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If there is something emergency services are good at it is making life or death decisions in the heat of battle. The below model is used by the British police. At least some of it is. We have expanded on it’s utility to cause cognisance of the factors that play into points 1 to 5.

CYW Decision making model

What is important is the ease with which people can grasp this. It’s about providing staff with a model that everyone knows to make decisions throughout the firm, at all levels.

At the command level the strategy/mission/Objective is set and this is communicated to the whole organisation. That’s the centre green circle.

From that, at any level, and at any urgency, the model is followed from 1 through 5. This is where the police model finishes. We have added the additional requirements to help people assess and consider information.

  1. Where did the information come from and how reliable is it?
  2. Do we know it to be true without reservation or just suspect it is true?
  3. What further information do we need to make a decision?
  4. We consider information using the PESTEL model
    • What political impact does this have?
    • How does it effect the environment?
    • What sociological impact does it have?
    • Any technical requirements/needs?
    • How does it impact the economy (or our revenue)?
    • What legal aspects do we need to consider?
  5. Out of the information we have or require, what is essential and what implied information do we need or have that supports this? Is it contingent on success?
  6. From the previous, build a plan. Have two contingencies based on the information we do not know or do not know to be 100% true. If those things have misled us, the two contingencies will be ready to then go through this cycle again, using the updated information.
  7. Put the plan into action and maintain a review cycle, constantly spinning the circle and re-assessing as you go.

Any question you have then feel free to direct them to us via our contact page.

How to Technologically Enhance Money Laundering – to make it harder to trace illicit cash.

Technology enhanced money laundering

We’ve noticed that despite our target audience being the financial compliance industry, when we post with a heading to attract criminal attention, it gets read more!

So welcome to this post. In it we will discuss the steps that criminals take to use technology to hide their assets.

Firstly, a basic understanding of Placement, Layering and Integration are needed, you can find that here if you do not understand these three steps.

In the main, technology aids steps two and three. It helps criminals to layer their asset with repeated levels of trade of one sort or another. It then helps them to ‘cash out’ in the integration stage.

We do not make a distinction between a money launderer (professional) or a criminal (commits the predicate offence) other than simply. Similarly, with something like 150 definitions of an organised criminal or their enterprise, this post sets out to use the terms colloquially, inasmuch as any one of the three can act in any capacity so it’s fair to call them all criminals.

Europol define organised crime, not on a personal level as to state the activity of a single individual, but as to the commodities, groups and hubs that make up an OCG (Organised Criminal Gang). In the UK, the definition (loosely termed) relates to activity of a group rather than an individual or specific crime type. It more relates to criminals acting as groups at level two and above (above ‘street’ level crime and cross regional/international).

Money laundering is characterised as a secondary offence to the predicate offence that generated the illicit funds. It is a dynamic and flexible process with launderers actively adapting to fluctuating situational conditions. It is these dynamics that make it difficult to define, describe and prosecute. The levels of convictions are pitifully low globally and this is one area FATF are starting to push with the move to ‘Outcome’ based mutual evaluations at the national level.

As in our post describing the links between Nations that are high on the Corruption index and Bitcoin pricing, the links between laundering and regions that have lax controls and high levels of corruption are sought out by organised criminal groups to layer their transactions to conceal the real origin of the revenue. A research paper into Money Laundering has described it as the third largest industry globally, only oil and agriculture generate more revenue, this indicates just how professional the ‘sector’ is and the sometimes insurmountable odds the industry, regulators and prosecutors face.

Indeed it is these odds, and a nascent belief that the financial sector is inextricably and on occasion corruptly linked to OCGs that is forcing the political agenda to get tougher with sanctions and fines for firms that transgress and get caught. Certainly there are more huge fines than there are ‘bellies against the charge desk’ as I used to say in a former career.

I am going to deliberately steer away from the more obvious routes to launder money. This site covers the more obvious routes in other posts (search for money laundering in our search box and posts will come up). Instead I hope to show you more nuanced methods that a ‘professional’ launderer would use and hopefully point to ways for firms to identify those efforts.

It is obvious that the nearer the point to the actual criminal predicate offence, the more risk there is to laundering cash. The further the cash is layered, actually or digitally, the harder it is for an investigator to track the asset backwards. This is especially true of asset that moves across borders. It is also evident that the regulated sector, spends most of its time trying to detect this first placement into the system. Defeat the placement stage and the professional launderer has the odds stacked in his favour.

The key to laundering is therefore, the successful first step. To conceal it the launderer needs a Trojan horse. Digital transactions and cryptography along with ‘straw-men’ hide the identity of the original criminal. Again, in nations that have a large populous of poor communities, people are prepared to have their identity used as a placement vehicle; this influences the regional choices of OCGs. There are also cases showing more ‘middle class’ white collar workers prepared to lend their identities to support business transactions involving laundering transactions further into the layering process – this includes allowing legitimate business be used to clean money. It is these reasons that money laundering causes capital flight from an economy, investors fearful of the instability and risk attached to the market.

The Trojan Horse


A simple use of technology, a photocopier. Used in high value sales around the globe to prove the outlet checked the identity of the person purchasing- especially when paying in cash. It is a simple task to obscure the image of a passport, make it too dark or otherwise unidentifiable to help the launderer evade any future scrutiny. Purchasing gold, jewels and other high value goods.

Intelligent Deposit Machines

These machines were used to great effect in Australia where a gang used them to launder tens of millions of AUD. Enabling placement and movement of cash through the machines even when the banks were closed. The gang used a network of the machines at lower than threshold amounts to avoid suspicion.

e-commerce and mobile payments

OCGs setting up online storefronts that trade in transactions and not goods to help the launder layer his transactions in what appear genuine stores. No goods are actually moved. This problem is set to get worse as more fintechs operate in this space with a ‘less than conservative approach’ to regulations. One that shall remain unnamed even switched off its transaction monitoring for several months because it was alerting too much (!!)

Virtual World

An International internet payment provider was suspected of laundering on an industrial scale. Implicated were digital currency exchanges, precious metal dealers and more. The OCG had effectively infiltrated the entire system to move large sums in apparent legitimate trade.

Online Betting

An OCG used online betting and internet payment system to launder the proceeds of narcotic dealings. The gang used the two services to receive transactions and then move the funds offshore. In an investigation, it was found that two of the enterprises had the same registered physical address (our intelligence system would flag this as the transaction processed – even across institutional business lines). The gang transferred revenue acting as a remittance service and this disguised the origin of the transaction when the bank conducted the transactions. The gang also used the accounts to simply store funds, making passwords widely known so multiple members could draw on the accounts.

