 Financial Action Task Force (FATF) publication and guidelines on virtual currency definitions and the overall impact of blockchain technology on anti-money laundering (AML) compliance and regulation. The report cites three case study examples, which the FATF paper uses and which this paper questions as to their relevance, especially to the formal banking sector.,The paper has provided a critical analysis of a FATF publication and guideline document. Additional secondary data has been used on blockchain technology and to analyse the relevance and implications of the case studies used in the FATF document.,The main findings are that virtual currency technology has the potential to support AML frameworks within banking when and if they are better understood. However, generic case examples of virtual currency legal cases are not necessarily useful when developing AML risk assessment frameworks within the banking sector.,The implications from the research affect any financial organisation undertaking AML risk analysis or compliance especially for virtual currencies. It applies to the banking, insurance and auditing professions and is of interest to academics working on virtual and digital currencies.,The social implications are that virtual currency technology can be used to add protection to banking transactions and could also be considered for client identity information such as beneficial ownership.,The originality of this paper is the topic of blockchain technology being considered in AML frameworks and the critical analysis of the FATF cases.

Assessing the introduction of anti-money laundering regulations on bank stock valuation: An empirical analysis

Abstract: This paper aims to analyze the impact of the introduction of anti-money laundering (AML) regulations on bank stock valuations in the USA. Regulations can have a negative impact on financial returns as a result of increased operational costs, potentially driving down stock valuations and loss of profitability. However, regulations can also have a positive impact on valuations because of greater oversight and increased investor confidence. Findings are useful for assessing the market impact of future regulations.,Event studies and cross-sectional regression analysis are used to determine the impact on bank stock valuations together with specific characteristics of bank size and geographic headquarter location of the bank for identified AML regulations. Hypothesis related to the impact of the introduction of AML regulations are empirically tested based on the statistical significance of cumulative abnormal returns of markets.,AML regulations introduced in 1998 had a positive impact on bank stock valuations, while the USA PATRIOT Act legislation of 2001 had a negative impact. These findings suggest that recent AML regulation is a cost compliance burden for banks, where the costs of operations outweigh the benefits of improved processes. Larger banks see a more negative impact on their bank stock valuations compared to smaller banks, suggesting the market perceives greater cost and less profit for larger banks. Results also show that the location of bank’s headquarters does not significantly impact bank stock valuations.,This paper specifically focuses on the impact of AML regulations on the US banking sector, providing investors, academics and regulators additional insight on the market dynamics of regulations. Identifying whether the introduction of regulations has a significant impact on a bank’s performance will provide both banks and regulators clarity as to the net benefits associated with the current and future AML legislation.

Anti-money laundering and counter-terrorist financing threats posed by mobile money

Abstract: The purpose of this paper is to explore the various characteristics of mobile money transactions and the threats they present to anti-money laundering (AML) and counter terrorist financing regimes.,A thorough literature review was conducted on mobile money transactions and the associated money-laundering and terrorist financing threats. Four key themes were identified in relations to the three stages of money laundering and effective law enforcement.,The findings indicate that as money laundering and terrorist financing transactions continue to gravitate towards the weaknesses in the financial system, mobile money provides yet another avenue for criminals to exploit. Risk factors associated with anonymity, elusiveness, rapidity and lack of oversights were all integral considerations in building an effective AML regime. The use of cash is considered a higher threat than mobile money prior to implementation of systems and controls.,This rapidly changing environment of how individuals manage their money during transactions is set to further explode globally, which poses new problems for regulators and governments alike. Unless there is a unified concentration to heighten global awareness, the imposing threat of mobile money is set to increase at a rapid rate if appropriate actions are not taken.,The findings from this study can be used to gain greater insights on mobile money transactions and raise further awareness of the ever-increasing threat to global financial integrity.

