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Posts tagged financial crime
Intensifying the fight against corruption and money laundering in Africa

By Lyla Latif

Illicit financial flows (IFFs) cost Africa around US$88.6 billion per year. They have hamstrung progress and created poverty, insecurity and financial challenges which today impede implementing the 2030 UN Agenda for Sustainable Development and the AU Agenda 2063: The Africa We Want. IFFs have also driven the African continent towards indebtedness, in addition to eroding funds that could be used for services such as education, health care and infrastructure.

This study focuses on one form of IFF, namely corruption and the resultant money laundering. It describes and analyzes the symbiotic relationship between corruption and money laundering and how they mutually reinforce an IFF ecosystem inclined towards draining resources needed for development. It further proposes measures to enhance the effectiveness of the fight against corruption and money laundering.

This study is produced by the Office of the Special Adviser on Africa (OSAA) within its mandate to support analytical work in improving coherence and coordination of the UN System support to Africa and to facilitate intergovernmental deliberations on Africa\

United Nations, 2022. 46p.

Banking Fraud

By Abbas Panjwani, Greg Oxley, William Downs

Criminals successfully stole £1.2 billion from individuals through banking fraud and scams in 2023 according to industry figures. 1 Fraud accounted for over 40% of crimes against individuals in England and Wales in 2024. And the government has said the total impact of fraud when counting things like emotional harm and investigatory costs is over double that of the direct losses from fraud. Despite the prevalence of fraud and the public costs, the government and police approach to fraud in recent years has been criticised for failing to take the crime seriously. For example, in the year ending March 2024, only around 2% of fraud offences recorded by police were referred to territorial forces for investigation. In 2023 the government published its fraud strategy which included a range of measures to stop fraud happening in the first place, pursue fraudsters when they are successful, and help victims. Some of the main initiatives include establishing a National Fraud Squad of specialist investigators, overhauling the fraud reporting system and requiring payment service providers to reimburse victims of authorised payment fraud. The nature and scale of banking fraud Industry body UK Finance estimates that criminals successfully stole £1.17 billion through banking fraud and scams in 2023. Of this £709 million was unauthorised and £460 million was authorised, levels which have remained broadly flat since 2021. Unauthorised fraud is where the fraudulent transaction is carried out by a third party, not the victim. Authorised fraud involves the victim being tricked into paying money into another account that is controlled by a criminal. This is also known as Authorised Push Payment (APP) fraud. Payment providers almost always reimburse victims of unauthorised fraud. For APP fraud, in 2023 62% of losses were reimbursed, a figure which has increased over time. From October 2024, payment providers are required by law to reimburse APP victims, subject to some conditions.

London: House of Commons Library, 2025. 32p.

Seizing the opportunity: 5 recommendations for crypto assets-related crime and money laundering

By EUROPOL and Basel Institute on Governance,

These recommendations follow the 6th Global Conference on Criminal Finances and Cryptocurrencies on 1–2 September 2022. The conference was hosted by Europol at its headquarters in The Hague, the Netherlands, together with the Basel Institute on Governance through the Joint Working Group on Criminal Finances and Cryptocurrencies.

The Recommendations are intended to highlight broad approaches and best practices. They are designed to help public and private actors stay one step ahead of those seeking to abuse crypto assets (also known as virtual assets) and services to make, hide and launder illicit money.

The main message is that as the use of crypto assets expands into practically every country and sector, so does its abuse to commit new forms of crime and launder criminal proceeds. Yet with the right tools, capacity and cooperation, the unique characteristics of blockchain-based technologies offer an unprecedented opportunity to investigate organised crime and money laundering networks and to recover stolen funds.

The five recommendations cover:

  1. Breaking down silos between “traditional” and “crypto”

  2. Regulating broadly and make full use of existing laws 

  3. Taking advantage of the blockchain to disrupt organised crime 

  4. Raising crypto literacy through capacity building and clear communication 

  5. Increasing public-private cooperation

EUROPOL and Basel Institute on Governance, 2022. 6p.

Global Developments in Trade-Based Money Laundering

By George Herbert

This rapid research review provides an overview of the current state of knowledge on the scale and dynamics of trade-based money laundering (TBML) and key challenges and opportunities in relation to TBML, both globally and in relation to the United Kingdom (UK) specifically. The study took place over ten days in August and September 2022, and involved a review of existing literature, as well as two interviews with experts. Much of the literature reviewed originated from international organisations and publications by national governments, supplemented by news reports and publications by private sector firms.

K4D Emerging Issues Report 55.

Brighton, UK: Institute of Development Studies. .2022.165p.