Sales Registers and CCTV

A nightclub had CCTV all over its premise except in the VIP lounge for ‘privacy reasons’. That lounge was then used to till up huge sums of cash transactions as ‘revellers’ purchased $800 champagne in huge quantities. Not so elaborate but an easy way to place cash into the legitimate system through bogus purchases of high value goods/services.

An old colleague of mine filmed a car wash over aperiod of several months to prove vehicles were indeed never washed there, helping to secure the conviction for the predicate offence and ML.

Elaborate ways to facilitate the first stage of money laundering are constantly evolving. As we have stated this is the most risky part of laundering. Not only because it’s the first and easy to trace back to the predicate offence, but also because policy focuses compliance agent attention on this first stage through transaction monitoring and identity checks.

Placement of the cash is the most risky stage of laundering

It is also likely the algorithms being adopted through machine learning technology are focusing on this ‘thick edge’ of transactions. At the front of the process. The more involved and professional launderer will adopt moving and flexible processes to move the money many times over, using no set pattern and through many jurisdictions, transaction types and institutes. This way, unless the whole financial sector had one Ai system, the individual systems in each firm will fail to spot the patterns of transactions/behaviour.

Other technologies are also being used by OCGs. From encrypted communications to virtual services and products and the darknet facilitating on a huge scale the market-place for many OCGs and their gang members.

It is safe to say that criminal gangs have business processes very similar to legitimate businesses. They use highly skilled financiers and skilled business people to move money and assets around as we have discussed previously in our post about cyber crime and money laundering.

This post only details a few examples of ‘how’ criminals use technology. It explains ‘why’ they use it. There is a much bigger study currently ongoing to identify the methods regulators, policy-makers and the industry can use to identify how to combat the professional OCG by understanding their methods. Unfortunately, my experience in these matters tends to lean me towards the opinion that this will be mostly wasted effort. The reason I say this is because;

  1. OCGs will know the models adopted before they are launched – they will almost certainly have informed people on the inside.
  2. The policy-setters will take far too long through bureaucratic channels to put something live.
  3. OCGs will adapt and change and this requires not a look to the past but an accurate prediction of the future to enable swift machine learning from new sets of learning data.

Here at CYW we are developing a networked system that will, for the first time, link the institutes intelligence together. With over 300 metrics to monitor from outside the sector, we will merge data and intelligence to pass it at the speed of transactions to enhance red flags and reduce false positives.

This is essentially providing public level enforcement typologies to the private sector to provide more effective and efficient means to stop transactions and put the onus on the criminal to prove it is innocent. It is our view this is the only way the industry can proceed to force change, cause reductions in criminal use of the financial system and increase the amount of seizures being made. stand alone transaction modelling, even with machine learning functionality, will be hampered by the lack of full data as money moves outside their dataset and comes back in again through different entitites/routes. The firm would have no way of tracking it outside of their own institute.

If you think this post is worthy of a like or a share we would really appreciate you taking the time to do so. We need more readers to influence the agenda.

Thank you.

60 Best Money Laundering Research Papers, Books and web links.


Research into money laundering goes deeper than reading ACAMS or Linkedin. Here we have provided links to the 60 Best Money Laundering Research Papers, books and web articles.

In the coming weeks we will be blogging about these articles and what they mean to the industry. Stay tuned and register with the site (bottom of the page) if you want to get our posts via your inbox (sent once a month only – no spam!)

We would really appreciate you sharing this resource if you find it useful – it took a long time to research!! Thank you. Simply use one of the sharing links or copy the web address and post about it.

