Money Laundering

The taking of criminal proceeds and disguising their illegal sources in order to use the funds to perform legal or illegal acts.

Electronically moving funds from one country to another;
Moving funds from one financial institution to another; and
Converting the cash placed into the system into monetary instruments.

Purchasing luxury assets like property, artwork, jewelry or high-end automobiles; and investing in business enterprises.

Commingling illegitimate funds with legitimate ones;
making foreign exchange transactions with illegal funds; and
depositing small amounts of cash into various accounts.

Reminds prosecutors that criminal and civil investigations into corporate misconduct should also focus on individuals who perpetrated the wrongdoing.
Issued by then-Deputy Attorney General Sally Yates of the Department of Justice

Funds transfers to or from a financial secrecy haven;
large, incoming fund transfers from a foreign client with little or no explanation or apparent reason;
and fund transfers that have no apparent link to legitimate business.

A product offered by banks that allows customers to scan a check and transmit an electronic image to the bank for deposit.

The risk associated with it is that it enables a money launderer to deposit checks without having to visit the bank and risk detection.

PTAs with foreign institutions licensed in offshore centers with each bank supervision;
PTAs where the respondent bank (the foreign bank) fails to conduct adequate customer due diligence; and
PTAs where the sub-account holders have currency deposit and withdrawal privileges.

The primary money laundering risk pertaining to the use of concentration accounts is the fact that the customer-identifying information may not be included, making the audit trail difficult or impossible to follow.

A PEP is a “politically exposed person,” meaning a person who has or has had a prominent government or quasi-public position
in a country.

The primary risk in dealing with a PEP is that the source of funds from a PEP may be from corruption.

Structuring involves taking a large cash deposit and breaking it into smaller amounts to be deposited into separate banks, separate accounts or on separate days in order to avoid currency transaction reports.

Credit cards are not likely to be used in the initial placement of money laundering. They are more likely to be used in the layering or integration stages of money laundering.

One example of using credit cards for money laundering purposes is overpaying a credit card balance and then asking for a refund. Receiving a check from the reputable credit card company makes it look like the funds received are legitimate.

Multiple financial institution relationships whereby the TPPP’s suspicious activity cannot be seen in its entirety by one institution;
engaging in ACH transactions from overseas whereby the suspicious transactions get hidden by the large number of other transactions the TPPP engages in; and
the possibility of the return rates stemming from unauthorized transactions are higher than average.

Cashing checks without obtaining adequate proof of identity;
failing to file Currency Transaction Reports when required;
and transmitting funds overseas without sufficient due diligence.

Its international nature;
the speed of their transactions;
the ease of converting holdings into cash without significant loss of principal;
the large volume of wires used;
the competitive, commission-driven environment;
the practice of maintaining securities accounts in the name of nominees or trusts; and
weak AML programs.

Paying off gambling debts in cash just under the reporting requirements;
purchasing chips, but engaging in minimal gambling and then cashing the chips back in;
using the gambling house for banking-like financial services, including wiring funds overseas;
betting on both “red” and “black” spaces in roulette; and
purchasing chips with cash just under the reporting requirements.

The fact that gold is an extremely attractive vehicle for laundering money due to the fact that it is relatively compact and easy to transport; and
the fact that the gold market is a target for criminal activity because it is lucrative and holds its value regardless of the form it takes.

Purchasing an expensive airline ticket and then asking for a refund;
paying for travel tours with multiple wires just under the reporting threshold; and
creating false bookings through tour operator networks to justify significant payments from foreign travel groups.

Creating and managing corporate vehicles or other complex legal arrangements;
buying or selling property as a cover for transfers of illegal funds;
performing financial transactions, including making deposits, withdrawing funds, engaging in foreign exchange operations, buying or selling stock and sending international wires; and
setting up or managing a charity.

The primary concern with regard to the use of gatekeepers is the fact that they can be used to enhance secrecy and to keep hidden the beneficial owner of an account or transaction.

It can be purchased with cash;
the ultimate beneficial owner can be disguised;
it is a relatively stable and reliable investment; and t
he value can be increased through renovations and improvements.