Money Launderer
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Money laundering is the process of illegally concealing the origin of
money Money is any item or verifiable record that is generally accepted as payment for goods and services and repayment of debts, such as taxes, in a particular country or socio-economic context. The primary functions which distinguish money are: m ...
obtained from illicit activities (often known as dirty money) such as
drug trafficking A drug is any chemical substance other than a nutrient or an essential dietary ingredient, which, when administered to a living organism, produces a biological effect. Consumption of drugs can be via inhalation, injection, smoking, ingestion, ...
,
sex work Sex work is "the exchange of sexual services, performances, or products for material compensation. It includes activities of direct physical contact between buyers and sellers as well as indirect sexual stimulation". Sex work only refers to volun ...
,
terrorism Terrorism, in its broadest sense, is the use of violence against non-combatants to achieve political or ideological aims. The term is used in this regard primarily to refer to intentional violence during peacetime or in the context of war aga ...
,
corruption Corruption is a form of dishonesty or a criminal offense that is undertaken by a person or an organization that is entrusted in a position of authority to acquire illicit benefits or abuse power for one's gain. Corruption may involve activities ...
, and
embezzlement Embezzlement (from Anglo-Norman, from Old French ''besillier'' ("to torment, etc."), of unknown origin) is a type of financial crime, usually involving theft of money from a business or employer. It often involves a trusted individual taking ...
, and converting the funds into a seemingly legitimate source, usually through a
front organization A front organization is any entity set up by and controlled by another organization, such as intelligence agencies, organized crime groups, terrorist organizations, secret societies, banned organizations, religious or political groups, advocacy ...
. Money laundering is illegal; the acts generating the money almost always are themselves
criminal In ordinary language, a crime is an unlawful act punishable by a State (polity), state or other authority. The term ''crime'' does not, in modern criminal law, have any simple and universally accepted definition,Farmer, Lindsay: "Crime, definiti ...
in some way (for if not, the money would not need to be laundered). As
financial crime Financial crime is crime committed against property, involving the unlawful conversion of the ownership of property (belonging to one person) to one's own personal use and benefit. Financial crimes may involve fraud (cheque fraud, credit card f ...
has become more complex and
financial intelligence Financial intelligence (FININT) is the gathering of information about the financial affairs of entities of interest, to understand their nature and capabilities, and predict their intentions. Generally the term applies in the context of law enfo ...
is more important in combating international crime and terrorism, money laundering has become a prominent
political Politics () is the set of activities that are associated with decision-making, making decisions in social group, groups, or other forms of power (social and political), power relations among individuals, such as the distribution of Social sta ...
,
economic An economy is an area of the Production (economics), production, Distribution (economics), distribution and trade, as well as Consumption (economics), consumption of Goods (economics), goods and Service (economics), services. In general, it is ...
, and
legal debate A legal debate is a discussion between lawyers, legal academics, jurists, politicians, and others who might have interest or expertise in the law, about a particular legal issue. Legal debates can take many forms, and do not necessarily need to ...
. Most countries implement some anti-money-laundering measures. In the past, the term "money laundering" was applied only to
financial transaction A financial transaction is an Contract, agreement, or communication, between a buyer and seller to exchange goods, Service (economics), services, or assets for payment. Any transaction involves a change in the status of the finances of two or mo ...
s related to
organized crime Organized crime is a category of transnational organized crime, transnational, national, or local group of centralized enterprises run to engage in illegal activity, most commonly for profit. While organized crime is generally thought of as a f ...
. Today its definition is often expanded by government and international regulators such as the US
Office of the Comptroller of the Currency The Office of the Comptroller of the Currency (OCC) is an independent bureau within the United States Department of the Treasury that was established by the National Currency Act of 1863 and serves to corporate charter, charter, bank regulation ...
to mean "any financial transaction which generates an
asset In financial accounting, an asset is any resource owned or controlled by a business or an economic entity. It is anything (tangible or intangible) that can be used to produce positive economic value. Assets represent value of ownership that can b ...
or a value as the result of an illegal act," which may involve actions such as
tax evasion Tax evasion or tax fraud is an illegal attempt to defeat the imposition of taxes by individuals, corporations, trusts, and others. Tax evasion often entails the deliberate misrepresentation of the taxpayer's affairs to the tax authorities to red ...
or
false accounting False accounting is a legal term for a type of fraud, considered a statutory offence in England and Wales, Northern Ireland and the Republic of Ireland. England and Wales This offence is created by section 17 of the Theft Act 1968 which provides: ...
. In the UK, it does not need to involve money, but any
economic good In economics, goods are anything that is good, usually in the sense that it provides welfare or utility to someone. Alan V. Deardorff, 2006. ''Terms Of Trade: Glossary of International Economics'', World Scientific. Online version: Deardorffs' ...
. Courts involve money laundering committed by private individuals, drug dealers, businesses, corrupt officials, members of criminal organizations such as the
Mafia "Mafia", as an informal or general term, is often used to describe criminal organizations that bear a strong similarity to the Sicilian Mafia, original Mafia in Sicily, to the Italian-American Mafia, or to other Organized crime in Italy, organiz ...
, and even states. In
United States The United States of America (USA), also known as the United States (U.S.) or America, is a country primarily located in North America. It is a federal republic of 50 U.S. state, states and a federal capital district, Washington, D.C. The 48 ...
law, money laundering is the practice of engaging in financial transactions to conceal the identity, source, or destination of illegally gained money. In
United Kingdom The United Kingdom of Great Britain and Northern Ireland, commonly known as the United Kingdom (UK) or Britain, is a country in Northwestern Europe, off the coast of European mainland, the continental mainland. It comprises England, Scotlan ...
law, the
common law Common law (also known as judicial precedent, judge-made law, or case law) is the body of law primarily developed through judicial decisions rather than statutes. Although common law may incorporate certain statutes, it is largely based on prece ...
definition is wider. The act is defined as "the process by which the proceeds of crime are converted into assets which appear to have a legitimate origin, so that they can be retained permanently or recycled into further criminal enterprises".