Understanding the characteristics of serious fraud offending in the UK

By Michael Skidmore and Beth Aikenhead

This study aims to improve our understanding of the most serious fraud offences perpetrated in the UK, specifically the diversity of methods for committing these crimes, the characteristics and pathways of offenders involved and where applicable, how the groups or networks of offenders operate. This is an exploratory study which used qualitative data taken from the documents compiled by police practitioners in 25 separate criminal investigations. The cases included in this analysis do not constitute a representative sample of frauds in England and Wales during this period. The selection of cases reflects the choices made by the research team to incorporate a diversity of methods, offenders and settings to capture the breadth of fraud. Furthermore, the sampling frame is the product of practitioner choices over which crimes to assign investigation by specialist teams; these are a limited resource and due to the challenges of international investigation, will likely prioritise offending that has a footprint in the UK. Furthermore, in focusing on frauds that were perpetrated (at least in part) from within England and Wales it does not represent fraud offending that emanates from other countries. The specific fraud cases were serious for different reasons; high financial losses (£100,000 or more), high volume offending (50 or more known victims) and high victim impact (assessed by the victim and/or police practitioner). These dimensions of harm reflect those used in practitioner assessments for deciding which frauds are high harm and a priority for intervention. Only three cases satisfied all three harm criteria, all of which involved the mis-selling of investments. Twelve cases satisfied only one criterion and those linked to each dimension of harm were associated with different methods and victims; all cases that fulfilled the high financial loss criterion had defrauded businesses, and two out of three that fulfilled the high-volume criterion involved taking advance payment from consumers In five cases the scale of victimisation and impact was hidden, but they were included because they involved high-risk offenders suspected of being engaged in serious and complex offending. There was considerable diversity in the methods for perpetrating serious fraud and this study borrows from a typology of acquisitive crime developed in a previous study (Naylor, 2002). This model provided a good fit for distinguishing serious frauds on the basis of two overarching models of offending, and this delineation simultaneously revealed distinctions in the situational context, victim and offender profiles: • Commercial frauds: perpetrated from within a legitimate or pseudo-legitimate business setting and included the sale of investments or the mis-selling of products or services online or face-to-face, and nearly all had victimised individual members of the public. • Predatory frauds: involved theft by impersonating legitimate individuals or organisations, mostly by offenders operating from outside of a business setting and without the pretence of a legitimate commercial exchange. The victim profile was more varied, and over half had victimised businesses (for example, payment diversion fraud). There was divergence in the types of fraud offence encompassed by each category of fraud.

London: Police Foundation 2023. 39p.

Decoding Crypto Crime: A Guide for Law Enforcement

By The Organization for Security and Co-operation in Europe

The Organization for Security and Co-operation in Europe (OSCE) is proud to release a practical resource designed to empower law enforcement officers, prosecutors, and stakeholders in tackling cryptocurrency-related crimes. The guide "Decoding Crypto Crime: A Guide for Law Enforcement" simplifies complex concepts like blockchain technology and virtual assets, offering best practices for investigating common crypto crimes such as investment scams, extortion, and phishing.

It provides actionable steps for collecting critical evidence, interacting with Virtual Asset Service Providers (VASPs), and utilizing blockchain analytics tools. Recognizing the challenges victims face, the guide also offers support strategies and emphasizes the importance of cross-jurisdictional collaboration. While not exhaustive, this guide serves as a foundational tool to bridge the knowledge gap and enhance law enforcement’s ability to navigate the rapidly evolving world of crypto crime. Download the guide today to strengthen your capacity to combat digital financial crime and ensure a safer digital landscape.

Prague: OSCE, 2025. 64p.

Seizing the opportunity: 5 recommendations for crypto assets-related crime and money laundering

By Europol

These recommendations follow the 6th Global Conference on Criminal Finances and Cryptocurrencies on 1–2 September 2022. The conference was hosted by Europol at its headquarters in The Hague, the Netherlands, together with the Basel Institute on Governance through the Joint Working Group on Criminal Finances and Cryptocurrencies.

The Recommendations are intended to highlight broad approaches and best practices. They are designed to help public and private actors stay one step ahead of those seeking to abuse crypto assets (also known as virtual assets) and services to make, hide and launder illicit money.

The main message is that as the use of crypto assets expands into practically every country and sector, so does its abuse to commit new forms of crime and launder criminal proceeds. Yet with the right tools, capacity and cooperation, the unique characteristics of blockchain-based technologies offer an unprecedented opportunity to investigate organised crime and money laundering networks and to recover stolen funds.

The five recommendations cover:

  1. Breaking down silos between “traditional” and “crypto”

  2. Regulating broadly and make full use of existing laws 

  3. Taking advantage of the blockchain to disrupt organised crime 

  4. Raising crypto literacy through capacity building and clear communication 

  5. Increasing public-private cooperation

Europol and Basel Institute on Governance, 2022.  6p.

Who benefits? Shining a light on the business of child sexual exploitation and abuse

By Childlight (Global Child Safety Institute)

The sexual exploitation and abuse of children is a global health crisis. This report – presenting a diverse set of studies into the nature of the crisis – underscores the need for urgent action, provides solutions and shines a light on the financial networks that fuel child sexual exploitation and abuse (CSEA). The theme – who benefits? – asks a critical question: who is making money from this vile trade? The answer is as disturbing as it is clear. Organised crime groups profit, of course, but so do mainstream technology companies. 