Banks’ vulnerabilities to money laundering activities

Abstract: This paper aims to provide insights as to why money laundering persists in banks and their weaknesses as gatekeepers.,This paper contextualizes the design and proliferation of anti-money laundering (AML) measures; investigates the different manners of conceptualizing them; and provides insights pertaining to probable limitations of these measures. The paper relies on primary data from statutes and secondary data from published sources.,The paper’s findings suggest that competitive pressures, shareholders return imperative, and lucrative misaligned incentives for management contributed to weaknesses in effective compliance in banks.,Insights drawn from this paper reinforces the notion that banks need to seriously review their business approaches, as well as their roles as gatekeepers.,Given the slew of corporate scandals and other materially harmful misjudgments in money-laundering compliance, banks might need to seriously review their role and obligations in the economy.,Much has been said about money-laundering activities enabled by the banking sector. This paper contributed to insights as to why they persist despite AML rules, and what measures could be further taken to enhance compliance effectiveness.

An investigation of the fraud risk and fraud scheme methods in Greek commercial banks

Abstract: The purpose of this study is to examine types of fraud risk and fraud scheme methods in Greek commercial banks.,Data used for this study were obtained from primary source through questionnaires. This method of data collection was followed and was considered appropriate because the information sought is not publicly available and middle management and internal auditors are in a good position to know the answers to the questions asked. Questionnaires were sent to a sample of 230 persons, all bank branch employees (internal auditors were excluded), in the city of Athens (capital city of Greece), in five banks, National Bank of Greece, Piraeus Bank, Alpha Bank, Eurobank and Postal Bank, during February 2017-March 2017. Finally, of the 230 questionnaires distributed, 225 completed and returned but only 203 of them were usable questionnaires. Cronbach’s alpha was used to test the reliability of variables.,Results showed that forgeries, bribery and money laundering are the most important types of fraud risk, and the best fraud scheme methods are using dormant accounts and checks. Based on the empirical findings, the study recommends that there is a need for banks to implement a code of conduct and a code of ethics for staff, staff training, signature verification, control over dormant accounts, asking employees about their opinions and the way they feel about their bank, conducting surprise audits and using a hot line for whistleblowing.,The study will help banks in fraud risk management and in the development of policies to reduce risk within the banking sector. Also, will be useful to all categories of potential bank clients and users of financial services including shareholders, creditors, debtors and fund providers.,To the best of the authors’ knowledge, this is the first study examining middle management and staff opinions about fraud risk and fraud scheme methods in Greek commercial banks.

Does corruption cause tax evasion? Evidence from an emerging economy

Abstract: The purpose of this study is to examine the corruption-tax evasion nexus and to establish the strength of relationships among corrupting activities.,The research applied structural equation modelling on selected data from the World Economic Forum Executive Opinion Survey on corruption activities and data on tax evasion triggering factors from the World Development Indicators and the Bank of Ghana to test two hypotheses.,The test of the first hypothesis suggests that corrupting activities significantly cause tax-evading activities in Ghana; hence, there is at least one corrupting activity triggering tax evasion. Testing the second hypothesis revealed that corruption in Ghana exhibits all of the five dimensions of corruption that were examined. Hence, there is correlation among the corrupting activities.,The research is limited by the availability of data; hence, only data for selected variables for the period were examined.,The results are indicative that most emerging economies tend to have more than one type of dominating corruption dimension, which are tax-evading triggers.,The study extends the literature by examining the various dimensions of corruption, analysing the strength of their relationships and how they impact tax evasion in an emerging economy. By identifying and employing specific corrupting activities, there is a better understanding and appreciation of the corruption-tax evasion nexus in the revenue generation process. This may aid emerging economies in the drafting of tax evasion and corruption reduction policies/programmes to ensure the achievement of sustainable development goals.

Data mining for statistical analysis of money laundering transactions

Abstract: The purpose of this paper is to use statistical techniques to mine and analyze suspicious transactions. With the increase in money laundering activities across various sectors in some of the world’s leading democracies, the ability to detect such transactions is gaining grounds with more urgency. Regulators and practitioners have been calling for an approach that can mine the large volume of unstructured data form suspicious money laundering transactions to inform public policies.,By deducing from the results of empirical studies in the field of money laundering detection, this paper presented an overview of data mining technology for detecting suspicious transactions.,After chronicling the data mining process, the paper delves into an analysis of the statistical approaches that can be used to differentiate between legitimate and suspicious money laundering transactions. The different stages of the data mining process are carefully explained in relation to their application to anti-money laundering compliance. The results indicate that statistical data mining methodology is a very efficient and useful technique to detect suspicious transactions.,The paper is of relevance to regulators and the financial service sector. A discussion of how data can be mined to facilitate statistical analysis can be used to inform regulatory policies on the detection and prevention of money laundering activities in the financial service sector.,The paper discuss approaches that illustrate how analysts can use statistical techniques to analyze data for suspicious money laundering transactions

