By Mathias Bak and Matthew Jenkins

Illicit financial flows (IFFs) undermine economic growth by weakening institutional quality, state legitimacy, facilitating corruption and discouraging foreign and domestic investment. Empirical studies that have explicitly assessed the links between IFFs and economic growth, either on a regional scale or at the national level, generally find that illicit financial outflows have a negative and significant impact on core determinants of economic growth, notably domestic investment. Evidence suggests that IFFs not only hinder growth in source countries but also distort investment patterns in destination countries, particularly in real estate markets.

Bergen: U4 Anti-Corruption Resource Centre, Chr. Michelsen Institute (U4 Helpdesk Answer 2025: 2. 44p.

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.

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.

By Vanya Petrova

Illicit cross-border financial flows – estimated at US$1–1.6 trillion a year globally – are harming economic development on a national and global level. This is particularly true when such flows originate in heavily étatist economies, with no effective division or independence of the private from the public or state-owned sector. Autocracies have long utilized obfuscated corporate ownership structures and illicit financial flows (IFFs) for nefarious purposes such as bribery, corruption and improper lobbying to secure anything from technologies and know-how to economic and political influence on countries of interest. Russia has established a pattern of malign economic impact in Europe through its cultivation of ‘an opaque network of patronage across the region that it uses to influence and direct decision-making’ in key markets and institutions. IFFs in the Balkan region, in particular, are manifold, multi-directional and, proportionally, large as a percentage of GDP. While global illicit outflows are 3–5% of world GDP, IFFs in the Balkans are estimated at about 6% of the region’s GDP. The common denominator of the Western Balkan countries is their vulnerabilities kindled by institutional weakness and state capture. IFFs promote rent-seeking and criminal behaviour, reduce governments’ capacity to support development and inclusive growth, undermine the rule of law and jeopardize the business environment. Illicit flows drain public resources, reduce the scope and quality of public services and, thus, undermine confidence in state institutions. The Kremlin has repeatedly taken advantage of its integration into the Western financial system to exploit governance gaps through the corrosive effect of illicit finance.7 The brutal invasion of Ukraine shed a harsh light on the sobering dangers of kleptocracy and the risks to which Europe – and the world – has exposed itself by taking a lax approach to dirty money. Russia’s war in Ukraine could exacerbate these circumstances and accelerate further IFFs in the Balkan region – a crucial entry point and essential route for a plethora of illegal activities, such as drug trafficking, human smuggling, illicit trade and contraband.8 Due to imposed travel bans, Serbia is one of the few remaining routes for Russians to establish themselves in the region. Since the start of the invasion of Ukraine, Russian nationals have registered more than 5 000 companies in Serbia, over 1 000 being limited liability companies and nearly 4 000 entrepreneurial businesses.9 The establishment of so many companies in the country offers fertile ground for money laundering.10 As observed in the Serbian national risk assessment by the Administration for the Prevention of Money Laundering, limited liability companies and entrepreneurs pose a particularly high degree of threat with respect to money laundering. Through such means wealthy Russians could seek investment opportunities and use existing connections to launder money in real estate and other sectors traditionally vulnerable to IFFs in the region. The primary goal of this report is to assess the major enablers and vulnerabilities of illicit finance in the eight Balkan countries (Albania, Bosnia and Herzegovina, Bulgaria, Croatia, Kosovo, Montenegro, North Macedonia and Serbia) after Russia’s invasion of Ukraine. More concretely, the study aims to analyze the primary IFFs sources and channels in the region, and identify any emerging trends concerning modus operandi, routes, business models, use of information and communications technology. In addition, the study intends to inspect the pressing challenges to border control, police and anti-money laundering authorities to effectively prevent, investigate and counter organized crime involved in cash smuggling and money laundering. Finally, the report aims to suggest feasible recommendations for improvement. The analysis presented is based on information collected through mixed methods research consisting of qualitative and quantitative desk research and in-depth interviews with key professionals from different organizations and professional affiliations in the eight countries. A total of 15 semi-structured interviews were conducted with experts from regional organizations, customs agencies, national anti-money laundering authorities, national revenue agencies, national customs agencies and NGOs, as well as with journalists and academics. A guiding questionnaire with key questions and topics was shared with the field researchers to facilitate the work and to ensure consistency in the information collection process.

Geneva, SWIT: Global Initiative Against Transnational Organized Crime (GI-TOC)’s , 2023. 24p.

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.

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.

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.

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.

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.

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.

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.