History

While existing laws were used to fight money laundering during the period of
Prohibition in the United States The Prohibition era was the period from 1920 to 1933 when the United States prohibited the production, importation, transportation, and sale of alcoholic beverages. The alcohol industry was curtailed by a succession of state legislatures, an ...
during the 1930s, dedicated Anti-Money Laundering legislation was only implemented in the 1980s.
Organized crime Organized crime is a category of transnational organized crime, transnational, national, or local group of centralized enterprises run to engage in illegal activity, most commonly for profit. While organized crime is generally thought of as a f ...
received a major boost from Prohibition and a large source of new funds that were obtained from illegal sales of alcohol. The successful prosecution of
Al Capone Alphonse Gabriel Capone ( ; ; January 17, 1899 – January 25, 1947), sometimes known by the nickname "Scarface", was an American organized crime, gangster and businessman who attained notoriety during the Prohibition era as the co-foun ...
on
tax evasion Tax evasion or tax fraud is an illegal attempt to defeat the imposition of taxes by individuals, corporations, trusts, and others. Tax evasion often entails the deliberate misrepresentation of the taxpayer's affairs to the tax authorities to red ...
brought in a new emphasis by the state and law enforcement agencies to track and confiscate money, but existing laws against tax evasion could not be used once gangsters started paying their taxes. In the 1980s, the war on drugs led governments again to turn to money laundering rules in an attempt to track and seize the proceeds of drug crimes in order to catch the organizers and individuals running drug empires. It also had the benefit, from a law enforcement point of view, of turning rules of evidence "upside down". Law enforcers normally have to prove an individual is guilty to seize their property, but with civil forfeiture laws, money can be confiscated and it is up to the individual to prove that the source of funds is legitimate to get the money back. This makes it much easier for law enforcement agencies and provides for much lower burdens of proof. However, this process has been abused by some law enforcement agencies to take and keep money without strong evidence of related criminal activity, to be used to supplement their own budgets. Civil asset forfeiture has been harshly criticized by
civil liberties Civil liberties are guarantees and freedoms that governments commit not to abridge, either by constitution, legislation, or judicial interpretation, without due process. Though the scope of the term differs between countries, civil liberties of ...
advocates for its greatly reduced standards for conviction,
reverse onus Reverse or reversing may refer to: Arts and media *Reverse (Eldritch album), ''Reverse'' (Eldritch album), 2001 *Reverse (2009 film), ''Reverse'' (2009 film), a Polish comedy-drama film *Reverse (2019 film), ''Reverse'' (2019 film), an Iranian cr ...
, financial conflicts of interests arising when the law enforcement agencies who decide whether or not to seize assets stand to keep those assets for themselves, and violation of
separation of powers The separation of powers principle functionally differentiates several types of state (polity), state power (usually Legislature#Legislation, law-making, adjudication, and Executive (government)#Function, execution) and requires these operat ...
and
due process Due process of law is application by the state of all legal rules and principles pertaining to a case so all legal rights that are owed to a person are respected. Due process balances the power of law of the land and protects the individual p ...
. The
11 September attacks The September 11 attacks, also known as 9/11, were four coordinated Islamist terrorist suicide attacks by al-Qaeda against the United States in 2001. Nineteen terrorists hijacked four commercial airliners, crashing the first two into ...
in 2001, which led to the Patriot Act in the U.S. and similar legislation worldwide, led to a new emphasis on money laundering laws to combat
terrorism financing Terrorism financing is the provision of funds or providing financial support to individual terrorists or non-state actors. Most countries have implemented measures to counter terrorism financing (CTF) often as part of their money laundering law ...
. The
Group of Seven (G7) The Group of Seven (G7) is an intergovernmental political and economic forum consisting of Canada, France, Germany, Italy, Japan, the United Kingdom and the United States; additionally, the European Union (EU) is a "non-enumerated member". I ...
nations used the
Financial Action Task Force on Money Laundering The Financial Action Task Force (FATF), also known by its French name, Groupe d'action financière (GAFI), is an intergovernmental organisation founded in 1989 on the initiative of the G7 to develop policies to combat money laundering and to m ...
to put pressure on governments around the world to increase surveillance and monitoring of financial transactions and share this information between countries. Starting in 2002, governments around the world upgraded money laundering laws and surveillance and monitoring systems of financial transactions. Anti-money laundering regulations have become a much larger burden for
financial institution A financial institution, sometimes called a banking institution, is a business entity that provides service as an intermediary for different types of financial monetary transactions. Broadly speaking, there are three major types of financial ins ...
s and enforcement has stepped up significantly. During 2011–2015 a number of major banks faced ever-increasing fines for breaches of money laundering regulations. This included
HSBC HSBC Holdings plc ( zh, t_hk=滙豐; initialism from its founding member The Hongkong and Shanghai Banking Corporation) is a British universal bank and financial services group headquartered in London, England, with historical and business li ...
, which was fined $1.9 billion in December 2012, and
BNP Paribas BNP Paribas (; sometimes referred to as BNPP or BNP) is a French multinational universal bank and financial services holding company headquartered in Paris. It was founded in 2000 from the merger of two of France's foremost financial instituti ...
, which was fined $8.9 billion in July 2014 by the U.S. government. Many countries introduced or strengthened border controls on the amount of cash that can be carried and introduced central transaction reporting systems where all financial institutions have to report all financial transactions electronically. For example, in 2006,
Australia Australia, officially the Commonwealth of Australia, is a country comprising mainland Australia, the mainland of the Australia (continent), Australian continent, the island of Tasmania and list of islands of Australia, numerous smaller isl ...
set up the AUSTRAC system and required the reporting of all financial transactions. With the surge in digital asset in the late 2010s, there's been a noticeable rise in money laundering and fraud tied to cryptocurrency. In 2021 alone, cybercriminals managed to secure US$14 billion in cryptocurrency through various illicit activities. Chinese organized criminal groups have become the principal money launderers for
drug cartel A drug cartel is a criminal organization composed of independent drug lords who collude with each other in order to improve their profits and dominate the illegal drug trade. Drug cartels form with the purpose of controlling the supply of the i ...
s in Mexico, Italy, and elsewhere. The East and Southeast Asia regions have become areas of major concern for money laundering. The
United Nations Office on Drugs and Crime The United Nations Office on Drugs and Crime (UNODC; French language, French: ''Office des Nations unies contre la drogue et le crime'') is a United Nations office that was established in 1997 as the Office for Drug Control and Crime Prevention ...
noted in a 2019 transnational organised crime assessment that threats arising from organized crime in Southeast Asia were becoming more deeply integrated within the region itself, as well as with neighbouring and connected regions. As the region's illicit economies expanded and evolved, including the growth of the synthetic drug industry, casinos and economic zones in the region's border areas became important hubs for money laundering. Sites such as the
Golden Triangle Special Economic Zone The Golden Triangle Special Economic Zone (, , abbreviated GTSEZ) is located along the Mekong River in the Ton Pheung District of Bokeo Province in Laos. The zone has an area of about 3,000 hectares and was created in 2007 by the Politics of ...
in Laos have been identified as hotspots for money laundering and various other types of transnational crime. Other high risk sectors for money laundering include commercial banks, securities companies, currency exchange shops, money transfer service providers, insurance companies, real estate agencies, and the trade in valuable materials such as art, antiquities and wildlife products. As these industries have grown, the presence and sophistication of money laundering operations has too, creating a backdoor for organized crime to launder illicit funds into the global financial system. Casino junkets operating from Macao emerged as a major facilitator of money laundering, as has the more recently established online gambling industry. The rise of the cyber-enabled fraud industry across Southeast Asia, especially in Cambodia, Myanmar, Laos, and the Philippines, has given rise to new platforms providing guarantees and facilitating the laundering of funds through app-based channels. One such case is that of Huione, a Cambodia-based operation that blockchain analysis firms have identified as one of the leading actors in this space. Blockchain analytics firm Elliptic described Huione as the "largest illicit online marketplace to have ever operated". Global law enforcement has begun to respond to the threats posed by such platforms, and in May 2025 the U.S. Department of the Treasury's
Financial Crimes Enforcement Network The Financial Crimes Enforcement Network (FinCEN) is a bureau within the United States Department of the Treasury that collects and analyzes information about financial transactions to combat domestic and international money laundering, terrori ...
(FinCEN) issued a finding and notice of proposed rulemaking (NPRM) pursuant to Section 311 of the USA PATRIOT Act that identified Huione Group as a financial institution of primary money laundering concern, seeking to sever its access to the U.S. financial system.