Tax compliance of financial services firms: a developing economy perspective

Abstract: The purpose of this study is to examine the contribution of tax morale, compliance costs and tax compliance of financial services firms in Uganda.,This study is cross-sectional and correlational and adopts firm-level data collected using a questionnaire survey of 210 financial services firms in Uganda from which usable questionnaires were received from 152 financial services firms.,Tax morale and compliance costs contribute up to 20.6 per cent of the variance in tax compliance of the financial services firms. Tax morale and tax compliance are positively and significantly associated. Results further indicate that compliance costs and tax compliance are positively and significantly associated. National pride and trust in government and its legal systems as dimensions of tax morale independently are significantly associated with tax compliance. Results also indicate that administration costs and specialist costs as dimensions of compliance costs individually are significantly associated with tax compliance.,This study results should be generalized with caution, as they are limited to the financial services firms in Uganda.,Whereas there has been a number of studies on tax compliance in both developed and developing countries, this is the first study on the African scene to examine the contribution of tax morale and compliance costs on tax compliance of financial services firms in a single suite. It is unbelievable that the financial services firms, especially commercial banks which are highly regulated by the central bank in many developing countries, can afford to report tax payables year after year.

A target-centric intelligence approach to WannaCry 2.0

Abstract: This paper aims to demonstrate the utility of a target-centric approach to intelligence collection and analysis in the prevention and investigation of ransomware attacks that involve cryptocurrencies. The paper uses the May 2017 WannaCry ransomware usage of the Bitcoin ecosystem as a case study. The approach proves particularly beneficial in facilitating information sharing and an integrated analysis across intelligence domains.,This study conducted data collection and analysis of the component Bitcoin elements of the WannaCry ransomware attack. A note of both technicalities of Bitcoin operations and current models for sharing cyber intelligence was made. Our analysis builds on and further develops current definitions and strategies for sharing cyber threat intelligence. It uses the problem definition model (PDM) and generic target network model (TNM) to create an analytic framework for the WannaCry ransomware attack scenario, allowing analysts the ability to test their hypotheses and integrate and share data for collaborative investigation.,Using a target-centric intelligence approach to WannaCry 2.0 shows that it is possible to model the intelligence problem of collecting and analysing data related to inflows and outflows of Bitcoin-related ransomware transactions. Bitcoin transactions form graph networks and allow to build a target network model for collecting, analysing and sharing intelligence with multiple stakeholders. Although attribution and anonymity prevail under cryptocurrency usage, there is a means for developing transaction walks using this method to target nefarious cryptocurrency exchanges where criminals are inclined to cash out their proceeds of crime.,The application of a target-centric intelligence approach to the cryptocurrency components of a ransomware attack provides a framework for intelligence units to break down the problem in the financial domain and model the network behaviour of illicit Bitcoin transactions relating to ransomware.