NB: Scroll left and right for small screen views

Title & LinkAuthor & Link to BibliographyDescription
(scroll to left to read)
Money launderingM Levi, P Reuter – Crime and Justice, 2006 – journals.uchicago.eduTechniques for hiding proceeds of crime include transporting cash out of the country, purchasing businesses through which funds can be channeled, buying easily transportable valuables, transfer pricing, and using “underground banks.” Since the mid-1980s …
 Dirty money: The evolution of money laundering counter-measuresWC Gilmore – 1999 – ncjrs.govThe first chapter provides an overview of the problem, as it notes that estimates of money from criminal activities range from 300 to 500 billion US dollars annually, money that is available for laundering. Such quantities of money, often linked with organized crime …
How big is global money laundering?J Walker – Journal of Money Laundering Control, 1999 – emerald.comKnown incidents of money laundering involving large amounts of money generated from crime are of tremendous public interest and are consequently given wide publicity. A wide range of national and international agencies have attempted to quantify organised crime …
 Macroeconomic implications of money launderingPJ Quirk – Washington, Fondo Monetario Internacional, WP, 1996 – elibrary.imf.orgThis paper reviews the main analytical, empirical, and policy issues related to the macroeconomic implications of money laundering. The paper discusses, first, how money laundering can be measured, given that it is unobservable, and reports cross-section …
 Chasing dirty money: The fight against money launderingP Reuter – 2005 – books.google.comOriginally developed to reduce drug trafficking, efforts to combat money foundering have broadened over the years to address other crimes and, most recently, terrorism. In this study,[the authors] look at the scale and characteristics of money laundering, describe and …
 Money laundering: a new international law enforcement modelG Stessens – 2000 – books.google.comThis book gives a broad analysis of the legal issues raised by the international fight against money laundering. It offers an extensive comparative research of the criminal and preventive law aspects from an international perspective. Stessens portrays money laundering as a …
Money laundering: muddying the macroeconomyPJ Quirk – Finance and Development, 1997 – search.proquest.comIMF staff went to a small island country to assess economic developments. As they walked around the capital, they noticed a surprisingly large number of small banks (more than 100 in a country of less than 100,000 people). A year later, it was revealed that many of these …
Money laundering and its regulationM Levi – The Annals of the American Academy of Political …, 2002 – journals.sagepub.comThis article examines definitions of” money laundering” and the conceptual and actual role its regulation plays in dealing with drug markets. If laundering is prevented, incentives to become major criminals are diminished. It identifies and critiques three aspects of harm …
Money laundering: the economics of regulationD Masciandaro – European Journal of Law and Economics, 1999 – SpringerEconomic research has not yet systematically undertaken the analysis of the existing interactions between criminal economy and financial markets. The present work belongs to a research field increasingly interested in such issues and focuses on the economic analysis of money laundering …
Money laundering: some factsF Schneider, U Windischbauer – European Journal of Law and Economics, 2008 – SpringerThis paper tackles the quite difficult topic of money laundering. After defining money laundering, and after explaining the three stages (steps), placement, layering and integration, the paper tries a quantification and estimation of the volume and development of …
Money laundering and the international financial systemV Tanzi – 1996 – ideas.repec.orgThe IMF Working Papers series is designed to make IMF staff research available to a wide audience. Almost 300 Working Papers are released each year, covering a wide range of theoretical and analytical topics, including balance of payments, monetary and fiscal issues …
Measuring Global Money Laundering:” The Walker Gravity Model”J Walker, B Unger – Review of Law & Economics, 2009 – degruyter.comMeasuring global money laundering, the proceeds of transnational crime that are pumped through the financial system worldwide, is still in its infancy. Methods such as case studies, proxy variables, or models for measuring the shadow economy all tend to under-or …
Money laundering—a global obstacleB Buchanan – Research in International Business and Finance, 2004 – ElsevierOne of the biggest obstacles to maintaining an effective operating international financial system is money laundering. A global phenomenon and international challenge, money laundering is a financial crime that often involves a complex series of transactions and …
An inquiry into money laundering tools in the Bitcoin ecosystemM Möser, R Böhme, D Breuker – 2013 APWG eCrime …, 2013 – ieeexplore.ieee.orgWe provide a first systematic account of opportunities and limitations of anti-money laundering (AML) in Bitcoin, a decentralized cryptographic currency proliferating on the Internet. Our starting point is the observation that Bitcoin attracts criminal activity as many …
 Black finance: the economics of money launderingD Masciandaro, E Takats, B Unger – 2007 – books.google.com” The recent dramatic wave of terrorist attacks has further focussed worldwide attention on the money laundering phenomena. The objective of this book is to offer the first systematic analysis of the economics of money laundering and its connection with terrorism finance …
 Critical reflections on transnational organized crime, money laundering and corruptionME Beare – 2003 – books.google.comTransnational crime, organized crime, money laundering and corruption are four concepts that have gained and continue to gain an international and domestic profile. Is the information given to the public concerning these concepts distorted by the vested interests of …
 The amounts and the effects of money launderingB Unger, M Siegel, J Ferwerda, W de Kruijf… – Report for the Ministry of …, 2006 – ftm.nl0.4. The amount of money laundered is sizeable 0.5. Where is the criminal money being laundered and placed? 0.6. The Netherlands are a transit country of crime and criminal money 0.7. What are the effects of money laundering? 0.8. The long term dangers of money  …
The consequences of money laundering and financial crimeJ McDowell, G Novis – Economic Perspectives, 2001 – ncjrs.govMoney laundering is seen as critical to the effective operation of transnational and organized crime. However, money laundering effects a country’s economy, government, and social well-being. This article briefly reviewed both the economic and social costs of money laundering …
 Money laundering: A guide for criminal investigatorsJ Madinger – 2011 – books.google.comMany changes have occurred in the twenty-five years that have passed since the enactment of the Money Laundering Control Act of 1986. The law has been amended, new underlying crimes have been added, and court decisions have modified its scope. The Act remains an …
 The hawala alternative remittance system and its role in money launderingPM Jost, HS Sandhu – 2000 – peacepalacelibrary.nlThe components of hawala that distinguish it from other remittance systems are trust and the extensive use of connections such as family relationships or regional affiliations. Unlike traditional banking or even the’chop’system, hawala makes minimal (often no) use of any …
The fight against money launderingH Geiger, O Wuensch – Journal of Money Laundering Control, 2007 – emerald.comPurpose–To provide an economic view on the costs and benefits of anti‐money laundering (AML) efforts. Design/methodology/approach–Based on a international, comparative study conducted in Switzerland, Singapore and Germany, the authors outline the impact of AML …
Bitcoin and money laundering: mining for an effective solutionD Bryans – Ind. LJ, 2014 – HeinOnlineTechnology forges ahead at a rapid pace, whether we like it or not. Criminals recognize this inevitability and use technological improvements to advance their craft,’committing crimes from half a world away in real time. Meticulous criminals also use technological …
Corruption and money laundering: a symbiotic relationshipD Chaikin, J Sharman – 2009 – Springer
 Financial havens, banking secrecy and money-launderingJA Blum, M Levi, RT Naylor, P Williams – 1998 – amnet.co.ilThe major money laundering cases coming to light in recent years share a common feature: criminal organizations are making wide use of the opportunities offered by financial havens and offshore centres to launder criminal assets, thereby creating roadblocks to criminal …
A typological study on money launderingP He – Journal of Money Laundering Control, 2010 – emerald.comPurpose–The purpose of this paper is to make objective descriptions on various money‐laundering techniques and to put forward countermeasures in order to combat money laundering more effectively and efficiently. Design/methodology/approach–This paper …
 Reference guide to anti-money laundering and combating the financing of terrorismPA Schott – 2006 – elibrary.worldbank.orgThis second edition of the Reference Guide is a comprehensive source of practical information on how countries can fight money laundering and terrorist financing. Aimed at helping countries understand the new international standards, it discusses the problems …
 Money laundering policyPC Van Duyne – Fears and Facts, 2003 – petrusvanduyne.nlIt is difficult to argue about the nature of smells. Some of them do not even have names. But one kind of smell has certainly been nominated and changed in our appreciation: the ‘moral smell’of money. Today the adage ‘money does not smell’does not apply any more. Now we …
Responding to Money LaunderingE Savona – 2005 – books.google.comResponding to Money Laundering has its origin in the International Conference on Preventing and Controlling Money Laundering and the Use of Proceeds of Crime: A Global Approach organised by ISPAC, the International Scientific and Advisory Board of the United …
 Dirty money: the evolution of international measures to counter money laundering and the financing of terrorismWC Gilmore – 2004 – books.google.comThis is the third edition of this publication which explores key issues in the fast evolving field of money laundering and terrorist financing, and which has been restructured so as to fully reflect the high international priority given to tackling the financing of terrorism since …
Money laundering and globalizationP Alldridge – Journal of law and society, 2008 – Wiley Online LibraryThe article traces the various imperatives generated by the combination of the money laundering panic of the late 1990s with the advent of globalization. If there is to be an attempt legally to regulate laundering, it (laundering) must be a relatively serious offence …