Features


Definition

Money laundering is the conversion or transfer of property; the concealment or disguising of the nature of the proceeds; the acquisition, possession or use of property, knowing that these are derived from criminal acts; the participating in or assisting the movement of funds to make the proceeds appear legitimate. Money obtained from certain crimes, such as
extortion Extortion is the practice of obtaining benefit (e.g., money or goods) through coercion. In most jurisdictions it is likely to constitute a criminal offence. Robbery is the simplest and most common form of extortion, although making unfounded ...
,
insider trading Insider trading is the trading of a public company's stock or other securities (such as bonds or stock options) based on material, nonpublic information about the company. In various countries, some kinds of trading based on insider informati ...
,
drug trafficking A drug is any chemical substance other than a nutrient or an essential dietary ingredient, which, when administered to a living organism, produces a biological effect. Consumption of drugs can be via inhalation, injection, smoking, ingestion, ...
,
human trafficking Human trafficking is the act of recruiting, transporting, transferring, harboring, or receiving individuals through force, fraud, or coercion for the purpose of exploitation. This exploitation may include forced labor, sexual slavery, or oth ...
, and
illegal gambling Gambling law is the set of rules and regulations that apply to the gaming or gambling industry. Gaming law is not a branch of law in the traditional sense but rather is a collection of several areas of law that include criminal law, regulatory law ...
is "dirty" and needs to be "cleaned" to appear to have been derived from legal activities, so that banks and other financial institutions will deal with it without suspicion. Money can be laundered by many methods that vary in complexity and sophistication. Money laundering typically involves three steps: The first involves introducing cash into the financial system by some means ("placement"); the second involves carrying out complex financial transactions to camouflage the illegal source of the cash ("layering"); and finally, acquiring wealth generated from the transactions of the illicit funds ("integration"). Some of these steps may be omitted, depending on the circumstances. For example, non-cash proceeds that are already in the financial system would not need to be placed. According to the
United States Treasury Department The Department of the Treasury (USDT) is the national treasury and finance department of the federal government of the United States. It is one of 15 current U.S. government departments. The department oversees the Bureau of Engraving and ...
:


Methods


List of methods

Money laundering can take several forms, although most methodologies can be categorized into one of a few types. These include "bank methods, smurfing lso known as structuring currency exchanges, and double-invoicing". Lawrence M. Salinger, ''Encyclopedia of white-collar & corporate crime: A – I, Volume 1'', page 78, , 2005. *
Structuring Structuring, also known as smurfing in banking jargon, is the practice of executing financial transactions such as making bank deposits in a specific pattern, calculated to avoid triggering financial institutions to file reports required by law ...
: Often known as ''smurfing'', is a method of placement whereby cash is broken into smaller deposits of money, used to defeat suspicion of money laundering and to avoid anti-money laundering reporting requirements. A sub-component of this is to use smaller amounts of cash to purchase bearer instruments, such as money orders, and then ultimately deposit those, again in small amounts. * Bulk cash smuggling: This involves physically smuggling cash to another jurisdiction and depositing it in a financial institution, such as an
offshore bank An offshore bank is a bank that is operated and regulated under international banking license (often called offshore license), which usually prohibits the bank from establishing any business activities in the jurisdiction of establishment. Due to ...
, that offers greater
bank secrecy Banking secrecy, alternatively known as financial privacy, banking discretion, or bank safety,Guex (2000), p. 240 is a Non-disclosure agreement, conditional agreement between a bank and its clients that all foregoing activities remain secure, Con ...
or less rigorous money laundering enforcement. * Cash-intensive businesses: In this method, a business that is typically expected to receive a large proportion of its revenue as cash uses its accounts to deposit criminally derived cash. This method of money laundering often causes organized crime and
corporate crime In criminology, corporate crime refers to crimes committed either by a corporation (i.e., a business entity having a separate legal personality from the natural persons that manage its activities), or by individuals acting on behalf of a corpor ...
to overlap. Such enterprises often operate openly and in doing so generate cash revenue from incidental legitimate business in addition to the illicit cash. In such cases, the business will usually claim all cash received as legitimate earnings. Service businesses are best suited to this method, as such enterprises have little or no
variable cost Variable costs are costs that change as the quantity of the good or service that a business produces changes.Garrison, Noreen, Brewer. Ch 2 - Managerial Accounting and Costs Concepts, pp 48 Variable costs are the sum of marginal costs over all u ...
s and/or a large ratio between revenue and variable costs, which makes it difficult to detect discrepancies between revenues and costs. Examples are parking structures,
strip club A strip club (also known as a strip joint, striptease bar, peeler bar, gentlemen's club, among others) is a venue where strippers provide adult entertainment, predominantly in the form of striptease and other erotic dances including lap dances. St ...
s, tanning salons,
car wash A car wash, or auto wash, is a facility used to clean the exterior, and in some cases the interior, of motor vehicle, cars. Car washes can be #Self-serve car wash, self-service, full-service (with attendants who wash the vehicle), or #Autom ...
es,
arcade Arcade most often refers to: * Arcade game, a coin-operated video, pinball, electro-mechanical, redemption, etc., game ** Arcade video game, a coin-operated video game ** Arcade cabinet, housing which holds an arcade video game's hardware ** Arcad ...
s,
bar Bar or BAR may refer to: Food and drink * Bar (establishment), selling alcoholic beverages * Candy bar ** Chocolate bar * Protein bar Science and technology * Bar (river morphology), a deposit of sediment * Bar (tropical cyclone), a laye ...
s,
restaurants A restaurant is an establishment that prepares and serves food and drinks to customers. Meals are generally served and eaten on the premises, but many restaurants also offer take-out and food delivery services. Restaurants vary greatly in app ...
,
casino A casino is a facility for gambling. Casinos are often built near or combined with hotels, resorts, restaurants, retail shops, cruise ships, and other tourist attractions. Some casinos also host live entertainment, such as stand-up comedy, conce ...
s,
barber shops A barber is a person whose occupation is mainly to cut, dress, groom, style and shave hair or beards. A barber's place of work is known as a barbershop or the barber's. Barbershops have been noted places of social interaction and public discourse ...
, DVD stores,
movie theaters A movie theater (American English) or cinema (Commonwealth English), also known as a movie house, cinema hall, picture house, picture theater, the movies, the pictures, or simply theater, is a business that contains auditoriums for viewing fi ...
, and
beach resort A seaside resort is a city, town, village, or hotel that serves as a vacation resort and is located on a coast. Sometimes the concept includes an aspect of an official accreditation based on the satisfaction of certain requirements such as in t ...
s. * Trade-based laundering: This method is one of the newest and most complex forms of money laundering. This involves under- or over-valuing
invoice An invoice, bill, tab, or bill of costs is a commercial document that includes an itemized list of goods or services furnished by a seller to a buyer relating to a sale transaction, that usually specifies the price and terms of sale, quanti ...
s to disguise the movement of money. For example, the art market has been accused of being an ideal vehicle for money laundering due to several unique aspects of art such as the subjective value of artworks as well as the secrecy of auction houses about the identity of the buyer and seller. According to the