How seriously do taxpayers regard tax evasion? A survey of opinion in England

Abstract: Numerous studies have been done on various aspects of tax evasion in recent years. Some studies focus on compliance, while others examine more esoteric topics, such as optimum tax evasion. A third group of studies discusses theoretical issues, such as when tax evasion can be justified on moral grounds. A few studies have addressed the relative seriousness of tax evasion compared to other infractions. The purpose of this paper is in the latter category.,Wave 6 of the World Values Surveys (2010-2014) asked hundreds of questions to participants in 57 countries. One of those questions asked whether it was justifiable to evade taxes if one had the opportunity to do so. Another question asked whether it was justifiable to pay cash to avoid paying taxes. It also asked questions about other ethical issues such as bribery, avoiding a fare on public transport, claiming government benefits and buying stolen goods. The present study included those questions in a survey that was distributed to 485 students and faculty members at the University of Exeter in England to determine the relative seriousness of each act. They were asked to select a number from 1 (never justifiable) to 10 (always justifiable) to show the extent of their agreement or disagreement with the commission of the six acts. The goal was to determine how serious tax evasion was compared to other acts that might be considered unethical. One-sample t-test and one-way analysis of variance (ANOVA) methods were used for the data analysis.,The results of the study show that the act considered least serious was paying cash for services to avoid tax followed in order of seriousness by avoiding a fare on public transport, cheating on taxes if you have a chance, buying stolen goods, claiming benefits without entitlement and, with least justification, accepting a bribe in the course of one’s duty. Some interesting results emerged by examining the responses of different groups. Like other studies, the results indicate older groups tend to have a higher respect for the law than younger ones. This was true for the cheating on taxes possibility, but the 30-49 years age group were more opposed than the other two groups to paying cash for services to avoid taxes. In terms of gender, females were significantly more opposed than males to cheating on taxes if you have a chance. The respondents who are married were more opposed to the six acts, including of course, the two tax ones, than non-married persons. There was also evidence that the level of higher education makes a difference to individuals’ opinions.,This is an important study in relation to England. It is the first study to do so. The relative seriousness of tax evasion is compared to other offenses. Mean scores are used to rank the various offenses in terms of relative seriousness. Various demographics are also examined to see whether some groups view tax evasion as more serious than other groups. Those demographics included gender, age, academic major, education level and marital status.

The risk analysis of Bitcoin and major currencies: value at risk approach

Abstract: Purpose This study aims to compare investors of major conventional currencies and Bitcoin (BTC) investors by using the value at risk (VaR) method common risk measure. Design/methodology/approach The paper used a risk analysis named as VaR. The analysis has various computations that Historical Simulation and Monte Carlo Simulation methods were used for this paper. Findings Findings of the analysis are assessed in two different aspects of singular currency risk and portfolios built. First, BTC is found to be significantly risky with respect to the major currencies; and it is six times riskier than the singular most risky currency. Second, in terms of inclusion of BTC into a portfolio, which equally weights all currencies, it elevates overall portfolio risk by 98 per cent. Practical implications In spite of the remarkable risk level, it could be considered that investors are desirous of making an investment on BTC could mitigate their overall exposed risk relatively by building a portfolio. Originality/value The paper questions the risk level of Bitcoin, which is a digital currency. BTC, a matter of debate in the contemporary period, is seen as a digital currency free from control or supervision of a regulatory board. With the comparison of major currencies and BTC shows that how could be risky of a financial instrument without regulations. However, there is some advice for investors who would like to invest digital currencies despite the risk level in this study.

Anti-money laundering/trade-based money laundering risk assessment strategies – action or re-action focused?

Abstract: This paper aims to discuss whether most anti-money laundering (AML) risk assessment strategies within the banking and financial services sector are reactionary focused and/or whether it should be possible to predict where increased costs and resources need to be targeted in future AML risk processes.,The paper reviewed research findings from the researchers own study on trade-based money laundering (TBML) and also survey results from the KPMG Global Anti-Money Laundering Survey (2014), along with academic discussion papers.,The paper concluded that risk assessment strategies were still largely responsive, and this left banks exposed to two factors – not recognising risk that they were not assessing for and, second, being challenged legally as new cases emerged in the court systems from victims of ML and terrorism crimes.,The practical implications affect the resources and costs assigned to risk assessment strategies and called for a more holistic approach that was forward thinking from the bank’s perspective rather than reactionary focused and working from the regulators’s agenda.,Any improvements in detection of AML and counter-terrorism financing has broader social outcomes.,The originality is the subject matter of AML risk assessment strategies and the input from TBML/AML experts from across the globe that contributed to the author’s research survey and interviews. These results have been analysed along with other research and the current academic discussion on this topic.

