Money laundering through money remittance ... - Council of Europe
Money laundering through money remittance ... - Council of Europe
Money laundering through money remittance ... - Council of Europe
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2010 - <strong>Money</strong> Laundering <strong>through</strong> <strong>Money</strong> Remittance and Currency Exchange Providers<br />
withdrawals. Some “runners” had during a period <strong>of</strong> months made withdrawals for millions. The <strong>money</strong><br />
was used for paying to black labour. STRs were received from banks indicating <strong>money</strong> flows from<br />
different companies‟ bank accounts to the bank account <strong>of</strong> the currency exchange-company. The<br />
owner <strong>of</strong> the currency exchange company was later prosecuted and convicted.<br />
Source: Sweden.<br />
Example 3 – Criminal group obtaining ownership over sub-agents <strong>of</strong> <strong>money</strong> remitters and exchange<br />
<strong>of</strong>fices<br />
Several Bulgarian citizens and companies where the citizens were beneficial owners were involved in<br />
large ML scheme. The companies received transfers to their bank accounts in different Bulgarian<br />
banks and transferred the <strong>money</strong> to foreign company A. The ultimate beneficiary <strong>of</strong> all <strong>money</strong><br />
transfers was company B, one <strong>of</strong> the Bulgarian companies.<br />
The investigation carried out by FIU detected that a group <strong>of</strong> Bulgarians bought up sub-agents <strong>of</strong> MR<br />
and CE. After a change in ownership, the total number <strong>of</strong> transfers received multiplied and a great<br />
number <strong>of</strong> transfers in small sums were ordered by foreign citizens. Beneficiaries <strong>of</strong> those transfers<br />
were typically Bulgarian citizens and the company B. It was also found out that the ultimate<br />
beneficiary <strong>of</strong> the transactions received by the individuals was company B.<br />
It is suspected that the funds originated from drug trafficking. The scheme was <strong>of</strong> a significant scale,<br />
involving dozens <strong>of</strong> natural and legal persons from Bulgaria and foreign countries. The amount <strong>of</strong><br />
funds transferred <strong>through</strong> MR system was several millions <strong>of</strong> Euros.<br />
Source: Bulgaria.<br />
Example 4 - In October 2008, 5 persons pleaded guilty to one count <strong>of</strong> operating an illegal <strong>money</strong><br />
remitting business in the US. According to documents filed with the court and statements made in<br />
court, persons operated different enterprises. From December 2005 to March 2008, the defendants<br />
managed illegal and unlicensed <strong>money</strong> transmitting businesses in Connecticut. In exchange for<br />
remitting a total <strong>of</strong> more than USD 22 million from Connecticut to Brazil and for guaranteeing the<br />
anonymity <strong>of</strong> both their customer and their customer‟s intended beneficiary, the defendants took a<br />
percentage <strong>of</strong> the remitted funds for their own financial gain. Several other persons have been<br />
pleaded guilty in committing the crimes similar to this, the destination <strong>of</strong> the transfers have been to<br />
Middle East countries.<br />
Source: United States.<br />
Example 5 - Use <strong>of</strong> agents <strong>of</strong> <strong>money</strong> <strong>remittance</strong> business<br />
A suspicious transaction report from a <strong>money</strong> <strong>remittance</strong> business was received in the FIU. The report<br />
revealed that one <strong>of</strong> the agents <strong>of</strong> the <strong>money</strong> <strong>remittance</strong> company was making operations with the<br />
following characteristics:<br />
- Every <strong>remittance</strong> operation was sent to country B (Country B was a drug producing<br />
country).<br />
- The amount sent in every <strong>remittance</strong> operation was higher than usual for <strong>money</strong><br />
<strong>remittance</strong> operations to country B.<br />
- In the period <strong>of</strong> time <strong>of</strong> one year, the senders <strong>of</strong> <strong>money</strong> never made more than three<br />
operations.<br />
- Every sender sent <strong>money</strong> to different receivers.<br />
- There were no apparent relationship between the sender and the receiver <strong>of</strong> the <strong>money</strong>.<br />
- The receivers never received <strong>money</strong> from more than three or four senders.<br />
After making a more comprehensive analysis, other agents <strong>of</strong> different <strong>money</strong> <strong>remittance</strong> companies<br />
with similar operational pr<strong>of</strong>ile were discovered.<br />
Police investigations revealed that those agents were working together in a joint action with the<br />
objective to launder <strong>money</strong> for a drug trafficking organisation. <strong>Money</strong> <strong>laundering</strong> and drug trafficking<br />
organisations were dismantled. The information was shared with country B, where several police<br />
operations were carried out.<br />
Source: Spain.<br />
28 - © 2010 MONEYVAL and FATF/OECD