Money launderingN Morris-Cotterill – Foreign Policy, 2001 – JSTORFrom Moscow to Buenos Aires, money laundering scandals sap economies and destabilize governments. Policymakers blame crime cartels, tax havens, and new techniques like cyberlaundering. But dirty money long predates such influences. Without unified rules …
The economics of crime and money laundering: does anti-money laundering policy reduce crime?J Ferwerda – Review of Law & Economics, 2009 – degruyter.comAnti-money laundering policy has become a major issue in the Western world, especially in the United States after 9-11. Basically, all countries in the world are more or less forced to cooperate in the global fight against money laundering. In this paper, the criminalization of …
 Dirty dealing: the untold truth about global money laundering, international crime and terrorismP Lilley – 2003 – books.google.comPraise and ReviewsEntertaining, well written and well presented.JOHN MULQUEEN, The Irish TimesPaints an alarming picture of the power and scale of todays crooked and corrupt financial world. Lilley has done his homework.THE IODS DIRECTOR MAGAZINESChoice of …
System and method for analyzing and dispositioning money laundering suspicious activity alertsBJ Kloostra, C Dalvi, BN Behm – US Patent App. 12/258,784, 2009 – Google PatentsA system and method for analyzing, dispositioning, recording, reviewing, and managing potentially suspicious financial transactions. In some cases, the system models the steps taken by a subject matter expert to reach a conclusion so that a novice can follow similar …
A theory of “Crying Wolf”: The economics of money laundering enforcementE Takáts – The Journal of Law, Economics, & Organization, 2011 – academic.oup.comThe article shows how excessive reporting, called “crying wolf”, can dilute the information value of reports and how more reports can mean less information. Excessive reporting is investigated by undertaking the first formal analysis of money laundering enforcement …
Power and discourse in policy diffusion: Anti-money laundering in developing statesJC Sharman – International Studies Quarterly, 2008 – academic.oup.comTwenty years ago not a single country had a policy against money laundering; currently, over 170 have very similar anti-money laundering (AML) policies in place. Why have so many countries with so little in common adopted the same policy so rapidly? This extensive …
 Global financial crime: terrorism, money laundering and offshore centresD Masciandaro – 2017 – books.google.comThe scope for financial crime has widened with the expansion and increased integration of financial markets. Money laundering, terrorism financing and tax crime have all changed in both nature and dimension. As new technologies reduce the importance of physical …
AI fights money launderingJ Kingdon – IEEE Intelligent Systems, 2004 – ieeexplore.ieee.orgThe bank had approached Searchspace, formed by re- searchers from the Intelligent Systems Lab at University College London in 1993. It applies adaptive and learning- systems approaches to a range of business and finance tasks. However, until then, we had principally developed …
 Transnational criminal organizations, cybercrime, and money laundering: a handbook for law enforcement officers, auditors, and financial investigatorsJR Richards – 1998 – books.google.comWRITTEN BY A LAW ENFORCEMENT PROFESSIONAL FOR OTHER LAW ENFORCEMENT PERSONNEL IN THE TRENCHES This book examines the workings of organized criminals and criminal groups that transcend national boundaries. Discussions …
Trade-based money laundering and terrorist financingJS Zdanowicz – Review of law & economics, 2009 – degruyter.comMoney laundering can be defined, generally, as the process of concealing the existence, illegal source, or application of income derived from a criminal activity, and the subsequent disguising of the source of that income to make it appear legitimate. Deception is the heart of …
The tenuous relationship between the fight against money laundering and the disruption of criminal financeMF Cuéllar – J. Crim. L. & Criminology, 2002 – HeinOnlineThis article examines the fight against money laundering as a case study of the separation between an enforcement system’s objectives and performance. To launder money is to hide its illegal origin. The fight against money laundering is supposed to disrupt laundering in its …
 Detecting money laundering and terrorist financing via data miningJS Zdanowicz – Communications of the ACM, 2004 – dl.acm.orgThe use of international trade to move money, undetected, from one country to another is one of the oldest techniques used to circumvent government scrutiny. Either overvaluing imports or undervaluing exports can achieve this transfer. If an imported prod- uct is overvalued, the foreign …
Money laundering regulation: the micro economicsD Masciandaro – Journal of Money Laundering Control, 1998 – emerald.comThe analysis of the interactions between the criminal economy and the financial markets has not yet been systematically studied by the economists. This study belongs to a current research interested in this area, ie the economic analysis of money laundering. The work is …
Money laundering: The crime of the’90sGR Strafer – Am. Crim. L. Rev., 1989 – HeinOnlineIn the Money Laundering Control Act of 1986,’codified at sections 1956 and 1957 of Title 18 of the United States Code, Congress for the first time attempted to define and prohibit a category of activity known colloquially as” money laundering.” During an election year frenzy …
Applying data mining in investigating money laundering crimesZ Zhang, JJ Salerno, PS Yu – Proceedings of the ninth ACM SIGKDD …, 2003 – dl.acm.orgIn this paper, we study the problem of applying data mining to facilitate the investigation of money laundering crimes (MLCs). We have identified a new paradigm of problems—that of automatic community generation based on uni-party data, the data in which there is no direct …
Turnover of organized crime and money laundering: some preliminary empirical findingsF Schneider – Public choice, 2010 – SpringerAfter a short literature review, the paper quantifies the turnover of organized crime with the help of a MIMIC estimation procedure for the years 1995 to 2006 for 20 highly developed OECD countries. The volume of turnover from organized crime was US-270billionintheyear1995forthese20OECDc …
Money laundering: an international challengeLA Barbot – Tul. J. Int’l & Comp. L., 1995 – HeinOnlineIn the words of South American drug barons,” dirty money is best passed through clean hands.” 1 Money laundering is often defined as” the process by which one conceals the existence, illegal source or illegal application of income, and then disguises that income to …
Money laundering and its regulationA Chong, F Lopez‐De‐Silanes – Economics & Politics, 2015 – Wiley Online LibraryThe recent wave of terrorist attacks has increased the attention to money laundering activities, and the role played by the regulatory frameworks controlling feeder activities. We investigate empirically the determinants of money laundering and its regulation in close to …
 Money laundering: a concise guide for all businessD Hopton – 2009 – books.google.comWorldwide, anti-money laundering regulations and legislation have become one of the weapons of choice of governments that are fighting global terrorism and criminality. In this updated edition of Money Laundering, Doug Hopton explains how The Money Laundering  …
Virtual money laundering: the case of Bitcoin and the Linden dollarR Stokes – Information & Communications Technology Law, 2012 – Taylor & FrancisThis paper presents an analysis of the money laundering risks of two virtual currencies, the Linden dollar, the in-world currency of the interactive online environment Second Life, and Bitcoin, an experimental virtual currency that allows for the transfer of value through peer-to …
 Anti-Money Laundering: international law and practiceWH Muller, CH Kalin, JG Goldsworth – 2007 – books.google.comAnti-Money Laundering is the definitive reference on money laundering and practice. First an outline will be given of the general approach taken by supra-national organisations like the United Nations and the European Council. Next the approach taken by international …
 Crime, illicit markets, and money launderingP Williams – Managing global issues: Lessons learned, 2001 – carnegieendowment.orgPhil Williams organized crime is perhaps best understood as the continuation of commerce by illegal means, with transnational criminal organizations as the illicit counterparts of multinational corporations. During the 1990s, transnational organized crime—and the …
 Criminal finance: The political economy of money laundering in a comparative legal contextK Hinterseer – 2002 – books.google.comLike it or not, money launderers are major players in the world’s economy. Their strategies constrain national economic policies and undermine financial institutions. With the advent of secure transfer technologies, and with the help of modern financial theories of derivatives …
A comparative guide to anti-money launderingM Pieth, G Aiolfi – 2004 – academia.eduMoney laundering is the process by which criminals attempt to conceal the source and ownership of the proceeds of their illicit activities; if successful, the criminal maintains control and access to these funds when and where he chooses. The efforts to combat this …
 Money launderingFAT Force – Policy Brief July 1999, 1999 – bahamasb2b.comThe goal of a large number of criminal acts is to generate a profit for the individual or group that carries out the act. Money laundering is the processing of these criminal proceeds to disguise their illegal origin. This process is of critical importance, as it enables the criminal to …
Money Laundering: The Scope of the Problem and Attempts to Combat ItS Sultzer – Tenn. L. Rev., 1995 – HeinOnlineMoney laundering is the process of taking the proceeds of criminalactivity and making it appear legal. Money laundering has been called the” lifeblood” of crime because, without cleansing the profits of crime, the criminal enterprise cannot flourish. While drug money  …
Money laundering law: Forfeiture, confiscation, civil recovery, criminal laundering and taxation of the proceeds of crimeP Alldridge – 2003 – Bloomsbury Publishing
Money laundering and financial means of organized crime: some preliminary empirical findingsF Schneider – Paolo Baffi Centre Research Paper, 2008 – papers.ssrn.comAfter giving a short literature review, the paper tries a quantification of the volume of money laundering activities, with the help of a DYMIMIC estimation procedure for the years 1995 to 2006 for 20 highly developed OECD countries. The volume of laundered money was 273 …
Money‐Laundering: Estimates in FogPC Van Duyne – Journal of Financial Crime, 1994 – emerald.comThe paper examines certain problems in determining the extent of money‐laundering. The author first discusses the methodological problems inherent in assessing its volume. He then discusses two methods to estimate the extent of money‐laundering. One method is …