The problem of regulating the easy way out – EU money laundering regulation

Abstract: Current research within law and economics focus on money laundering as an externality problem caused by financial institutions. Thus, when existing research and legislation place the responsibility on financial institutions, it creates a void where it is neglected that clients of financial institutions may, in fact, play a vital role in the problem of externality. However, based on the definition of money laundering, this paper aims to examine and analyze the need to focus on the clients as part of the externality problem with regard to money laundering.,This paper examines how a lack of regulatory focus on the clients of financial institutions lead to inefficient anti-money laundering regulation. Through a functional approach of law and economics, it analyzes the externality problem of money laundering based on both the legal definition and the economic conditions of the problem.,Based on the fourth anti-money laundering directive, the paper argues that present regulation has a tendency to focus on financial institutions, thereby not considering the entire scope of the externality problem in money laundering. For regulation to efficiently combat money laundering, it is necessary to place some responsibility on the clients of financial institutions and not solely on the financial institutions. Nevertheless, the inclusion of client responsibility might lead to some legal or economic complications, which need to be subject to further research.,The paper identifies the need for a fundamental change in the perception of the externality problem of money laundering, and thus, presents the required approach to reach an efficient solution.

An estimation of the underground economy and tax evasion: Empirical analysis from an emerging economy

Abstract: This paper aims to use an econometric model to estimate tax evasion from the size of the underground economy and examined the factors that trigger it.,The study used time series data sourced from world development indicators and Bank of Ghana covering the period 1990-2015 to estimate tax evasion from the underground economy using an autoregressive distributed lag model drawing on the currency demand approach.,The results confirmed the existence of a large underground economy and a high incidence of tax evasion in Ghana. The Ghanaian situation has been aggravated by an underground economy-triggering factor of mobile money activities, which increased by 83.1 per cent in 2015. Tax evasion averaged 20.78 per cent of GDP over the period. The study, thus, concludes that the increased number of mobile money activities, high tax burden and unemployment contribute to the worsening of the tax evasion problem in Ghana.,The study is one of the premier attempts to introduce electricity power consumption variables in the currency demand model to estimate tax evasion from the size of the underground economy. The authors hypothesize that the emergence of mobile money activities in its current form triggers underground and tax-evading activities. The study, thus, calls for the formalization and regulation of the operations of mobile money activities in emerging economies as a way of managing the underground economy, which incubates tax evasion.

Anti-money laundering and combating the financing of terrorism compliance. Are FATF member states just scratching the surface?

Abstract: The purpose of this paper is to investigate how well countries comply with global anti-money laundering and counter-financing of terrorism (AML/CFT) regulations.,With the help of an AML/CFT compliance index composed by the author, this study is able to numerically quantify countries’ AML/CFT compliance levels. Countries were selected based on their membership with the Financial Action Task Force (FATF), precisely members who have gone through at least one round mutual evaluation and have duly submitted a report to the task force. The AML/CFT index was composed by assigning numeric values to the individual country ratings across all 49 FATF recommendations contained in their mutual evaluation reports (MER).,Some notable findings include the yearly global level of AML/CFT compliance between the period 2004 and 2016, as well as compliance levels across continents for the same period. Compliance levels for the seven components of the FATF recommendations were also reported to help assess which set of recommendations countries comply with the most and why they do. It was also found that countries’ lack of compliance was as a result of high cost of compliance with FATF recommendations.,The main limitation of this study was a lack of high-frequency AML data of countries, especially less-developed countries.,The uniqueness of this paper lies in the fact that the AML/CFT compliance index constructed and used in the study is the first of its kind.

Money laundering and terrorism financing through consulting companies

Abstract: The purpose of this paper is to illustrate how criminals need to proceed to launder money and finance terrorism through the use of consulting firms.,A qualitative content analysis of 58 semi-standardized expert interviews with both illegal financial services providers and prevention experts led to the identification of concrete techniques for money laundering and terrorism financing through consulting companies.,Consulting firms could be considered to be “criminals’ best friends”. Terrorists could either buy or set up consulting firms in reputable countries, such as Switzerland or the UK. Subsequently, they could combine real consulting services along with fake clients to cover their illicit activities.,As the findings are based on semi-standardized interviews, they are limited to the 58 interviewees’ perspectives.,The identification of gaps in current prevention mechanisms is meant to provide legislators, compliance officers, law enforcement agencies and intelligence offices with insights into how criminals finance terrorism and launder money.,While the existing literature focuses on simply naming areas that could play a part in money laundering or the financing of terrorism, this paper describes a concrete method. It takes both prevention and criminal perspectives into account.