The report shows that advertising revenue increases when platforms attract high volumes of traffic, including traffic generated by offenders engaging in CSEA. The exploitation of children is not just an atrocity — it is an industry, generating billions of dollars in profits. This is a market, structured and profitable, designed to generate revenue off the backs of vulnerable children. But markets can be disrupted, and that is where change must begin. Governments, businesses and communities must shift to a prevention-focused approach that stops CSEA before it begins.

Key findings

  • Offenders are evolving, adapting and exploiting gaps in legislation and regulations.

  • Offenders groom single parents via dating apps to access their children.

  • Offenders target displaced children in conflict zones like Ukraine.

  • Images are traded using sophisticated payment methods, including cryptocurrencies, to evade detection.

Key solutions

  • Law enforcement and financial institutions can use tell-tale digital breadcrumbs to track and dismantle CSEA networks.

  • Tech companies must be held accountable, pro-actively detect and remove child sexual abuse material (CSAM), and make more effective use of tried and tested tools, like blocklists, to shut down access to CSAM.

  • Policymakers must act decisively, as the United Kingdom has begun to do, by criminalising AI-generated CSAM and banning so-called ‘how-to’ manuals for paedophiles. 

Edinburgh: University of Edinburgh, Childlight, 2025. 15p.

Money Laundering and Terrorist Financing in the Art and Antiquities Market

By The Financial Action Task Force (FATF)

The market of art, antiquities and other cultural objects has attracted criminals, organised crime groups and terrorists to launder proceeds of crime and fund their activities. Criminals seek to exploit the sector’s history of privacy and the use of third-party intermediaries while terrorist groups can use cultural objects from areas where they are active to finance their operations.

The vast majority of market participants do not have a connection to illicit activities, but there are risks associated with these markets and many jurisdictions do not have sufficient awareness and understanding of them. This results in a lack of investigative resources and expertise, and difficulties with pursuing cross-border investigations.

The report includes a list of risk indicators that can help public and private sector entities identify suspicious activities in the art and antiquities markets, and also highlights the importance of rapidly identifying and tracing cultural objects involved in money laundering or terrorist financing.

The report includes some good practices that countries have taken to address the challenges they face, including the establishment of specialised units and access to relevant databases and cooperation with experts and archaeologists to help identify, trace, investigate and repatriate cultural objects.

Paris: The Financial Action Task Force (FATF), 2023. 60p.

Countering Ransomware Financing

By The Financial Action Task Force (FATF)

Ransomware attacks target individuals, businesses and government agencies, across the world. The impact of these attacks can be devastating for individuals, government agencies and business activity and even disrupt essential infrastructure and services.

This FATF report analyses the methods that criminals use to carry out their ransomware attacks and how payments are made and laundered. Criminals are almost exclusively using crypto, or virtual assets and have easy access to virtual asset service providers around the world. Jurisdictions with weak or non-existent AML/CFT controls are therefore of concern.

The report proposes a number of actions that countries can take to more effectively disrupt ransomware-related money laundering. This includes building on and leveraging existing international cooperation mechanisms, given the transnational nature of ransomware attacks and related laundering. Authorities also need to develop the necessary skills and tools to quickly collect key information, trace the nearly instantaneous financial transactions and recover virtual assets before they dissipate. The multi-disciplinary nature of ransomware also means that authorities must extend their collaboration beyond their traditional counterparts to include cyber-security and data protection agencies.

The FATF also finalized a list of potential risk indicators that can help public and private sector entities identify suspicious activities related to ransomware.

Paris: The Financial Action Task Force (FATF) 2023. 54p.

Illicit Finance: Agencies Could Better Assess Progress in Countering Criminal Activity

By Triana McNeil

 Criminal organizations generate money from illicit activities such as drug and human trafficking and launder the proceeds. Federal agencies investigate illicit activity and have developed several strategies and efforts to combat these crimes. GAO was asked to review efforts to counter illicit finance activities. This report addresses, among other things, (1) selected agencies’ roles and responsibilities in investigating and prosecuting illicit finance activities and (2) the progress made with selected strategies and efforts to counter illicit finance activities. To address these objectives, GAO reviewed agency documents and data, including those related to eight selected federal strategies and efforts on countering illicit finance activities. GAO compared four of these strategies and efforts—which represent long range, multi agency undertakings—to selected key practices for evidencebased policymaking and for interagency collaboration. What GAO Recommends GAO is making four recommendations, including that Treasury collect and assess performance information on implementing the Illicit Finance Strategy, and that the Department of State and U.S. Agency for International Development establish goals and assess progress for implementing the Initiative. Treasury disagreed with the recommendation, State agreed with the intent of the recommendation but believes it already addressed it, and USAID agreed.

The National Security Council did not provide comments. 2025. 94p.