Conservative Firms less likely to be involved in Money Laundering

A recent study has found that firms that adopt a culture of conservative accounting are less likely to be involved in money laundering scandals.

The authors used three measurements of the concept of conservative accounting, and in all three the results were the same.

The degree of conservativism is significantly and negatively associated to the firm’s risk to money laundering

Bolgorian, M., & Mayeli, A. (2020). Accounting conservatism and money laundering risk. Accounting Research Journal, 33(2), 343-361.

The study reviewed 924 firms across a five year time-span and accounted for metrics like firm size and sector in the findings. The results open up questions that the financial compliance industry may find useful to consider.

  1. The lack of regulatory framework in offshore jurisdictions may encourage firms to be less prudent with standards.
  2. The lack of requirement to submit accounts in offshore jurisdictions may cause less routine rigour in day to day activities.
  3. Offshore regions may be more susceptible to money laundering and terrorist financing simply due to these points, as well as the more liberal use of business registrations without full due diligence.

Accounting conservatism has been shown to reduce risk in the value of a business crashing via the stock price and to favour longevity as opposed to ‘quick win’ capitalistic strategy.

It follows that the concept ‘dampens’ the temptation to over state accounts within a firm and inculcates throughout the firm a more robust approach to audit.

The questions raised by the paper relate a different reasoning to offshore money laundering from the firm side of the transaction. That is to suggest that criminals come to offshore for the perceived secrecy and confidentiality cloak, whereas the firms (Law, Accounting, Corporate Support, Accounting, Audit) operate more loosely because necessary regulatory rigour is absent. This effectively inculcates a less than conservative approach to business.

We suggest because of these two aligned concepts, regulators are more likely to find money laundering, tax evasion, bribery, fraud and other white collar crime in offshore regions because the criminals want to exploit the opportunity and the firms are less likely to turn them away. if they adopt a more relaxed approach to prudence.

Firms are advised to be cognisant of this research established metric and understand the culture in their firm to reduce the risk of wittingly or unwittingly facilitating criminality.

Contact us to review your firm’s cultural conservatism.

25 Ways the Small Compliance Consultancy Can Cut Costs.

Time is money
  1. Reduce your tax burden

Move some of your business offshore to take advantage of zero corporation tax. Does it seem difficult? It really isn’t when you know how. You could start this journey today. See how.

  1. Use a Programmable or Smart Thermostat
    Heating and air conditioning aren’t negotiable expenses. Even small changes in your facility’s ambient temperature can adversely impact your customers’ comfort and employees’ productivity, threatening your top and bottom lines. But that doesn’t mean you can’t do everything in your power to save money on air conditioning.

  1. Use Passive Energy-Saving Measures
    Complement your programmable or smart thermostat with passive energy-saving measures that reduce your climate control and lighting systems’ workloads and carbon footprints.

  1. Power Down Non-essential Lights and Equipment After Hours
    This is a painfully straightforward way to reduce your company’s electricity bill without affecting its operations. And once you and your team get in the habit of following through, it’s painfully easy too.

In a white-collar office, personal computer workstations comprise the single biggest nonessential energy suck, so make sure everyone powers theirs down before heading out. Shut off overhead and desk lights too, or leave instructions for building cleaning crews to do so when they’re done.