Implementation evaluation: a future direction in money laundering investigation

Abstract: Malaysia has implemented a comprehensive AML/CFT framework, yet its effectiveness remains questionable due to low number of prosecutions on money laundering cases. Therefore, this study aims to understand the reasons for low number of prosecutions, by addressing the challenges faced by the law enforcement agencies in conducting money laundering investigation. This study then identifies future improvement actions to enhance their effectiveness in combating money laundering in future.,This study distributed surveys to the law enforcement agencies that are responsible for conducting money laundering investigation in Malaysia. In total, 65 surveys were distributed; however, only 61 were returned to the researchers. Out of the 61 surveys returned, only 39 can be analysed due to incomplete answers given by respective respondents.,The results show that the investigating officers are facing difficulties in gathering sufficient information to support their charges. Besides information gathering, they are also facing difficulties due to short investigation timeframe regulated in the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act (AMLATFPUAA) 2001. This study concludes that, although the law enforcement agencies have the power to investigate money laundering and terrorism financing under the act, Malaysia is lacking in having a good investigative support system to assist the law enforcement agencies during the investigation process.,The results of this study are helpful to the regulators and law enforcement agencies in determining the flaws of the current money laundering investigation practices. This study also provides suggestions for future improvement action.,Lack of study focuses on money laundering investigation conducted by the law enforcement agencies, especially in the Malaysian setting, makes the study valuable to the money laundering research.

Saudi Arabia’s efforts on combating money laundering and terrorist financing: (Review undertaken in September 2017)

Abstract: This paper aims to study Saudi Arabia’s approach to combat money laundering and terrorist financing through legislation, regulation and implementation. Saudi Arabia is an integral part of the global economy and energy market. Saudi Arabia is also an important nexus for incoming foreign investment in the region. The country has, for many years, confronted negative exposure on challenging money laundering and terrorist financing. This paper analyses Saudi Arabia’s efforts to maintain international standards of AML/CTF and distinguishes regulatory practice from the existing comments and conjecture on the country’s performance.,The paper uses a qualitative study of Saudi Arabia’s approach to combat money laundering and terrorist financing. The approach is spread across three stages of AML/CTF policy – namely, legislative, regulatory and implementation. Further, the paper also uses independent evaluation to understand Saudi Arabia’s performance in comparison to the international standards of good AML/CTF practice.,The paper finds Saudi Arabia in compliance with international standards of AML/CTF practice. The paper also traces strengthening of AML/CTF-related legislation and regulation in Saudi Arabia over the past two decades. The paper also finds significant evidence that suggests a biased representation of Saudi Arabia’s AML/CTF practices. The factual analysis of Saudi Arabia and its AML/CTF practice is in contradiction of the established discourse on the country’s money laundering and terrorist financing risk profile.,The paper presents a legislative and regulatory analysis of Saudi Arabia’s AML/CTF practice. It is important to understand the implications of injudicious conjecture on Saudi Arabia’s financial strategy to diversify the country’s economy (Mouawad, 2005). Commentators and observers must consider the evidence presented in this paper and reassess the discourse regarding Saudi Arabia’s adherence to international standards of AML/CTF.,Understanding Saudi Arabia’s approach to combat money laundering and terrorist financing is essential to the factors that maintain stability in the Middle East. Saudi Arabia has participated in the region with government forces to maintain stability. The paper examines the overall risk as per international standards, which can be attributed to Saudi Arabia’s AML/CTF profile.

The role of the police in anti-money laundering

Abstract: This paper aims to describe and discuss the role of the police in anti-money laundering, with particular reference to the situation in the Republic of Macedonia.,A doctrinal approach is used to describe the role of the police in anti-money laundering policy, as well as to discuss whether the police is the central and main body in the fight against this crime. Deductive and inductive methods are used to analyze the collected data about Macedonian activities, provided by domestic and international organizations and institutions. Government agencies, institutions and bodies with different capacities for identifying and combating money laundering are included.,According to global statistics, about $2tn is laundered annually. Money laundering directly affects general economic and social life and the entire development, which shows why the concerns about this phenomenon have been growing worldwide. The most important issue in combating money laundering refers to preventing and detecting the problem. The police have the central role in combating money laundering in the Republic of Macedonia, but they must co-operate with public prosecutors and other agencies to fight this crime with more success. Even though Macedonian legislation is harmonized with European Union (EU) directives, there are a lot of activities in the field of money laundering to be done to fulfill EU standards. Relevant collected data were acquired from MONEYVAL reports, annual reports from the Ministry of Interior, Public Bureau of Statistics and statistics from the public prosecutor’s office, including all published documents.,The paper answers questions related to the role and effectiveness of the police by examining different authorizations and powers. Different approaches in implementing the law are specified and suggestions to overcome “two voices” are given. A comparative approach is also used to demonstrate the number of criminal charges per year, mainly collected by the public prosecutor’s office. The authors analyze whether additional training is needed for the police. All institutions should collaborate with the police because money laundering offences may be disclosed during investigations of other offences.