Organized crime behavior of shell-company networks in procurement: prevention insights for policy and reform 

By J. R. Nicolás-Carlock and  Luna-Pla

In recent years, the analysis of economic crime and corruption in procurement has benefited from integrative studies that acknowledge the interconnected nature of the procurement ecosystem. Following this line of research, we present a networks approach for the analysis of shell-companies operations in procurement that makes use of contracting and ownership data under one framework to gain knowledge about the organized crime behavior that emerges in this setting. In this approach, ownership and management data are used to identify connected components in shell-company networks that, together with the contracting data, allows to develop an alternative representation of the traditional buyer-supplier network: the module-component bipartite network, where the modules are groups of buyers and the connected components are groups of suppliers. This is applied to two documented cases of procurement corruption in Mexico characterized by the involvement of large groups of shell-companies in the misappropriation of millions of dollars across many sectors. We quantify the economic impact of single versus connected shell-companies operations. In addition, we incorporate metrics for the diversity of operations and favoritism levels. This paper builds into the quantitative organized crime in the private sector studies and contributes by proposing a networks approach for preventing fraud and understanding the need for legal reforms.   

Trends in Organized Crime (2024) 27: pages 412–428

Lipstick on a Slaughtered Piggybank: Civil RICO Against “Pig Butchering” Cryptocurrency Investment Schemes

By Samantha B. Larkin

Niki Hutchinson, at twenty-four years of age, decided it was time to start dating. She thought she connected with a guy named Hao on Hinge, a dating website. The two started messaging and formed a bond after Hao told Niki he was born in the same town in China from which she was adopted. After learning she recently lost her mom, Hao offered to help Niki make money with her inheritance and told her he knew how to invest in cryptocurrency. While Niki was initially skeptical, Hao eventually instructed Niki on how to make wire transfers from her bank account to Crypto.com, an exchange platform. Through illustrated screenshots and text messaging, Hao described to Niki exactly how to use the platform. From there, Hao convinced Niki to transfer her crypto assets to another website. On the second platform, Niki saw profits in her account and decided to keep investing. She even convinced her father to invest in cryptocurrency too. But when Niki went to withdraw her virtual funds, she was informed that she needed to pay the tax bill with a new transfer of capital to release her earnings. The realization then set in that Niki and her dad lost over $390,000 to scammers. The scam Niki encountered is called “pig butchering.” Pig butchering is a billion-dollar industry of loss, draining American bank accounts, according to official government publications. Scammers abroad invented the term, referring to the concept of “fattening a pig before the slaughter,” where the goal is to nourish trust and confidence in a virtual relationship before conning the victim out of their money and slaughtering their savings. Cryptocurrency is the signature of the scheme. According to complaints received by the Federal Bureau of Investigation’s (FBI) Internet Crime Complaint Center (IC3), the typical targets in crypto-investment scams are individuals between the ages of thirty and forty-nine. Aiming at young professionals with disposable income, these scammers vet their targets to ensure a level of sophistication with technology and susceptibility to emotional manipulation. Scammers then coach their targets into virtual exchanges on false websites, where the victims are manipulated into believing they are making a profit. Their investments increase over time, typically until the victim attempts to cash out their illusory gains, and then the scam reaches its final stage: the victim is informed they need to pay exorbitant taxes or fees with fresh crypto transfers in order to release their funds. In reality, their assets were already gone. (continued)

Roger Williams University Law Review, Volume 30, Issue 1 (2025) Winter 2025, 47p.

The virtual asset ecosystem in El Salvador: risks and challenges to counter financial crime

By Global Financial Integrity and the Cyrus R. Vance Center for International Justice

On September 7, 2021, El Salvador became the first country in the world to adopt Bitcoin as legal tender. Two years later, the country has undergone technological change and growth, faced operational and regulatory challenges, and learned a tremendous amount in the process. This joint publication by the Vance Center and Global Financial Integrity (GFI) analyzes virtual assets (VAs) in El Salvador, first from a legal and regulatory perspective, as well as from an anti-money laundering (AML) and counter-terrorism financing (CFT) perspective The first half of the report analyzes the current regulatory landscape in El Salvador regarding Bitcoin and VAs. El Salvador has taken a major leap in embracing technological innovation, specifically in the digitalization of the financial system, through adopting bitcoin, cryptocurrencies, and digital assets. The country has established a regulatory framework encompassing the Bitcoin Law, the Digital Assets Issuance Law, and the Innovation and Manufacture of Technologies Promotion Law. These laws aim to provide a supportive environment for individuals and businesses engaging in transactions involving digital currencies while fostering innovation and technology manufacturing within the nation.

As a result, El Salvador is poised to become a leading proponent of emerging technologies across various sectors of its economy. Due to the dynamic nature of the subject matter and the ongoing efforts to standardize these frameworks internationally, the report identifies additional areas that may still require regulation.

The second half of the report analyzes VAs in El Salvador from an AML/CFT perspective. The report approaches these issues from the perspective of the Financial Action Task Force (FATF), which states that “the cornerstone (…) is the risk-based approach which emphasizes the need for countries to identify and understand the money laundering (ML) and terrorism financing (TF) risks they are exposed to.”