National Crime Agency The National Crime Agency (NCA) is a Law enforcement agency#natlea, national law enforcement agency in the United Kingdom. It is the UK's lead agency against organised crime; Human trafficking, human, Arms trafficking, weapon and Illegal drug t ...
, one strategy that is favored by high-net-worth individuals is specialist storage facilities. Art kept in these spaces has been used by individuals to evade sanctions and launder the proceeds of crime. *
Shell companies A shell corporation is a company or corporation with no significant assets or operations often formed to obtain financing before beginning business. Shell companies were primarily vehicles for lawfully hiding the identity of their beneficial ...
and trusts: Trusts and shell companies disguise the true owners of money. Trusts and corporate vehicles, depending on the jurisdiction, need not disclose their true owner. Sometimes referred to by the slang term ''rathole'', though that term usually refers to a person acting as the fictitious owner rather than the business entity. * Round-tripping: Here, money is deposited in a controlled foreign corporation offshore, preferably in a
tax haven A tax haven is a term, often used pejoratively, to describe a place with very low tax rates for Domicile (law), non-domiciled investors, even if the official rates may be higher. In some older definitions, a tax haven also offers Bank secrecy, ...
where minimal records are kept, and then shipped back as a
foreign direct investment A foreign direct investment (FDI) is an ownership stake in a company, made by a foreign investor, company, or government from another country. More specifically, it describes a controlling ownership an asset in one country by an entity based i ...
, exempt from taxation. A variant of this is to transfer money to a law firm or similar organization as funds on account of fees, then to cancel the retainer and, when the money is remitted, represent the sums received from the lawyers as a legacy under a will or proceeds of litigation. * Bank capture: In this case, money launderers or criminals buy a controlling interest in a bank, preferably in a jurisdiction with weak money laundering controls, and then move money through the bank without scrutiny. * Invoice Fraud: An example is when a criminal contacts a company saying that the supplier payment details have changed. They then provide alternative, fraudulent details in order for you to pay them money. *
Casino A casino is a facility for gambling. Casinos are often built near or combined with hotels, resorts, restaurants, retail shops, cruise ships, and other tourist attractions. Some casinos also host live entertainment, such as stand-up comedy, conce ...
s: In this method, an individual walks into a casino and buys chips with illicit cash. The individual will then play for a relatively short time. When the person cashes in the chips, they will expect to take payment in a check, or at least get a receipt so they can claim the proceeds as
gambling Gambling (also known as betting or gaming) is the wagering of something of Value (economics), value ("the stakes") on a Event (probability theory), random event with the intent of winning something else of value, where instances of strategy (ga ...
winnings. * Other gambling: Money is spent on gambling, preferably on high odds games. One way to minimize risk with this method is to bet on every possible outcome of some event that has many possible outcomes, so no outcome(s) have short odds, and the bettor will lose only the
vigorish Vigorish (also called the cut, the house edge, juice, the margin, the take, under-juice, or the vig) is the fee charged by a bookmaker for accepting a gambler's wager. In American English, it can also refer to the interest owed a loanshark in con ...
and will have one or more winning bets that can be shown as the source of money. The losing bets will remain hidden. * Black salaries: A company may have unregistered employees without written contracts and pay them cash salaries. Dirty money might be used to pay them. * Tax amnesties: For example, those that legalize unreported assets and cash in tax havens. * Transaction Laundering: When a merchant unknowingly processes illicit credit card transactions for another business. It is a growing problem and recognised as distinct from traditional money laundering in using the payments ecosystem to hide that the transaction even occurred (e.g. the use of fake front websites). Also known as "undisclosed aggregation" or "factoring". * Online job marketplaces such as
Freelancer.com Freelancer is an Australian freelance marketplace website, which allows potential employers to post jobs that freelancers can then bid to complete. Founded in 2009, its headquarters is located in Sydney, Australia, though it also has offices in ...
and
Fiverr Fiverr is an Israeli multinational online marketplace for freelance services. Fiverr's connects freelancers to people or businesses looking for services. Fiverr takes its name from the $5 asking price attached to all tasks when the company was ...
, which accept funds from clients and hold them in
escrow An escrow is a contractual arrangement in which a third party (the stakeholder or escrow agent) receives and disburses money or property for the primary transacting parties, with the disbursement dependent on conditions agreed to by the transact ...
to pay freelancers. A money launderer can post a token job on one of these sites, and send the money for the site to hold in escrow. The launderer (or his associate) can then sign on as a freelancer (using a different account and IP address), accept and complete the job, and be paid the funds. * Through Sports: Investigation teams have identified sport profits as a common way to launder money. In Latin America, in particular, drug traffickers are frequently found to own Soccer Clubs, and to launder money through their intermediate, by buying and selling players, selling tickets and merchandise.