  1. Reduce Paper Use
    Like reducing energy and water usage, cutting down paper waste is good for your company’s bottom line and the environment. And there are myriad ways to do it, including:

Print and copy double-sided by default
Use secure electronic file exchange services.
Reuse waste paper for scratch or notes
Tighten margins and shrink fonts on printed reports

  1. Align Plan Costs With Usage
    Your company probably pays for a lot of essential services – telecommunications, cloud storage, bookkeeping, perhaps even legal support – via monthly or annual plans. At minimum, you should review these plans once per year to determine whether they’re adequate for your needs.

See how to reduce this right now.

  1. Encourage Telecommuting
    For millions of employers, telecommuting has tremendous cost-cutting potential. Unfortunately, that potential remains largely untapped, until of course COVID19 and now everyone, wherever possible is doing it. Work from home now.

According to Global Workplace Analytics, 50% of the U.S. workforce holds a “telework-compatible job” and 80% to 90% of workers want to be able to telecommute at least some of the time – but only 20% to 25% telecommute at all. Still, the trend is unmistakable: Among non-self-employed workers, the share of workers who telecommute rose 103% between 2005 and 2014.

  1. Use Space More Efficiently
    Offices have been getting more efficient for years now. According to CCIM, the average new office lease (as of late 2012) had just 185 square feet of dedicated office space per worker. That’s down more than 20% from the beginning of the century. And the trend may accelerate: In a survey cited by CCIM, U.S. executives revealed plans to shrink their footprints to less than 100 square feet of dedicated office space per worker by 2018.

Moving your business digital and having remote workers who can conference call in gives them flexibility and saves you cost. See how you can facilitate this, right now.

  1. Make Sensible Healthcare Changes
    Most employee benefits packages include some form of healthcare coverage. Salaried employees expect employers to provide for their healthcare needs, and it’s probably the right thing to do anyway. Unfortunately, it’s also getting more expensive each year.

Pro tip: If you’re thinking about adding a health savings account (HSA) look into Lively. It’s simple, transparent and you can get signed up in just five minutes.

  1. Use High-Tech Alternatives to Legacy Systems
    Look around your facility. How many legacy technologies do you see? That’s likely to depend on what your company does, as is your ability to address the problem.

In the Financial compliance industry, the drag from legacy digital systems isn’t always as clear-cut, but that doesn’t mean it’s not real. For instance, even if you still use it to send documents to old-fashioned vendors or state agencies, you can probably do away with your fax machine. Ditto for your landline phone service – a cloud-based phone system is far, far cheaper – especially if you are calling international.

See how you can benefit from this today!

  1. Buy (Gently) Used
    Nowhere in your company bylaws does it say that you must buy only shiny new equipment. So why not buy gently used items when it makes sense to do so?

Depending on what your company does, your used buys might include:

  • Office technology, such as printers and copiers
  • Personal technology, such as refurbished smartphones, tablets, and laptops
  • Vehicles, such as company cars
  • Storage equipment
  • Furniture
  1. Pay Invoices Early
    Many vendors offer small but meaningful discounts to clients that pay invoices ahead of schedule. For instance, it’s common for vendors to knock 2% off the invoice total when clients pay in full within 10 days, instead of the usual 30 days – an arrangement that’s typically represented as “2/10 net 30.”
  1. Barter or Make In-Kind Exchanges
    Thousands of years ago, the global economy (such as it was) depended on bartering. Today, most transactions use a currency backed by central banks, but that doesn’t mean non-monetary exchange is completely obsolete. The digital revolution has given rise to a committed cottage industry of barter facilitators such as Business Barter Unlimited and U-Exchange Business. There are limits to what (and how much) you can barter, but it’s worth looking into these arrangements if cash is extremely tight or you think your products or services make valuable trades.

  1. Leverage Social Media Advertising and create a networked opportunity.
    Paid social media advertising is cheap. For instance, according to Ad Espresso, the average U.S. Facebook ad’s CPM cost was $7.19 in the third quarter of 2016 – less than a third the cost of a prime-time TV ad. Social media ads are also less costly to produce – though it’s increasingly common to see slick video spots on your Facebook or Twitter feed, the most cost-effective social ads remain simple, dirt-cheap memes.

And you don’t have to pay for social media advertising at all. If you devote time and personnel to engaging your company’s fans and building your social following organically, you can reach thousands of current or prospective customers without spending a dime.

By creating a network of businesses that pool resources, you benefit from economies of scale and together your cost to market comes down.

You could do this right now. See how.

  1. Encourage Word-of-Mouth Marketing
    Organic social media conversation is but one form of word-of-mouth marketing, a cost-effective and potentially powerful form of outreach that essentially outsources part of your marketing department to your customers.

Word-of-mouth marketing comes in many different flavors: referral programs that pay existing customers to refer new customers, college brand ambassador programs that pay young people to evangelize about their employers’ products on campus, social sharing communities on Pinterest and other digital media, and online review directories, such as Yelp. Your company’s ideal word-of-mouth marketing strategy or strategies will depend on its audience’s demographic makeup, buying habits, and response to messaging and sales efforts.

  1. Disincentivize Procrastination and Encourage Effective Time Management
    Time is money. That means wasted time is wasted money. Every minute you and your team spend procrastinating is a minute that’s not being spent on value-producing work.

Procrastination can be as innocuous as stopping by a coworker’s desk for a brief, non-work-related chat, or as problematic as ducking out of the office for hours at a time to run personal errands. If chronic procrastination is a problem at your office, figure out why it’s happening and take appropriate steps to address it – for example, by breaking overwhelming tasks into chunks.

  1. Use Freelancers and Contract Labor for Non-core Work
    Freelancers and independent contractors are easier to hire and cheaper to keep employed than traditional employees, provided you have an enforceable freelance contract to set expectations and mitigate risk on both sides of the relationship. You aren’t expected to provide freelancers with health insurance benefits, pre-tax retirement accounts, family leave or paid time off, or other pricey benefits. You just need to pay them for completed work.

It’s important not to over-rely on freelancers and contractors, as they’re likely to be less loyal and may have other relationships that distract from their work for your company. But for one-off projects and ongoing, non-core activities, they can serve as the secret sauce that keeps your company’s labor costs under control.

