Money laundering through money remittance ... - Council of Europe

Money Laundering through Money Remittance and Currency Exchange Providers - 2010
CHAPTER II - MONEY LAUNDERING METHODOLOGIES INVOLVING MONEY
REMITTANCE AND CURRENCY EXCHANGE PROVIDERS
58. This chapter describes some of ways in which money remittance and currency exchange
providers have been exploited for ML/TF purposes through a series of selected case studies provided
by responding jurisdictions. The focus of this material is primarily on “traditional” i.e. formal money
remittance and currency exchange providers; however, a few observations have also been included
about informal systems.
59. Generally, these MR/CE providers can be used for money laundering and terrorist financing
in two ways: either by performing relevant transactions without knowledge of the illegal origin or
destination of the funds concerned or by a direct involvement of the staff/management of the provider
through complicity or takeover of such businesses by the criminal organisation.
60. Several features of the MR/CE sectors make them an attractive vehicle through which
criminal and terrorist funds can enter the financial system, such as the simplicity and certainty of
MR/CE transactions, worldwide reach (in case of money remitters), the cash character of transactions,
low-thresholds, the often less stringent customer identification rules that apply to such transactions
compared with opening bank account and reduced possibilities for verification of the customer‟s
identification than in credit or other financial institutions , etc. The nature of the customer‟s
relationship with the MR/CE service provider and the brevity of contacts is also a significant
vulnerability.
61. Money remittance providers are used at all stages of the money laundering process. Currency
exchanges specifically are an important link in the money laundering chain, particularly during the
placement stage. Once the money has been exchanged, it is difficult to trace its origin. Also, it has
been noted that considering that they are small businesses, currency exchanges can be easily prone to
takeover by criminals and used to launder money.
62. From responses received to the survey questionnaire for this project, the most important
factors that may indicate possible misuse of MR/CE service providers:
Use of underground remittance systems;
Use of mules / straw accounts;
Mismatch between the economic activity, country of origin, or person and the money
remittances received;
Periodic transfers made by several people to the same beneficiary or related persons;
Transfers over a short period of time of low amounts that together represent a large sum
of money;
Transfers from one or more senders in different countries to a local beneficiary.
Sudden inflow of funds in cash followed by sudden outflow through financial instruments
such as drafts and cheques;
Structuring of transactions and/or changing of MR/CE provider for subsequent orders to
keep a low profile; and
False information during the identification procedure/lack of co-operation.
© 2011 MONEYVAL and FATF/OECD - 21