Understanding risks enables countries such as El Salvador to take mitigating measures and to deploy limited resources effectively. In this regard, the report analyzes financial crime risks for the most common predicate offenses for ML in El Salvador, considering drug trafficking, extortion, migrant smuggling, and misappropriation of public funds (peculado). The report also assesses financial crime risks related to specific operational features or developments within El Salvador’s VA ecosystem.

The report concludes with policy recommendations that can help El Salvador to maximize the benefits and minimize the risks associated with financial innovation. Key recommendations include:

Policymakers in El Salvador should urgently adopt reforms strengthening AML/CFT as well as ensuring robust oversight over VAs. These reforms are particularly important in light of El Salvador’s upcoming Mutual Evaluation.

The Government of El Salvador, and specifically the Central Reserve Bank (BCR) and the National Commission of Digital Assets (NCDA), should engage with the legal and business community in developing regulations and technical standards according to need and practice for the Bitcoin Law and Digital Assets Issuance Law, following international best practices.

Lawyers and law firms advising companies wanting to operate in El Salvador should enhance compliance mechanisms to verify client backgrounds to prevent criminal actors from entering the national financial system.

All relevant government agencies should ensure transparency and access to public information, including contractual and operational processes, fraud and mismanagement investigations, and the use of public funds, per domestic laws and international standards.

The BCR should incorporate information on government Bitcoin purchases into the Balance of Payments and other similar documents.

The Superintendence of the Financial System (SSF) should require that Chivo Wallet collect information on legal persons opening Chivo Wallet accounts in line with the requirements for legal persons to open other types of financial accounts. In addition, Chivo Wallet should maintain beneficial ownership information for legal persons using Chivo Wallet, in line with FATF Recommendation 15’s interpretive guidance and similar to the requirements for financial institutions.

Considering that financial institutions and other obligated entities submit suspicious transaction reports (STRs) for crypto transactions, the Financial Intelligence Unit (FIU) of El Salvador and other government authorities should provide education and training opportunities to the financial sector and other obligated entities regarding identification of red flag indicators in crypto transactions. This will help to ensure that STRs contain relevant information and reflect an informed understanding of the risks.

Washington, DC: Global Financial Integrity 2023. 63p,

The Hawala System: Its Operations and Misuse by Opiate Traffickers and Migrant Smugglers

By The United Nations Office on Drugs and Crime

Key findings • Hawala is a Money or Value Transfer Service (MVTS) that has been used for centuries, originating in the Middle East and South Asia. It is overwhelmingly used for legitimate purposes, including personal and business financial transactions and for the sending of remittances by migrants and refugees to family members. Cultural preferences, convenience, low-threshold accessibility, low processing fees, reliability, and faster value transfer services are some of the reasons for using hawala, and customers using the service come from all walks of life. • Despite being widely used for legitimate purposes, some attributes of the hawala system also make it vulnerable to use by organised crime for the purposes of transferring illicit funds and values. This includes financial transfers by drug traffickers, migrant smugglers and other criminal actors and organisations, as well as safekeeping of funds obtained from illegal activity. The 113 hawaladars interviewed for this study do not commonly ask about the source of money or the reason for sending and receiving money. Additionally, when they did have doubts about the source of the funds, over half of the interviewed hawaladars reported that they had never refused a hawala transaction. • There is no single global regulatory framework for the hawala system. However, the Financial Action Task Force (FATF) has produced international standards and recommendations for countries to take measures to regulate the hawala system and ensure regular monitoring and compliance. Specific regulations and monitoring regimes vary by country, but FATF recommends countries take a risk-based approach to regulating the hawala system. Of the 18 countries covered by this study, the hawala system was regulated in most of them. However, in four countries it was not regulated, and in Afghanistan – following the events of August 2021 – the current regulatory status of the hawala system is unclear as of the time of writing. • Of the 113 hawaladars interviewed for this report, 43 per cent of hawaladars declared they had a license to operate. In jurisdictions where it is a requirement, 25 per cent operated without a license and 31 per cent preferred not to respond. 36 per cent of the interviewed hawaladars stated that they provided reports to the Central Bank or other relevant financial authorities about their hawala activities, while 64 per cent either had never reported or preferred not to answer the question. Licensed hawaladars collected more personal information from their customers and require identification documents, while for unlicensed hawaladars a name and contact number is sufficient to process a transaction. • Of the hawaladars interviewed in this