  1. Invest in Your Employees and Long-Term Contractors
    It costs more than you think to hire an employee, especially one with in-demand skills or specialized knowledge. According to the Center for American Progress, replacing a typical employee (not executives or physicians) costs about 20% of the employee’s annual salary. Other studies suggest that this estimate is conservative. Even if you take 20% at face value, that’s a lot of money – for an employee earning $75,000 per year, you’re looking at $15,000 in recruitment and onboarding costs.

With this in mind, it makes sense to do everything in your power to retain talented employees, even if it requires you to spend a bit more on salaries and benefits. If it keeps a high-potential worker in the fold for an extra year, upping that $75,000 salary to $85,000 is a bargain.

  1. Avoid Leverage and Interest Charges Wherever Possible
    Judicious use of small business credit cards notwithstanding, debt is generally your enemy. Before embracing small business financing options that put you in hock to big banks or venture capitalists, tap your personal finances and friends-and-family networks for interest-free startup capital. Every dollar of interest that you pay is a dollar that won’t accrue to your bottom line.

Investing wisely to save costs is essential in any strategic business.

  1. Understand and Control Your Location Costs
    Not all economies are created equal. Some cities and states are wonderful places to start and grow a business. Others aren’t so nice.

Collectively, location costs play a decisive role in sorting the former from the latter. The best way to reduce high location costs is to relocate to a lower-cost region, but that’s not always practical or even possible, especially if you’re an independent professional with deep family roots in your current backyard.

If moving isn’t an option, consider operating more digitally. Much of a compliance business is online nowadays,

See how to secure the best technology for a fraction of the cost.

  1. Pool Resources With Other Small Businesses
    When it comes to buying supplies, inventory, and equipment, there’s strength in numbers. Many businesses reduce recurring costs by pooling resources with other small businesses in their trade, or with like-minded companies across wider geographies. You can literally do this today. See how.
  1. Remember That Everything Is Negotiable
    Unless it’s clearly spelled out in a binding contract, every listed price is negotiable. This is the case even if you don’t leverage a small business alliance or network such as American Express OPEN. Entrepreneurs tend to look out for each other, and simply mentioning that you own a business is often enough to get a discount.

In some cases, there’s an active quid pro quo at work – often referral or bulk discounts. For instance, when outfitting your new commercial suite or home office, ask the interior decorator if they offer discounts or bonuses for new client referrals. Likewise, if you’re buying 10 or 20 desks or laptops at once, you’ll likely qualify for a volume discount – but you have to ask.

  1. Only Buy in Bulk When It Makes Sense
    It sounds counter-intuitive to advise against buying in bulk. However, anyone who’s made the mistake of purchasing the biggest tub of peanut butter at the warehouse club, only to throw it away two years later without making so much as a dent, has firsthand experience with the pitfalls of bulk buying.

Before committing to a bulk purchase, ask yourself a simple question: Does it make sense to buy this much of one thing? If your office goes through a ton of coffee each month, buy a 50-pound bag of whole beans. On the other hand, if you’ve dramatically cut your paper usage in recent years, maybe it doesn’t make sense to buy hundreds of reams at a time to get a slightly better per-unit rate – especially if you don’t have a ready place to store it all. Everything in moderation.

  1. Evaluate Employee Perks and Fringe Benefits on the Merits
    In many industries, notably software, competition for talent is fierce. On top of juicy (and often unwise) equity packages and generous time-off allowances, many tech employers offer fabulous perks and fringe benefits in a constant arms race to attract ultra-qualified engineers and designers.

With a requirement to go digital with your work and conduct more and more tasks online, it makes sense to have back up if you don’t employ IT talent.

See how you can secure this for free.

  1. Shop Around for Essential Services
    Most business service providers operate in competitive industries. Use that to your advantage by shopping around for essential services – or simply threatening to shop around at the right time.

Many insurance companies offer hefty discounts or bonuses to customers who make the leap from competitors. Ditto for credit unions and banks, which use the promise of free bank accounts and bank account promotions to drive new business. Cutting out that $10 to $15 monthly maintenance fee, and then bagging $200 to $300 in free money simply for opening a new account, sounds like a pretty good deal.

Final Word
Every business is different. For example, you can’t limit travel expenses if your duties don’t require you to travel, and you can’t downsize your office space if you’re working out of a home office.

Still, it’s virtually certain that your business ledgers contain at least some financial fat to trim. Even if you think you’ve plucked all the low-hanging fruit, it may be worth your while to take another look. It won’t cost you anything and it could produce a significant payoff in time.

The Case For a Networked Franchise Model in the Compliance Industry.

Financial industry franchise

In all industries operating globally, there are head and tail winds that impact the strategic moves of the incumbent businesses. The compliance industry is no different.

The financial industry as a whole has a few problems to solve.

This first chart details the rise in AI/Machine Learning provision across the FI.

47% of FI’s are currently using it in one form or another and 37% say they will be doing inside five years. This survey was taken three years ago so it is likely many of the 37% have already adopted.

Banks, in the main, are adopting this technology to reduce the huge human resource burden they have. This will include reducing external consulting as they all look to reduce costs – especially the small FI’s with assets less than $10B because they spend disproportionately more on compliance.

The FIs with assets less than $10B are the target market for small compliance consultancies, this group are more motivated than the larger FIs to reduce costs, and that means the loss of jobs. The smaller FIs, circled in red, are the bread and butter organisations of SME compliance consultancies the US over. As the larger FIs adopt machine learning technologies, they will pave the way by reducing the risk of the smaller FIs to adopt it – having done the risk related testing of the tech.


The global cost of Compliance relating to AML and CTF is $181 billion per annum.

  • APAC: $6.1B
  • EMEA: $138.8B
  • LATAM: $4.5B
  • U.S. and Canada: $31.5B

The cost is borne across every institute no matter the sector. From Banks to Insurance to Private Wealth management – no one escapes cost. It is divided into two broad areas, human resource and technology.

Within that paragraph lies the main reason a network to support the industry (and DNFP&Bs) is the route to maintain a compliance industry consultative base. The cost of human resource has exploded in compliance as the risk for not adhering to the rules has become significantly expensive economically and to reputation.

Yet the industry has ‘thrown’ human resource at the problem and that resource is not performing. The fines keep coming and the return on that investment is negative with reducing productivity, increasing costs on lines of business and reducing customer satisfactions – caused by delays.

Loss of productivity due to AML compliance…
Volume of staff directly employed by the FIs.
Customer attrition.