Digital electronic money

In theory,
electronic money Digital currency (digital money, electronic money or electronic currency) is any currency, money, or money-like asset that is primarily managed, stored or exchanged on digital computer systems, especially over the internet. Types of digital cu ...
should provide as easy a method of transferring value without revealing identity as untracked banknotes, especially wire transfers involving anonymity-protecting numbered bank accounts. In practice, however, the record-keeping capabilities of Internet service providers and other network resource maintainers tend to frustrate that intention. While some
cryptocurrencies A cryptocurrency (colloquially crypto) is a digital currency designed to work through a computer network that is not reliant on any central authority, such as a government or bank, to uphold or maintain it. Individual coin ownership records ...
under recent development have aimed to provide more possibilities of transaction anonymity for various reasons, the degree to which they succeed — and, in consequence, the degree to which they offer benefits for money laundering efforts — is controversial. Solutions such as
ZCash Zcash is a privacy-focused cryptocurrency based on Bitcoin's codebase. It shares many similarities, such as a fixed total supply of 21 million units. Transactions can be transparent, similar to bitcoin transactions, or they can be shielded t ...
and
Monero Monero (; Abbreviation: XMR) is a cryptocurrency which uses a blockchain with privacy-enhancing technologies to obfuscate transactions to achieve anonymity and fungibility. Observers cannot decipher addresses trading Monero, transaction amount ...
― known as ''privacy coins'' ― are examples of cryptocurrencies that provide unlinkable anonymity via proofs and/or obfuscation of information (
ring signature In cryptography, a ring signature is a type of digital signature that can be performed by any member of a set of users that each have keys. Therefore, a message signed with a ring signature is endorsed by someone in a particular set of people. ...
s). While not suitable for large-scale crimes, privacy coins like Monero are suitable for laundering money made through small-scale crimes. Apart from traditional cryptocurrencies,
Non-Fungible Token A non-fungible token (NFT) is a unique digital identifier that is recorded on a blockchain and is used to certify ownership and authenticity. It cannot be copied, substituted, or subdivided. The ownership of an NFT is recorded in the blockchai ...
s (NFTs) are also commonly used in connection with money laundering activities. NFTs are often used to perform Wash Trading by creating several different
wallets A wallet is a flat case or pouch, often used to carry small personal items such as physical currency, debit cards, and credit cards; identification documents such as driving licence, identification card, club card; photographs, transit pas ...
for one individual, generating several fictitious sales and consequently selling the respective NFT to a third party. According to a report by
Chainalysis Chainalysis is an American blockchain analysis firm headquartered in New York City. The company was co-founded by Michael Gronager, Jan Møller and Jonathan Levin in 2014, and is the first start-up company dedicated to the business of Bitcoin tr ...
, these types of wash trades are becoming increasingly popular among money launderers especially due to the largely anonymous nature of transactions on NFT marketplaces. Auction platforms for NFT sales may face regulatory pressure to comply with anti-money laundering legislation. Additionally, cryptocurrency mixers have been increasingly used by cybercriminals over the past decade to launder funds. A mixer blends the cryptocurrencies of many users together to obfuscate the origins and owners of funds, enabling a greater degree of privacy on public blockchains like
Bitcoin Bitcoin (abbreviation: BTC; Currency symbol, sign: ₿) is the first Decentralized application, decentralized cryptocurrency. Based on a free-market ideology, bitcoin was invented in 2008 when an unknown entity published a white paper under ...
and
Ethereum Ethereum is a decentralized blockchain with smart contract functionality. Ether (abbreviation: ETH) is the native cryptocurrency of the platform. Among cryptocurrencies, ether is second only to bitcoin in market capitalization. It is open-s ...
. Although not explicitly illegal in many jurisdictions, the legality of mixers is controversial. The use of the mixer
Tornado Cash Tornado Cash (also stylized as TornadoCash) is an open source, non-custodial, fully decentralized cryptocurrency tumbler that runs on Ethereum Virtual Machine-compatible networks. It offers a service that mixes potentially identifiable or "tain ...
in the laundering of funds by the Lazarus Group led the Office of Foreign Assets Control to sanction it, prompting some users to sue the Treasury Department. Proponents have argued mixers allow users to protect their privacy and that the government lacks the authority to restrict access to decentralized software. In the United States, Financial Crimes Enforcement Network, FinCEN requires mixers to register as money service businesses. In 2013, Jean-Loup Richet, a research fellow at ESSEC ISIS, surveyed new techniques that cybercriminals were using in a report written for the
United Nations Office on Drugs and Crime The United Nations Office on Drugs and Crime (UNODC; French language, French: ''Office des Nations unies contre la drogue et le crime'') is a United Nations office that was established in 1997 as the Office for Drug Control and Crime Prevention ...
. A common approach was to use a digital currency exchanger service which converted dollars into a digital currency called Liberty Reserve, and could be sent and received anonymously. The receiver could convert the Liberty Reserve currency back into cash for a small fee. In May 2013, the US authorities shut down Liberty Reserve, charging its founder and various others with money laundering. Another increasingly common way of laundering money is to use online gaming. In a growing number of online games, such as ''Second Life'' and ''World of Warcraft,'' it is possible to gold farming, convert money into virtual goods, services, or virtual cash that can later be converted back into money. To avoid the usage of decentralized digital money such as
Bitcoin Bitcoin (abbreviation: BTC; Currency symbol, sign: ₿) is the first Decentralized application, decentralized cryptocurrency. Based on a free-market ideology, bitcoin was invented in 2008 when an unknown entity published a white paper under ...
for the profit of crime and corruption, Australia is planning to strengthen the nation's anti-money laundering laws. The characteristics of Bitcoin—it is completely deterministic, protocol-based and can be difficult to censor—make it possible to circumvent national laws using services like Tor (network), Tor to obfuscate transaction origins. Bitcoin relies completely on cryptography, not on a central entity running under a Know your customer, KYC framework. There are several cases in which criminals have cashed out a significant amount of
Bitcoin Bitcoin (abbreviation: BTC; Currency symbol, sign: ₿) is the first Decentralized application, decentralized cryptocurrency. Based on a free-market ideology, bitcoin was invented in 2008 when an unknown entity published a white paper under ...
after ransomware attacks, drug dealings, cyber fraud and gunrunning. However, many digital currency exchanges are now operating KYC programs under threat of regulation from the jurisdictions they operate.


Reverse money laundering

Reverse money laundering is a process that disguises a legitimate source of funds that are to be used for illegal purposes. It is usually perpetrated for the purpose of financing terrorism but can be also used by criminal organizations that have invested in legal businesses and would like to withdraw legitimate funds from official circulation. Unaccounted cash received via disguising financial transactions is not included in official financial reporting and could be used to evade taxes, hand in bribes and pay "under-the-table" salaries. For example, in an affidavit filed on 24 March 2014 in United States District Court for the Northern District of California, United States District Court, Northern California, San Francisco Division, FBI special agent Emmanuel V. Pascua alleged that several people associated with the Chee Kung Tong organization, and California State Senator Leland Yee, engaged in reverse money laundering activities. The problem of such fraudulent encashment practices (''obnalichka'' in Russian) has become acute in Russia and other countries of the former Soviet Union. The Eurasian Group on Combating Money Laundering and Financing of Terrorism (EAG) reported that the Russian Federation, Ukraine, Turkey, Serbia, Kyrgyzstan, Uzbekistan, Armenia and Kazakhstan have encountered a substantial shrinkage of tax base and shifting money supply balance in favor of cash. These processes have complicated the planning and management of the economy and contributed to the growth of the shadow economy.