study, over one-third reported that they ran multiple branches within the same country and more than half of them reported having offices in other countries. Regular hawala customers are likely to receive a discount on commission charges by hawaladars. • People engaging in regular and irregular migration constitute one customer base of the hawaladars interviewed in this study. Over half of reported that they had migrants as customers. The findings of this study suggest that hawaladars – knowingly and unknowingly - facilitate irregular migration and migrant smuggling by providing multiple financial services including, but not limited to, money or value transfer, safekeeping of funds and introducing migrants and refugees to migrant smugglers. • There are multiple reasons why migrants and refugees would use hawala before, during and after traveling, and these are broadly linked to the features of the system, and, for some, lack of access to any other financial system, such as banks or mobile money services. Migrants and refugees may be directed to a hawaladar by a friend or relative, smuggler, fellow traveller, shopkeeper or accommodation provider. • The interviewed hawaladars identified the following services they provided to migrants and refugees during their journeys: guiding migrants on their journey; helping with finding work upon arrival; referring migrants to support organizations; providing temporary accommodation or referring migrants to an individual who provides temporary accommodation; and finding local medical aid, as undocumented migrants may not be able to or may be reluctant to access hospitals. • Some hawaladars also assist migrants and refugees by finding, recommending or introducing them to a smuggler; and finding or directly renting out boats and trucks for transportation. • The majority of customers using the services of the 113 hawaladars interviewed for this study sent funds to countries located in the Near and Middle East/ South-West Asia sub region, followed by Western and Central Europe and South-Eastern Europe subregions. Customers in the Near and Middle Eastern sub-regions frequently sent funds to hawaladars in most of the eighteen countries where interviews were conducted. Customers of the interviewed hawaladars in the countries of the North American sub-region only sent funds to hawaladars interviewed in Afghanistan, Denmark, Nigeria, Somalia, and the United Republic of Tanzania. • Hawala is widely associated with transferring money or value - this was the most common type of service provided by the sample group in this study. However, sending and receiving money is just one among several financial services hawaladars provide. Cash savings, currency exchange, short-term lending, safekeeping of funds, and trade guarantees were other services the interviewed hawaladars provided to their customers to varying degrees. Some of them safekeep customers’ funds. The amount of funds kept for safekeeping with the interviewed hawaladars ranged from US$ 20,000 to US$ 500,000. • Hawaladars often operate additional businesses alongside their hawala business. Some of the side businesses mentioned by interviewed hawaladars were grocery store, travel agency, selling mobile top-up cards, construction company and electronics shops. • A hawala transaction does not always proceed directly from country A to country B. Depending on the source and destination, sometimes a transaction is carried out through one or more intermediary hawaladars located in at least one other country. Hawaladars interviewed for this study reported that there are multiple hawala hubs located in several regions of the world where such intermediary hawaladars operate. • Hawaladars interviewed in this study reported processing both domestic and international transactions, however, nearly three out of four processed mostly international transactions. The amount of a single hawala transaction varies substantially. Transactions handled by the interviewed hawaladars ranged from as low as US$50 and as high

as US$200,000. To keep a record of these transactions, most hawaladars interviewed in this research reported that they keep a paper (ledger book) as well as an electronic (digital) record of hawala transactions and other services provided. • Hawaladars use a variety of methods to settle their accounts including through cash, reverse transaction, bank transfer or trading in goods and services. Reverse transaction was the most often used method of account settlement among the hawaladars interviewed in this study, followed by settlement through bank transfer. Misuse of the hawala service • In addition to its widespread legitimate use, hawala is vulnerable to misuse by organized crime groups and other criminal actors. More than one-third of the interviewed hawaladars judged the hawala system to be more vulnerable to illegal transactions compared to the formal banking system, while some perceived an equal vulnerability in both systems. A lack of proper oversight by national authorities, a lack of reporting by hawaladars, a lack of regulation, policy, or guidelines for hawaladars to follow, the operation of unlicensed hawaladars, and the closed nature of the hawala system are all potential reasons for vulnerability. • There are no exact estimates as to the extent to which hawaladars, knowingly or unknowingly, facilitate the misuse of their financial services for criminal purposes. Some hawaladars interviewed for this research reported the direct involvement of other hawaladars in transferring funds associated with illegal activities. Additionally, some criminal groups have hawaladars, who may be relatives, working specifically for them for the purposes of transferring funds linked to organised crime. • Several of the interviewed hawaladars reported that they do not ask the purpose of transactions from their customers. As a result, it is possible that hawaladars involved in handling transactions of illicit proceeds are not aware of the nature and source of the money they are transferring or safekeeping. This is particularly the case with hawaladars who are dealing with smaller transactions which usually do not arouse suspicions. However, some hawaladars reported that they could not refuse a transaction from customers connected with Organized Crime Groups (OCGs) due to the risk of negative consequences for themselves and their businesses. • It remains a challenge to precisely document the degree to which hawaladars are transferring illicit funds; it is also difficult to trace illicit financial flows, to separate them from licit flows, and to establish concrete financial links to criminal activities. Law enforcement agencies face challenges in investigating crimes linked to hawala systems, because of the closed nature of the business and, in some cases, the kinship ties of the actors.

Vienna: United Nations Office on Drugs and Crime, 2023. 91p.