By Jo‑Anne Kramer, Arjan A. J. Blokland·, Edward R. Kleemans, Melvin R. J. Soudijn

In order to launder large amounts of money, (drug) criminals can seek help from financial facilitators. According to the FATF, these facilitators are operating increasingly business-like and even participate in professional money laundering networks. This study examines the extent to which financial facilitators in the Netherlands exhibit business-like characteristics and the extent to which they organize themselves in money laundering networks. We further examine the relationship between business-like behavior and individual money launderers’ position in the social network. Using police intelligence data, we were able to analyze the contacts of 198 financial facilitators who were active in the Netherlands in the period 2016–2020, all having worked for drug criminals. Based on social network analysis, this research shows that financial facilitators in the Netherlands can be linked in extensive money laundering networks. Based on the facilitators’ area of expertise, roughly two main types of professional money laundering networks can be discerned. Some subnetworks operate in the real estate sector, while others primarily engage in underground banking. Furthermore, the application of regression models to predict business-like behavior using individual network measures shows that facilitators with more central positions in the net work and those who collaborate with financial facilitators from varying expertise groups tend to behave more business-like than other financial facilitators.

Trends in Organized Crime (2024) 27:314–341

By Global Financial Integrity, FACT Coalition, and the Anti-Corruption Data Collective

Today Global Financial Integrity, in conjunction with the FACT Coalition and the Anti-Corruption Data Collective, is releasing a report with identifies 25 cases in which illegal, allegedly illicit or suspicious funds were funneled into commercial property in the United States over approximately the last 20 years. With a total value of property exceeding $2.6 billion, California, Florida and New York are some of the most favored locations for these illegal investments, but criminals stashed money across some 20 different states. This money originated from around the globe and includes suspicious funds from 14 countries, including Iran, North Korea, Kazakhstan, Russia and Mexico. As varied as the sources of funds were, so too were the types of properties involved. Hotels, shopping malls, supermarkets, a music studio and an equestrian facility in addition to more pedestrian office high-rise

It should be noted that our research represents only known cases involving U.S. commercial real estate: the actual number is likely much higher. Our data definitively shows, however, that commercial property in the U.S. offers criminal syndicates, cartels, kleptocrats and fraudsters an easy path to hide and launder their ill-gotten gains. Russian oligarchs facing international sanctions have also invested in U.S. commercial real estate. Shockingly, eight of the 25 cases involve foreign government officials or their relatives, yet the links to these Politically Exposed Persons were only uncovered long after the purchases.In recent years it has become increasingly clear that the combination of complex financing schemes and a lack of transparency mean commercial real estate provides a unique opportunity for laundering huge amounts of cash with a relatively low risk of detection. Identifying who is behind the purchase of commercial property often presents a significant challenge given large financial flows from real estate investment trusts and private investment groups, in addition to funds from shell companies formed and operated by registered agents, proxies and/or attorneys. Key Findings – More than $2.6 billion in suspicious funds were invested in commercial real estate in 22 U.S. states over approximately the last 20 years. The actual figure is likely much higher.– Funds used to buy commercial real estate in the United States originated in 14 different countries including Russia (4 cases), Mexico (4 cases), China, Malaysia, Iran and Kazakhstan (see Map 2). – Of the 25 cases reviewed for this study, 14 involved either politically exposed persons or oligarchs who typically have especially close relationships with foreign government officials. – The types of properties appearing in cases fall into four broad categories: land/buildings, business facilities (e.g. music studios, health facilities), retail spaces (e.g. supermarkets, hotels) and industrial sites (e.g. steel plants). – Weak or non-existent reporting requirements by professions involved in the purchase of commercial real estate contributed to the ease with which illicit funds were laundered.Recommendations 1.FinCEN should adopt a reporting obligation for multiple real estate professionals in a cascading order to ensure the requirement falls on at least one U.S.-based entity involved in the transaction, from both the buyer and the seller. As attorneys are legally required to be part of the closing process in almost 20 states, attorneys should be included with specific reference to the function they perform in the transaction.The rule should cover transfers of ownership that do not constitute a sale. Current rules only refer to purchases of real property by a legal entity. However, numerous cases of real estate money laundering simply involve the transfer of ownership or creation of equitable interest in the property without an actual sale. FinCEN should expand the types of transactions covered to include direct/indirect transfers of ownership or creation of equitable interest in the property.The rule should cover transactions by trusts: An increasing proportion of housing is now owned by legal entities and arrangements, including trusts. In Los Angeles, for example, 23% of rental units are owned by trusts. Both foreign and some domestic trusts are excluded from the purview of the Corporate Transparency Act. We recommend that transactions by all different classes of legal entities and legal arrangements be included in any prospective rule.