Sigma ratings: adapting the credit rating agency model for the anti-money laundering world

Abstract: Sigma Ratings is a new entrant to the anti-money laundering (AML) marketplace and seeks to alleviate some of the inherent flaws within the AML regime. This paper aims to examine those flaws and ask whether Sigma may succeed in this bourgeoning marketplace.,This paper is based upon a normative methodology, which takes place after reviewing the relevant literature to examine the potential success for Sigma Ratings.,The paper finds that there is indeed a position for Sigma Ratings in the marketplace, and that it may alleviate key issues within the AML regime.,The paper presents Sigma Ratings to the literature for the first time and positions this against an examination of the role of banks within AML – Sigma’s main demographic.

Following the cyber money trail: Global challenges when investigating ransomware attacks and how regulation can help

Abstract: The purpose of this paper is to show how global regulation of cryptocurrencies and other cybercurrencies can assist in addressing the challenges of attribution when investigating ransomware attacks and other types of cybercrime using these payment methods.,A literature review, looking at current academic research and discourse on the topic cryptocurrency regulation, is conducted to highlight current thinking and perceived difficulties in implanting a global regulatory framework. In addition, the research explores how governments have addressed the risks posed by cryptocurrencies and how regulation has been implemented. The research focuses on the regulatory approaches of Australia, Europe and the Americas to determine whether they could feasibly address the risks posed by cryptocurrencies and be implemented on a global scale.,To date, few sustained efforts have been made to regulate Bitcoin or other cybercurrencies. Where regulation has been introduced, it has often proven too costly to implement, thereby, stifling Bitcoin industry growth, or too ad hoc to function effectively. These regulatory pitfalls are substantiated by the continuing difficulty faced by law enforcement agencies, in identifying individual Bitcoin users and separating those that are using them for nefarious purposes from those that are using them for legitimate ones. These challenges appear to grow exponentially when it comes to prosecuting criminals for Bitcoin-related offences, due to the enormous lack of agreement within the justice system of most countries as to the appropriate legal definition for Bitcoin. This research highlights three characteristics that will be vital to the success of any global regulatory framework. These are consistency, clarity and cost-effective implementation. A regulatory framework for Bitcoin that lacks any one of these elements will fail to meet the requirements of every stakeholder in the regulatory process. A framework that is too costly to implement will stifle fintech innovation, subsequently depriving national economies of the multitude of potential benefits promised by fostering fintech entrepreneurship. Equally, a framework that is inconsistent will hamper the global cooperation necessary to combat Bitcoin-related crime.,This research evaluates research, discourse and regulatory responses from academic and governmental sources and discusses how a global response to cryptocurrency regulation will help address the growing problem of attribution when it comes to ransomware attacks, which has experienced a considerable spike in recent months.

Politically exposed entities: how to tailor PEP requirements to PEP owned legal entities

Abstract: This paper aims to address the money laundering risk posed by politically exposed person’s (PEP’s) controlled legal entities. International standards and national legislation require enhanced due diligence of political office holders but no specific requirements exist on entities controlled by PEPs. While regulators expect the stringent AML risk mitigation regarding this type of entities, financial institutions have no guidelines to follow. This gap produces inconsistent due diligence measures applied to entities with significant PEPs’ connection.,The paper uses comparative analysis to identify discrepancies between legal requirements and their interpretation. Moreover, an empirical approach results in a standardised solution to address these discrepancies.,The paper defines the concept of politically exposed entities and the applicable due diligence framework. Anticipating legislative measures, it proposes to introduce this concept via best practices of financial institutions and private banking initiatives such as the Wolfsberg Group.,The research addresses the topic from a legal point of view. However, the implementation of proposed ideas depends on decisions which are political by nature and are not within the scope of this paper.,The paper aims at stimulating a debate in both the private and public sector to form a consistent approach to AML due diligence of legal entities associated to PEPs.,This paper responds to an identified need to study how legal entities connected to PEPs should be defined and monitored.