Detecting Money Laundering Through Trade Flow Analysis: An Empirical Case Study on Money Laundering in the Belgium Cocaine Trade

By Bendik Brunvoll and Bjørn Øvstedal

Europe has seen an increase in cocaine seizures in recent years. As the criminal landscape in South America has seen noticeable changes, there has been a shift in how cocaine enters Europe. Belgium has become the primary gateway for cocaine trafficking to Europe. With increased cocaine imports, organized criminal gangs have more money to be laundered. This thesis analyzes Belgium's trade data to investigate whether increased cocaine trafficking impacts a country's international trade flow. We propose

a method of detecting money laundering by analyzing trade flows of goods related to money laundering. This is done by introducing the synthetic difference-in-differences method in a case study. We analyze trade flows from 2000 to 2019 between Belgium, tax havens, and cocaine trafficking countries. The thesis finds that as Belgium experiences an increase in cocaine seizures, there is a significant increase in the import of diamonds, arts, and antiquities from cocainetrafficking countries. However, there is no conclusive evidence of increased money laundering activities between Belgium and tax havens. The method cannot conclude the causes of increased imports. However, it can be a tool to narrow down different countries and products to identify trade flows that raise suspicion regarding money laundering activities. Further work should analyze the trade flows identified by the proposed method to detect money laundering.

Norwegian School of Economics Bergen, Spring 2022 48p.

Trade-Based Money Laundering: A Global Challenge

By Global Financial Integrity, Fedesarrollo, Transparency International Kenya and ACODE

This policy memo is a joint publication by GFI, Fedesarrollo, Transparency International Kenya and ACODE, organizations that are based in the United States, Colombia, Kenya and Uganda, respectively. The memo draws on the technical and regional expertise of each of the organizations, seeking to analyze the complex challenges of Trade Based Money Laundering (TBML) from a truly global policy perspective. Broadly speaking, illicit financial flows (IFFs) are illegal movements of money or capital from one country to another. GFI classifies this movement as an illicit flow when funds are illegally earned, transferred, and/or utilized across an international border. The global scale of IFFs is considerable. According to the United Nations Conference on Trade and Development (UNCTAD), Africa loses US$88.6 billion annually to IFFs. In the case of Latin America and the Caribbean, the United Nations Economic Commission for Latin America and the Caribbean (UN ECLAC) estimates that from 2004- 2013, illicit financial outflows represented 1.8% of regional gross domestic product (GDP) and 3.1% of regional trade, with losses totalling US$765 billion for the 10-year period. Moreover, IFFs undermine institutions, contribute to insecurity, harm communities and the environment, and deprive countries of much-needed tax revenues. One of the most prevalent channels for IFFs is through the international trade system. As of 2021, GFI estimates that the annual value of trade-related IFFs in and out of developing countries amounted to, on average, about 20 percent of the value of their total trade with advanced economies. One area of particular concern is TBML, which the Financial Action Task Force (FATF) defines as the process of disguising the proceeds of crime and moving value through the use of trade transactions in an attempt to legitimize their illegal origin or finance illicit activities.5 As FATF notes, “the aim of TBML—unlike trade-related predicate offenses—is not the movement of goods, but rather the movement of money, which the trade transactions facilitate.”6; 7 TBML involves acts designed to conceal or disguise the true origin of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets. It is a highly effective way of integrating large volumes of criminal proceeds with legitimate income, and is attractive to organized crime groups because it is very hard to detect, track and investigate due to its transnational nature and the complexity of the international trade system. Recent cases have highlighted the sophisticated methods used to exploit the complex supply chains of international trade to launder criminal assets. When TBML goes unchecked, it has adverse effects on economies and societies as it perpetuates criminal activities such as illicit wildlife trade, bribery, corruption, and tax evasion. It subjects legitimate business to unfair competition in areas of goods and services due to unbalanced economies as a result of artificial manipulations. Additionally, TBML results in revenue losses, especially for developing countries struggling to meet their domestic resource mobilization targets

Global Financial Integrity, 2023. 23p.

Organized Fraud Issue Paper

By United Nations Office of Drugs and Crime - UNODC

Fraud has evolved significantly over the years, adapting to technological advancements and changes in society. It has become increasingly sophisticated, often using psychological manipulation, enabled by information and communications technologies (ICTs). The high volume and severity of fraud pose a significant risk to people, economies and prosperity worldwide, and have a negative impact on the public’s confidence in the rule of law. However, developing an accurate understanding of fraud presents several challenges. Victims often underreport fraud due to feelings of shame, self blame or embarrassment, as well as a lack of recognition that a crime has occurred. Moreover, a significant portion of fraud targets businesses, many of which choose not to report these crimes to avoid damaging their reputation. The anonymity and remoteness often associated with fraud perpetration conceal the identities of offenders from both victims and authorities, hindering efforts to assess underlying patterns, factors of vulnerability and associated risks. Furthermore, the dynamic nature of fraud — which is constantly being adapted to changes in legal, social, commercial and technological systems — means that new and innovative methods of the offence may go unnoticed within static official data. In many cases, domestic law enforcement entities do not have the capacity to investigate and uncover the offenders and the organized criminal groups behind the crime: international cooperation is required, suggesting the need to give greater prominence to fraud in the policy framework and legislation against organized crime.