Washington, DC: Global Financial Integrity, 2024. 21p.

By Andres Martinez-Fernandez

Key Points

• Corruption is an urgent challenge in Mexico that undermines political stability, economic development, the rule of law, efforts to combat organized crime, and the effectiveness of public services.

• Corruption in Mexico’s security forces is a key contributor to the sharp rise of organized criminal violence and severely handicaps US-Mexico security cooperation against drug cartels.

• President Andrés Manuel López Obrador’s emphasis on combating money laundering and his empowerment of Mexico’s Financial Intelligence Unit are positive developments for the government’s anti-corruption efforts. However, an increasingly hostile stance to US-Mexico security cooperation, the politicization of investigations, neglect of independent institutions, and inattention to cartel corruption are all concerning.

• The US should use a combination of diplomatic engagement, expanded cooperation against money laundering, and unilateral enforcement actions to restore trust and the effectiveness of bilateral security and anti-corruption cooperation while pushing Mexico to address its anti-corruption blind spots.

Washington, DC: American Enterprise Institute, 2021. 32p.

By Saana Rikkilä, Pirjo Jukarainen, Vesa MuttilainenNordic Council of Ministers

Nordic countries are viewed as having low levels of corruption. However, Nordic businesses can be exploited in corruption or money laundering schemes. The KORPEN project (Korruption i samband med näringsverksamhet i Norden) was funded by the Nordic Council of Ministers, coordinated by the Ministry of Justice, Finland and implemented by the Police University College. The project concludes that anti-corruption and anti-money laundering (AML) efforts share the same features and actors but are still rather separated. Some shared methods could be utilised in combatting both crimes. In general, the AML frameworks are more structured, whereas corruption and bribery are not viewed as such a serious issue in the Nordic countries. There are incidents in the Nordic region of interconnected corruption and money laundering. New risk assessment approaches and technology solutions could be of help.

Copenhagen: Nordic Council of Ministers, 2022. 104p.

By Melina Risso, et al.

Environmental crime became the world’s third most lucrative illicit economy after drug trafficking and smuggling, with estimates of $110 to $281 billion in annual profits. Between 2006 and 2016, environmental crimes grew at a rate of 5% to 7% per year, a pace two or three times faster than that of global GDP growth. Money laundering is part of the criminal machinery that plunders the Amazon Rainforest.

The study “Follow the Money: connecting anti-money laundering systems to disrupt environmental crime in the amazon” reveals the need for systems, agencies, and institutions responsible for preventing money laundering to turn their attention to the connections between this illicit practice and environmental crimes.

The Igarapé study shows that the money laundering cycle follows three stages before the laundered funds can enter the financial system: placement, layering, and integration. However, not all proceeds from criminal activity are directly laundered into the formal financial system. Thus, informal diversification constitutes the process of moving illegal flows into the informal economy. It is estimated that 30% of the money to be laundered is used to pay the operating expenses of illicit economies. Cash transactions, divided into small amounts and deposited by “money mules,” are used to finance the hiring of precarious labor, accommodations, food, security, transportation, health services, leisure, and machinery, for example. The remaining 70% of illicit proceeds are formally inserted into the financial system.

Rio de Janeiro - RJ - Brasil ; Igarape Institute, 2023. 33p.

ByThe Financial Action Task Force

he COVID-19 pandemic has led to unprecedented global challenges, human suffering and economic disruption. It has also led to an increase in COVID-19-related crimes, including fraud, cybercrime, misdirection or exploitation of government funds or international financial assistance, which is creating new sources of proceeds for illicit actors. Using information provided to the members of the FATF Global Network on 7 and 23 April, this paper identifies challenges, good practices and policy responses to new money laundering and terrorist financing threats and vulnerabilities arising from the COVID-19 crisis.

As the world is focusing on responding to the COVID-19 pandemic, it is impacting on the ability of government and the private sector to implement anti-money laundering and counter terrorist financing (AML/CFT) obligations in areas including supervision, regulation and policy reform, suspicious transaction reporting and international cooperation. This could lead to emerging risks and vulnerabilities that could result in criminals finding ways to:

• Bypass customer due diligence measures;

• Increase misuse of online financial services and virtual assets to move and conceal illicit funds;

• Exploit economic stimulus measures and insolvency schemes as a means for natural and legal persons to conceal and launder illicit proceeds;

• Increase use of the unregulated financial sector, creating additional opportunities for criminals to launder illicit funds;

• Misuse and misappropriation of domestic and international financial aid and emergency funding;

• Exploit COVID-19 and the associated economic downturn to move into new cash-intensive and high-liquidity lines of business in developing countries.