Customers most impacted are the most valuable to banks – the wealthy. Necessary increases in the volume of checks is causing delays to on-boarding and attrition in the sign up process. This impedes the very business of banking – moving money quickly.

By inference, it isn’t just the cost of compliance but the negative impact on the bottom line that frustrates and occupies the C-suite.

The fines keep coming and damage to reputation grows. This is because the legacy tech used within the industry isn’t good enough and human resource thrown at the problem cannot keep up with the evolving nature of crime and the speed of the issues.

But it is getting better as machine learning systems speeds up due diligence and makes it more accurate. Also reducing the false positive rates of monitoring checks.

For the small compliance consultancy this is a dangerous period. Unprecedented growth over the past ten years has seen small consultancies spring up across the globe, most notably in the US. They serve a market of risk, writing reports and completing audits of everything from process to training and beyond- but this is set to change as banks and institutes move to digital solutions making consultants redundant.

Andy Parr – Founder CYW Solutions.

The tech improves the speed of checks and makes them more effective so the banks are pursuing a strategy of IT to reduce human cost. The first to be damaged by these changes will be small consultancies.

Whether it is IT managing the screening/risk rating of customers or the online portals to train their staff, compliance is going digital.


It is mind boggling the volume of regtech start ups. The volume of investment in this sector is burgeoning at an ever greater pace and this identifies the trend to go digital.

The trend line can be seen to be increasing as wealth pours in to this sector. It is doing so because the Financial Industry is being impacted with large regulatory punishments and collectively all businesses are looking for solutions.

There is a realization that this cannot be solved with human resource. That the resolution has to be IT related. Humans simply cannot keep up with the criminals, neither can the regulators but that’s another story. The real story behind this chart should cause compliance professionals to consider;

“Where will I be and what will my job be in 5 year’s time?”

Here at CYW Solutions we predict that small to medium compliance consultancies are at the peak of the market right now. Their client base from the Financial Industry is set to tail off as the strategy moves from human to technological answer.


The political sphere of control extends beyond Nations to pseudo organisations like FATF. As the recommendations become more ‘regulatory’ in nature – moving to requiring an ‘outcome’ and not just a recommendation, it can be seen the industry and associated regulators are moving to not just require laws and policies to be implemented but actually used. An example of this can be seen in the Cayman Islands and its last mutual assessment by CFATF.

“It’s OK putting in place laws, but when no one is prosecuted it kind of makes them toothless. There is a dire need for FATF and it’s associate bodies to drive the ‘Outcome’ agenda now – forcing jurisdictions to not just implement and then leave to gather dust – but to prosecute the guilty – including those in the industry that ‘coalesce’.”

Andy Parr CYW Solutions Founder.

The tougher stance in Politics covers wider aspects of this as the EU blacklists whole jurisdictions, the US authorities keep driving prosecutions and fines for offending the Dollar and the EU makes it possible to convict for money laundering without proving a predicate offence and moves to include in evidence data stored outside of its jurisdiction.


Compliance consultants can see the market as rosy or they can recognise the headwinds and start to prepare to adapt. A simple Porter’s Five Forces analysis will show they are in a vulnerable position. They are being substituted by a new product, are much smaller than their buyer (the bank) with no option to purchase from their suppliers because they are smaller than those too.

This is a perfect strategic storm that they face. They cannot compete with a move to digital as they operate currently. They cannot ‘go digital’ because of the cost. They cannot compete with the substitute for them (the IT) because humans can’t compete.

They can diversify if they have digital consultative experience to become experts to advise on what systems to implement – but this is a short term solution and requires detailed technological knowledge.

The answer is to integrate forwards.

To merge into a global network that supports the digital transition to the financial industry, with expertise in the operation and integration of the digital solution. To actually supply the resource to the industry with human expertise in its operation.

Contact us today to secure a prospectus to join the future of compliance.

See this page for more.

Financial Crime Solutions

Financial Crime Solutions

What Financial Crime Solutions are Available?

The world of finance moves so fast with speed of light transactions how on earth can anyone counter financial crime? You’ve found the right place as we point to some detail to help you to fight financial crime and find the solution that meets your needs.

Preventing Financial Crime

We have written extensive mitigation controls to help our clients reduce the opportunity for financial crime occurring in their business. Talk to us to help you.

Improving Monitoring to Reduce Financial Crime

It’s not all about banking and transaction monitoring. The focus always goes to that. And yet the criminal knows it. Sophisticated criminals will get around transaction monitoring easily. You need to be smarter. Talk to us about how we can help you solve your issues.

Maybe the Solution is Internal?

Just take a look at the darkweb and you will see there is a volume of financial professionals working to clean dirty money and assets and selling their services to the highest bidder. We can route them out of your business. Forever.

Talk to us today to make your life less stressful – we have the financial crime solution for you.

AML-Resources U to Z

AML Resources U to Z

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Bring yourself up to date with this useful list of AML resources and help documents. We design training packages for your staff, the below is just a small section of our knowledge base. It is important to consider your requirement for bespoke training aligned to your risk.

See our training page to book some training


  • United Nations Convention Against Corruption
  • United Nations Convention Against Illicit Traffic in Narcotic Drugs and Psychotropic Substances
  • United Nations Convention for the Suppression of the Financing of Terrorism
  • United Nations Convention Against Transnational Organised Crime and the Protocols.



  • SEC Rules on Whistle-blowing
  • Wolfsberg Private Banking Principles. – The Principles were initially formulated in 2000 (and revised in 2002) to take into account certain perceived risks associated with private banking. Such risks continue to warrant appropriate levels of attention, no less today than ten years ago. Regulators continue to expect strong anti-money laundering standards, robust controls, enhanced client due diligence and suitable AML policies and procedures. The Wolfsberg Principles detail the groups considerations. –
  • Wolfsberg Guidance on Sanction Screening




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AML-Resources K to O

AML Resources K to O

A to EF to JK to OP to TU to Z

Bring yourself up to date with this useful list of AML resources and help documents. We design training packages for your staff, the below is just a small section of our knowledge base. It is important to consider your requirement for bespoke training aligned to your risk.

See our training page to book some training





  • New Zealand – Audit of AML/CTF programs and risk assessments


  • OECD – Standard for Automatic Exchange of Financial Account Information in Tax Matters
  • Organised Crime – United Nations Convention Against Transnational Organised Crime and the Protocols.-

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