The international community has recognized the worrying scale of fraud and the need for joint efforts in preventing and combating it. The General Assembly, in its resolution 78/229, reaffirmed the importance of the work of the United Nations Office on Drugs and Crime (UNODC) in the fulfilment of its mandate in crime prevention and criminal justice, including providing to Member States, upon request and as a matter of high priority, technical cooperation, advisory services and other forms of assistance, and coordinating with and complementing the work of all relevant and competent United Nations bodies and offices in respect to all forms of organized crime, including fraud. Nevertheless, the intersection between fraud and organized crime is not well understood and is further complicated by overlaps with other key areas, including cybercrime, white-collar crime, money-laundering and corruption. An understanding of organized fraud is necessary to inform the decisions of policymakers and other stakeholders and drive effective responses. The United Nations Convention against Transnational Organized Crime, the main global legally binding instrument to prevent and fight all forms and manifestations of transnational organized crime and protect the victims thereof, provides a framework to understand the nature of organized fraud and how the response to it can be integrated into the response to the different threats presented by transnational organized crime.

Scope of the issue paper

Fraud is an expansive category of crime. One of the greatest challenges to understanding it is its scope. It encompasses a range of criminal behaviours that are bound together by the common principle of dishonesty. The opportunities to employ dishonesty for the purposes of fraud span the full range of social, commercial, financial and technological settings, which can vary in different regions of the world. These opportunities are exploited by criminals from highly diverse backgrounds, ranging from professionals exploiting a legitimate corporate position to cybercriminals from within deprived communities. In this way, fraud is distinct from many other criminal categories that cover more discrete criminal behaviours occurring in specific settings (e.g. burglary). This diversity creates challenges in terms of developing a single, cohesive and comprehensive picture of fraud. The present issue paper covers fraud perpetrated by organized criminal groups (i.e. organized fraud). The role of organized crime can vary depending on the type of fraud, although, to a greater or lesser extent, it has a footprint in nearly all types of fraud. For the purposes of containing the scope of the issue paper, the following elements are not included:

  • Other crimes in which fraud plays an enabling role, including the fraudulent use of identity to prevent a perpetrator from being traced, such as opening financial accounts to launder the proceeds of crime; fraudulent communications to enter into a relationship with a victim for the purpose of blackmailing or extorting money from them;1 and fraudulent job advertisements for recruiting and trafficking victims into forced labour and servitude.

  • Fraud targeting the financial interests of the State (e.g. tax regimes), such as missing trader intra-community fraud (otherwise known as MTIC or VAT fraud); excise fraud, in which duties on imported products are not paid (e.g. fuel); public procurement fraud; and fraudulent applications for government grants and subsidies. The policy and response landscape for addressing these types of fraud can be distinct, being made up of various agencies and regulatory powers beyond law enforcement (e.g. the tax authority). The links between these types of fraud and organized crime are more well established in the literature.

The focus of the issue paper is organized fraud that targets individual members of the public or private institutions for the purposes of obtaining a financial or other material benefit.

Vienna: UNODC< 2024. 82p.

Examining emerging fraud facilitated by the internet through crime scripts

By Benoit Leclerc and Elena Morgenthaler

The rise of the internet or, more specifically, of services offered and conducted online has led to a dramatic rise in frauds and scams. This study is a systematic review of the literature on the use of crime script analysis in the field of fraud facilitated by the internet to identify stages of the crime commission process across different forms of fraud and examine ways to disrupt those crimes. The scripts for different forms of fraud shared three common elements: communicating with the victim, recruiting enablers, and using money mules. These common elements suggest possible prevention measures. Future applications of crime scripts in the field of fraud and financial crime more broadly are discussed.

Trends & issues in crime and criminal justice no. 680.

Canberra: Australian Institute of Criminology. 2023. 28p.

Financial Crime Scripting: an Analytical Method to Generate, Organise and Systematise Knowledge on the Financial Aspects of Profit-Driven Crime

By Thom Snaphaan and Teun van Ruitenburg

This article presents a further development of the existing crime scripting framework to enhance insight in the financial aspects of profit-driven crime: financial crime scripting. By drawing on the foundations of crime script analysis, financial crime scripting allows to generate, organize and systematize knowledge about the financial aspects of the crime commission processes of a variety of crime types, and accounts for linking the dots with financial crimes, such as bribery, bankruptcy fraud and money laundering. Viewing these financial crimes as supporting or succeeding offences in light of profit-driven crimes, and at the same time providing guidance to analyze these offences as profit-driven crimes in itself, opens the door for detailed analyses without losing sight of the bigger picture, i.e., the interconnectedness with other crimes. This analytical method helps crime researchers to take into account the financial aspects of crime-commission processes in crime script analyses and could help law enforcement agencies and other crime prevention partners to go beyond a proceeds-of-crime approach and put a follow-the-money approach in practice. Financial crime scripting takes full account of the financial aspects of profit-driven crime and puts relevant concepts in broader perspective, enhancing understanding with conceptual clarity. In addition to outlining the framework, the relevance for policy and practice is unraveled and avenues for future research are discussed.)

European Journal on Criminal Policy and Research, 2024.