AML/CFT policy responses can help support the swift and effective implementation of measures to respond to COVID-19, while managing new risks and vulnerabilities. This paper provides examples of such responses, which include:

• Domestic coordination to assess the impact of COVID-19 on AML/CFT risks and systems;

• Strengthened communication with the private sector;

• Encouraging the full use of a risk-based approach to customer due diligence;

• Supporting electronic and digital payment options.

Paris: FATF, 2020. 34p.

By The Financial Action Task Force (FATF)

The COVID-19 pandemic has led to unprecedented global challenges, human suffering and economic hardship. The pandemic has also spawned a range of COVID-19-related crimes, which are creating new sources of income for criminal networks. In May, the FATF highlighted the COVID-19-related money laundering and terrorist financing risks and policy responses.

Today, the FATF releases an Update-COVID-19-Related-Money-Laundering-and-Terrorist-Financing-Risks

The paper confirms the concerns expressed by the FATF in May, including:

• Changing financial behaviours - especially significant increases in online purchases due to widespread lockdowns and temporary closures of most physical bank branches, with services transitioning online.

• Increased financial volatility and economic contraction - largely caused by the losses of millions of jobs, closures of thousands of companies and a looming global economic crisis.

To respond to these evolving risks, authorities and the private sector need to take a risk-based approach, as required by the FATF Standards. This means mitigating the money laundering and terrorist financing risks without disrupting essential and legitimate financial services and without driving financial activities towards unregulated service providers.

Supervisors should also clearly communicate about the national risk situations and regulatory expectations. There is no one-size-fits-all approach. However, the FATF’s report on risks and policy responses provides guidance on how jurisdictions should address these issues.

Paris: FATF, 2020. 34;p.

By G. Herbert

This review provides a summary of the evidence on Illicit Financial Flows (IFFs) between China and developing countries in Africa and Asia. Specifically, it looks at the evidence on how IFFs to and from China impact on developing countries, as well as on the drivers of IFFs and of how flows are facilitated. The review draws upon a combination of academic and grey literature sources, though it is not exhaustive and only draws upon English language sources. IFFs involving China have attracted particular attention, due to estimates suggesting it is responsible for the largest IFFs by value globally. However, little has been published to date specifically on IFFs between China and developing countries. This paper attempts to help address this gap. Section 2 provides some background information on the debates and uncertainties around IFFs, including conceptual issues, difficulties in measuring these flows, and their potential impacts, as well as attempts to quantify China’s overall IFFs. Section 3 focuses on trade-related IFFs between China and developing countries in Asia and Africa. Discrepancies indicative of potential IFFs are identified using trade data from 2018 and an attempt is made to determine the scale of the revenue consequences of trade is-invoicing for China’s developing country partners. Section 4 considers IFFs-related to corrupt business practices, focusing largely on Chinese investment in Africa. Section 5 moves on to consider IFFs that relate to the trade in illegal products, including illegal narcotics, human trafficking, the illegal arms trade, the illegal wildlife trade, the illegal organ trade, and the trade-in counterfeit products. Finally, Section 6 discusses enabling environment factors relevant to IFFs between China and developing countries.

K4D Helpdesk Report.

Brighton, UK: Institute of Development Studies. 2020. 37p.

By Paul Michael Gilmour

Purpose – Money laundering poses significant challenges for policymakers and law-enforcement authorities. The money-laundering phenomenon is often acknowledged as a type of “serious and organised crime” yet has traditionally been described as a complicated three-stage process, involving the “placement, layering and integration” of criminal proceeds. This article aims to reexamine the money-laundering concept within the realm of organised crime and critique its legal underpinnings. Design/methodology/approach – This paper explores how criminal actors collude in organised money laundering schemes to circumvent laws and frustrate the efforts of officials, while advancing the regulatory-spatial paradigms of which organised money launderers operate. In doing so, it reframes the debate towards the “who” and “where” of money laundering. Findings – This paper argues that authorities’ efforts to combat money laundering relies on rigid legal definitions and flawed ideals that fail to address the money-laundering problem. Originality/value – There has been little scholarly debate that questions the fundamental approach to conceptualising money laundering. This paper proposes a new approach to combating money laundering that better incorporates the actors involved in money laundering and the spaces in which it occurs.

Journal of Financial Crime , 2022