The necessity of anti-money laundering standards for Iranian auditors

Abstract: According to the last public statement of FATF (2018), Iran has some significant deficiencies in its anti-money laundering (AML) regime, especially in suspicious transaction reporting. In this research, the author tries to empirically show that Iranian auditors do not a response to AML cases effectively and adopting an AML standard is required for Iranian auditors. Therefore, it helps to improve one of the deficiencies of Iran’s AML regime.,To collect data, the author designed and developed a questionnaire and the questionnaire sent to all partners of Iranian auditing firms, which have authorization from the Iranian Association of Certified Public Accountants on December 2018.,The finding shows most of the sample auditors’ claim that it is necessary to have an AML standard and it can be helpful for them. Furthermore, most of the Iranian auditors in money laundering cases, which companies are involved do nothing except filling the checklist of Anti-Money Laundering Implementing Regulations for Business and Non-business Companies (2012).,The results of the current research make clear the necessity of adopting an AML standard for Iranian auditors and recommend Iranian authorities to improve Iran’s AML regime.

“Underground banking” and Myanmar’s changing hundi system

Abstract: The purpose of this paper is to examine Myanmar’s “hundi” system, an informal value transfer system used widely by local Myanmar citizens and offshore migrant workers to remit money domestically and internationally. Due to historically stringent banking and foreign exchange controls and a lack of domestic and internationally linked financial services, the system grew to become the dominant medium for remittances in Myanmar. It also remains unregulated despite authorities acknowledging its use in criminal and terrorist activity. However, with an expanding and modernising financial sector, there is now increasing competition and challenges facing Myanmar’s hundi system.,This paper draws on available literature and open source reporting, as well as interviews with former Myanmar Police Force officials.,This study provides a unique insight into Myanmar’s hundi system, its history and the challenges it faces. The once dominant system remains a known anti-money laundering and countering the financing of terrorism (AML/CFT) risk and is having to compete with an expanding and modernising formal banking sector and the introduction of fintech and mobile money services. In the short term, these are unlikely to eliminate the hundi system completely, but may instead push hundi operators towards adopting these networks and technologies in their own operations.,Myanmar remains a very under-researched area and there has been a limited focus on its informal hundi remittance system and related AML/CFT issues. This paper will be a useful source for academics, development professionals, policymakers, law enforcement agencies and private sector actors seeking to understand Myanmar’s informal remittance system.

Anti-money laundering ratings: uncovering evidence hidden in plain sight

Abstract: This paper aims to increase the transparency of information in official anti-money laundering rating data to assist evidence-informed decision-making in compliance, policy-making and research.,This paper converts anti-money laundering rating data into information-rich visualisations, reintroduces a comparison methodology and ranks all anti-money laundering regimes evaluated to date.,Official anti-money laundering ratings as currently structured and presented offer surprisingly little policy-relevant information. Persistent failure to transform available data into information for knowledge and insight suggests that the risk has been realised that impressionistic judgments or politicised interests drive the policy agenda at least as much as objective evidence or substantive economic and social goals.,Any reluctance to generate policy-relevant information from the industry’s primary data set or disinclination to engage constructively with a growing body of independent critical policy effectiveness evidence calls into question whether implementing anti-money laundering controls with some prospect of achieving substantial societal benefits, or perpetuating the current system, prevails.,With a dearth of scholarship at the intersection of money laundering and policy effectiveness scholarship and practice, this paper combines elements of these disciplines and examines anti-money laundering effectiveness from a different viewpoint. Rather than seeking to measure money laundering or estimate the proportion of criminal proceeds successfully intercepted, this paper draws directly from the anti-money laundering industry’s own “main” data set.