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 Fawzi Banao, Bertrand Laporte

The actions of terrorist groups destabilize border states and economies. The presence of mining activities, such as gold extraction, favors the illicit export of this ore to finance terrorist groups. Using COMTRADE data, we estimate gold customs fraud with mirror analysis (gold export missing) for 50 African countries between 2000 and 2019. We use ordinary least squares, two-stage least squares, generalized method of moments, and local impulse strategy in our empirical strategies to estimate the impact of terrorism on gold customs fraud. Our results suggest that states affected by terrorism must pay more attention to the trafficking of gold, as this is a valued mineral for terrorist groups. The response to conflict with terrorist groups cannot be solely military. The State must necessarily get the various state services to work together, particularly the army, the police, and customs. The institutionalization of this cooperation remains a real challenge for these states. Regarding customs administration efficiency, data analysis is at the core of customs modernization programs. Only internal and external trade data have been used in risk management systems. Cooperation with the armed forces must allow the acquisition of tools and skills to analyze other data sources, such as satellite data. Customs could then carry out all of its missions at the borders: collecting duties and taxes but also protecting the local/border economy and cutting off the funding sources for terrorist groups.

Clermont-Ferrand, France Centre d’Études et de Recherches sur le Développement International, 2022. 27p.

y Fawzi Banao, Bertrand Laporte

The actions of terrorist groups destabilize border states and economies. The presence of mining activities, such as gold extraction, favors the illicit export of this ore to finance terrorist groups. Using COMTRADE data, we estimate gold customs fraud with mirror analysis (gold export missing) for 50 African countries between 2000 and 2019. We use ordinary least squares, two-stage least squares, generalized method of moments, and local impulse strategy in our empirical strategies to estimate the impact of terrorism on gold customs fraud. Our results suggest that states affected by terrorism must pay more attention to the trafficking of gold, as this is a valued mineral for terrorist groups. The response to conflict with terrorist groups cannot be solely military. The State must necessarily get the various state services to work together, particularly the army, the police, and customs. The institutionalization of this cooperation remains a real challenge for these states. Regarding customs administration efficiency, data analysis is at the core of customs modernization programs. Only internal and external trade data have been used in risk management systems. Cooperation with the armed forces must allow the acquisition of tools and skills to analyze other data sources, such as satellite data. Customs could then carry out all of its missions at the borders: collecting duties and taxes but also protecting the local/border economy and cutting off the funding sources for terrorist groups.

Clermont-Ferrand, France Centre d’Études et de Recherches sur le Développement International, 2022. 27p.

Juan Diego Cárdenas - Javier Lizcano Villalba - Lara Susana Loaiza - Laura Alonso , etc.

There were always going to be dissident elements from the FARC, from those who were unconvinced by the peace deal or simply refused to consider it. However, the ex-FARC mafia is now growing at such a rate that Colombia’s entire peace process is at risk. Almost every peace process has had combatants who refuse to give up their arms. There was no reason that the Revolutionary Armed Forces of Colombia (Fuerzas Armadas Revolucionarias de Colombia – FARC) should be any different. Looking abroad first, the Northern Ireland peace process saw the Provisional Irish Republican Army (PIRA, more commonly known as the IRA) reach the “Good Friday Agreement” with the British government in April 1998. It did not take long for the “Continuity IRA” and the “Real IRA,” which has now morphed into the “New IRA,” to appear. But while a series of bombs have been set off and some isolated killings have taken place, Irish dissident groups have been unable to win any significant support or rebuild the military capacity of the PIRA. …

Washington, DC: Insight Crime, 2019. 72p.

European Parliament

In July 2021, the European Commission tabled a proposal to establish a new EU authority to counter money laundering and the financing of terrorism (AMLA). This was part of a legislative package aimed at implementing the 2020 action plan for a comprehensive Union policy on preventing money laundering and the financing of terrorism. The AMLA would be the centre of an integrated system composed of the authority itself and the national authorities with an AML/CFT supervisory mandate. It would also support EU financial intelligence units (FIUs) and establish a cooperation mechanism among them. The Council achieved a partial political agreement on the proposal on 29 June 2022. In the European Parliament, the file was referred to the Committee on Economic and Monetary Affairs (ECON) and the Committee on Civil Liberties, Justice and Home Affairs (LIBE). The co-rapporteurs issued their joint report in May 2022. The joint committee report was voted on 28 March 2023 and the mandate to enter trilogues was granted by the plenary on 17 April 2023. Third edition. The 'EU Legislation in Progress' briefings are updated at key stages throughout the legislative procedure. The first edition was written by Carla Stamegna.

Brussels: European Parliament, 2020. 10p.