Magnitude

Many regulatory and governmental authorities issue estimates each year for the amount of money laundered, either worldwide or within their national economy. In 1996, a spokesperson for the IMF estimated that 2–5% of the worldwide global economy involved laundered money. The
Financial Action Task Force on Money Laundering The Financial Action Task Force (FATF), also known by its French name, Groupe d'action financière (GAFI), is an intergovernmental organisation founded in 1989 on the initiative of the G7 to develop policies to combat money laundering and to m ...
(FATF), an intergovernmental body set up to combat money laundering, stated, "Due to the illegal nature of the transactions, precise statistics are not available and it is therefore impossible to produce a definitive estimate of the amount of money that is globally laundered every year. The FATF therefore does not publish any figures in this regard." Academic commentators have likewise been unable to estimate the volume of money with any degree of assurance. Various estimates of the scale of global money laundering are sometimes repeated often enough to make some people regard them as factual—but no researcher has overcome the inherent difficulty of measuring an actively concealed practice. Regardless of the difficulty in measurement, the amount of money laundered each year is in the 1000000000 (number), billions of US dollars and poses a significant policy concern for governments. As a result, governments and international bodies have undertaken efforts to deter, prevent, and apprehend money launderers. Financial institutions have likewise undertaken efforts to prevent and detect transactions involving dirty money, both as a result of government requirements and to avoid the reputational risk involved. Issues relating to money laundering have existed as long as there have been Organized crime, large-scale criminal enterprises. Modern anti-money laundering laws have developed along with the modern War on Drugs. In more recent times anti-money laundering legislation is seen as an adjunct to the financial crime of terrorist financing in that both crimes usually involve the transmission of funds through the financial system (although money laundering relates to where the money has come ''from'', and terrorist financing relating to where the money is going ''to''). Finally, people, vessels, organisations and governments can be sanctioned due to international law-breaking, war (and of course tit-for-tat sanctions), and still want to move funds into markets where they are ''persona non grata''. Transaction laundering is a massive and growing problem. Finextra estimated that transaction laundering accounted for over $200 billion in the US in 2017 alone, with over $6 billion of these sales involving illicit goods or services, sold by nearly 335,000 unregistered merchants. Money laundering can erode democracy.


Notable cases

* Bank of Credit and Commerce International: Unknown amount, estimated in billions, of criminal proceeds, including drug trafficking money, laundered during the mid-1980s. * Bank of New York: US$7 1000000000 (number), billion of Russian capital flight laundered through accounts controlled by bank executives, the late 1990s. *
BNP Paribas BNP Paribas (; sometimes referred to as BNPP or BNP) is a French multinational universal bank and financial services holding company headquartered in Paris. It was founded in 2000 from the merger of two of France's foremost financial instituti ...
, in June 2014, pleaded guilty to falsifying business records and Conspiracy (civil), conspiracy, having violated U.S. sanctions against Cuba, Iran, and Sudan. It agreed to pay an $8.9 billion fine, the largest ever for violating U.S. sanctions. * BSI Ltd, BSI Bank, in May 2017, was shut down by the Monetary Authority of Singapore for serious breaches of anti-money laundering requirements, poor management oversight of the bank's operations, and gross misconduct of some of the bank's staff. * BTA Bank: $6 billion of bank funds embezzled or fraudulently loaned to shell companies and offshore holdings by the bank's former chairman and CEO Mukhtar Ablyazov. * Charter House Bank: Charter House Bank in Kenya was placed under statutory management in 2006 by the Central Bank of Kenya after it was discovered the bank was being used for money laundering activities by multiple accounts containing missing customer information. More than $1.5 billion had been laundered before the scam was uncovered. * Danske Bank + Swedbank: $30 billion – $230 billion US dollars Danske Bank money laundering scandal, laundered through its Estonian branch. This was revealed on 19 September 2018. Investigations by Denmark, Estonia, the U.K. and the U.S. were joined by France in February 2019. On 19 February 2019, Danske Bank announced that it would cease operating in Russia and the Baltic States. This statement came shortly after Estonia's banking regulator Finantsinspektsioon announced that they would close the Estonian branch of Danske Bank. The investigation has grown to include Swedbank, which may have laundered $4.3 billion. More at Danske Bank money laundering scandal. * Deutsche Bank was accused in a vast money laundering scheme, dubbed the Global Laundromat, involving secret Russian accounts that were transferred from European Union banks in Estonia, Latvia and Cyprus between 2010 and 2014. Newspaper sources estimated the total value of laundered currency to be as high as $80bn. The bank is also under investigation for its involvement in Europe's biggest banking scandal through Denmark's Danske Bank, which laundered €200bn, also from Russian sources. * United Arab Emirates' Dubai Islamic Bank was accused of "knowingly and purposefully" providing "financial services and other forms of material support to al-Qaeda operatives" when the terrorist group was planning the execution of the
11 September attacks The September 11 attacks, also known as 9/11, were four coordinated Islamist terrorist suicide attacks by al-Qaeda against the United States in 2001. Nineteen terrorists hijacked four commercial airliners, crashing the first two into ...
against the United States. In addition, the Sharjah branch of Standard Chartered Bank was also involved in opening the accounts of the terror operatives and allowing financial transactions to take place between them and Khalid Sheikh Mohammed, "the principal architect of the 9/11 attacks". * FinCEN Files: On 21 September 2020, The International Consortium of Investigative Journalists (ICIJ) revealed FinCEN Files, about the involvement of about $2tn of transactions by some of the world's biggest banks. FinCEN files also revealed that Dubai-based Gunes General Trading, based in Dubai funneled Iranian state money via UAE's central banking system and processed $142 million in 2011 and 2012. * Fortnite: In 2018, Cybersecurity firm Cybersixgill, Sixgill discovered that Credit card fraud, stolen credit card details may be used to purchase Fortnite's Virtual economy, in-game currency (V-Bucks) and in-game purchases, for the account to then be sold online for "clean" money. Epic Games, the makers of Fortnite, responded by urging customers to secure their accounts. *
HSBC HSBC Holdings plc ( zh, t_hk=滙豐; initialism from its founding member The Hongkong and Shanghai Banking Corporation) is a British universal bank and financial services group headquartered in London, England, with historical and business li ...
, in December 2012, paid a record $1.9 Billion fine for money-laundering hundreds of millions of dollars for drug traffickers, terrorists and sanctioned governments such as Iran. The money-laundering occurred throughout the 2000s. * Institute for the Works of Religion: Italian authorities investigated suspected money laundering transactions amounting to US$218 million made by the Institute for the Works of Religion, IOR to several Italian banks. * Liberty Reserve, in May 2013, was seized by United States federal authorities for laundering $6 billion. * Nauru: US$70 billion of Russian capital flight was laundered through unregulated Nauru offshore shell banks, the late 1990s * Sani Abacha: US$2–5 billion of government assets laundered through banks in the UK, Luxembourg, Jersey (Channel Islands), and Switzerland, by the president of Nigeria. * Standard Bank: Standard Bank South Africa London Branch – The Financial Conduct Authority (FCA) has fined Standard Bank PLC (Standard Bank) £7,640,400 for failings relating to its anti-money laundering (AML) policies and procedures over corporate and private bank customers connected to politically exposed persons (PEPs). * Standard Chartered: paid $330 million in fines for money-laundering hundreds of billions of dollars for Iran. The money-laundering took place in the 2000s and occurred for "nearly a decade to hide 60,000 transactions worth $250 billion". * Westpac: On 24 September 2020, Westpac and AUSTRAC agreed to an AUD $1.3 billion penalty over Westpac's breaches of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 - the largest fine ever issued in Australian corporate history.


Individuals

* Jose Franklin Jurado-Rodriguez, a Harvard College and Columbia University Graduate School of Arts and Sciences Economics Department alumnus, was convicted in Luxembourg in June 1990 "in what was one of the largest drug money laundering cases ever brought in Europe" and the US in 1996 of money laundering for the Cali Cartel kingpin Jose Santacruz Londono. Jurado-Rodriguez specialized in "Smurfing (financial crime), smurfing". * Ng Lap Seng: The Chinese billionaire real estate developer from Macau was sentenced to four years in prison in May 2018 for bribing two diplomats, including the former president of the United Nations General Assembly, John William Ashe, to help him build a conference center in Macau for the United Nations Office for South-South Cooperation (UNOSSC), headed by Director Yiping Zhou. The corruption case was the worst financial scandal for the United Nations since the abuse of the Iraqi Oil-for-Food Programme, oil-for-food program more than 20 years ago. Ng Lap Seng, 69, was convicted in Federal District Court in Manhattan on two counts of violating the Foreign Corrupt Practices Act, one count of paying bribes, one count of money laundering, and two counts of conspiracy. * Ferdinand Marcos: Unknown amount, estimated at US$10 billion of government assets laundered through banks and financial institutions in the United States, Liechtenstein, Austria, Panama, Netherlands Antilles, Cayman Islands, Vanuatu, Hong Kong, Singapore, Monaco, the Bahamas, the Vatican and Switzerland.


Prevention


Laws by country

*
United Kingdom The United Kingdom of Great Britain and Northern Ireland, commonly known as the United Kingdom (UK) or Britain, is a country in Northwestern Europe, off the coast of European mainland, the continental mainland. It comprises England, Scotlan ...
: Implemented the Proceeds of Crime Act (POCA) to establish money laundering offenses and facilitate asset recovery. *
United States The United States of America (USA), also known as the United States (U.S.) or America, is a country primarily located in North America. It is a federal republic of 50 U.S. state, states and a federal capital district, Washington, D.C. The 48 ...
: Enacted the Corporate Transparency Act (CTA) requiring companies to disclose their beneficial owners to the Financial Crimes Enforcement Network (FinCEN), effectively banning anonymous shell corporations and enhancing transparency in corporate ownership. *
Australia Australia, officially the Commonwealth of Australia, is a country comprising mainland Australia, the mainland of the Australia (continent), Australian continent, the island of Tasmania and list of islands of Australia, numerous smaller isl ...
: Introduced the Anti-Money Laundering and Counter-Terrorism Financing Act (AML/CTF Act) to regulate financial transactions and enhance transparency. *Singapore: Established the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act to confiscate proceeds from serious crimes. *Switzerland: Strengthened its anti-money laundering framework through the Swiss Anti-Money Laundering Act (AMLA), which mandates due diligence and reporting requirements for financial institutions.


Statistics

Below table shows the annual reported money laundering cases per 100,000 population for individual countries for the last available year according to the
United Nations Office on Drugs and Crime The United Nations Office on Drugs and Crime (UNODC; French language, French: ''Office des Nations unies contre la drogue et le crime'') is a United Nations office that was established in 1997 as the Office for Drug Control and Crime Prevention ...
. Proportion of unreported money laundering and definition of money laundering might differ between countries.


See also

* Anti-Money Laundering Act (Switzerland) * Anti–money laundering framework for financial institutions in France * Azerbaijani laundromat * Bank Secrecy Act * Danske Bank money laundering scandal * Financial Action Task Force * Gold laundering * Operation Greenback * Sven Stumbauer * Proxy criminal networks


References


External links

*
UNODC on money-laundering and countering the financing of terrorism
: profile from the
United Nations Office on Drugs and Crime The United Nations Office on Drugs and Crime (UNODC; French language, French: ''Office des Nations unies contre la drogue et le crime'') is a United Nations office that was established in 1997 as the Office for Drug Control and Crime Prevention ...

Financial Market Integrity Unit
of the World Bank
International Narcotics Control Strategy Report
(INCSR), annual report issued by the United States Department of State in March every year (prepared by Bureau of International Narcotics and Law Enforcement Affairs) on country money laundering risk {{Authority control Money laundering, Commercial crimes Financial regulation Tax evasion Cover-ups Organized crime Funding of terrorism