Category: Money Laundering

U.S. Officials Fear Russian Money is ‘Entrenched’ in London and Warn ‘Leverage Against Putin Could be Lost’

Money Laundering
As the Western world waits with bated breath on a potential Ukraine invasion by Russian military, American officials have revealed their fears of ineffective economic sanctions against Russia. US State Department officials are believed to have expressed “dismay and frustration” at the British government’s perceived failure to tackle dirty Russian money sloshing around London. “The fear is that Russian money is so entrenched in London now that the opportunity to use it as leverage against Putin could be lost,” one US diplomatic official was reported as telling The Times. “Biden is talking about sanctioning Putin himself but that can only…

Pressure Mounts for Action Against ‘Enablers’ of Russian Regime

Money Laundering
The role of English law firms acting for powerful Russian clients has come under growing political scrutiny as the government prepares to announce long-delayed legislation against the flow of ‘dirty money’ to the UK. Writing in today’s Financial Times, Cabinet Office minister Andrew Griffith called on law firms to ‘go further, faster, wherever they can’ to ensure that sanctions bite. His comments followed claims that the government has received threatening letters from City law firms acting for clients facing sanctions following the Russian invasion of Ukraine. Foreign secretary Liz Truss briefed MPs over the weekend that law firms were holding…

Charity Urges Crackdown on £1.5bn Worth of U.K. Property Linked to Kremlin and Financial Crimes

Money Laundering
A charity has urged the British Government to fast-track measures to crack down on dirty money following the Prime Minister’s announcement of new Russia sanctions. Their remarks come after the prime minister announced sanctions on five Russian banks and three Kremlin-linked individuals earlier today. Analysis from Transparency International UK has identified at least £1.5 billion worth of UK property owned by Russians accused of financial crime or with links to the Kremlin. Most of this property is held by secretive offshore companies. The true figure for illicit wealth invested in the UK is likely to be far higher, with almost…

Boris Johnson Promises U.K. Property Register to Expose Kleptocrat Money

Money Laundering, Regulation
As the government acts to squeeze Russian oligarchs in the wake of Vladimir Putin’s invasion of Ukraine, Boris Johnson has promised to rush forward plans for a new public register, revealing the ultimate owners of properties across the UK. The government had previously failed to act, despite the vast offshore leak known as the Pandora Papers revealing last year the details of 1,500 UK properties owned through secretive offshore companies, some of them connected to senior Russian figures. The data showed that the family of Russian oligarch Mikhail Gutseriev – who was placed under sanctions by the UK, EU and…

UK Second in Money Laundering Hall of Shame

Money Laundering
The second-highest amount of money is laundered each year in the UK, with an estimated £88bn worth of money cleaned by criminals annually. Only the US sees more, with £216.5bn laundered annually, while France (£54.5bn), Germany (£51.3bn) and Canada (£25.6bn) also rank among the top five countries in terms of value of money laundered. The figures, from identity verification software maker Credas Technologies, put together using OECD data, also revealed that about £1.8tn is laundered globally each year, some 3% of total GDP. Money laundering, and its links to organised crime, is a serious global problem that banks find themselves…

‘Credit Suisse Papers’ Leak Shows How Lender Banked Criminals and Tyrants with Little Due Diligence

Due Diligence, Money Laundering
TROUBLED Switzerland banking giant Credit Suisse was thrown into further crisis today as a massive data leak revealed a client list involved in money laundering, torture, drug trafficking and corruption. The data dump shows up massive failures of due diligence by Credit Suisse despite repeated promises by the bank that it would end relationships with dodgy clients and illicit funds. The Suisse Papers also shed light on one of the world’s largest and most secretive financial centres, based out of Geneva and Zurich, and grown used to operating in the shadows. Swiss financial institutions manage about 7.9tn CHF (€7.56tn) in…

Leak Exposes Credit Suisse’s Criminal Clients as AML Whistleblower Law Awaits Reform

Money Laundering, Whistleblowing
A whistleblower recently leaked data from Credit Suisse revealing that the bank opened accounts for and served numerous individuals with criminal ties, including sanctioned businessmen and human rights abusers. The leaked data includes information on more than 18,000 bank accounts, collectively holding more than $100 billion. It has increased scrutiny of the Swiss banking system and has renewed calls for stronger anti-money laundering laws. According to the New York Times, “among the biggest revelations is that Credit Suisse continued to do business with customers even after bank officials flagged suspicious activity involving their finances.” The Times reports that these customers…

‘Swiss Secrets’: What Would E.U. Blacklisting Mean for Switzerland?

Money Laundering
The Swiss Secrets scandal threatens to shift the country back to the European Union’s blacklist – but what does that mean for Switzerland? In view of a recent data leak showing that Credit Suisse bank accepted money from illicit sources, the European People’s Party (EPP) has called on the EU to “re-evaluate Switzerland as a high-risk money-laundering country” and add it to the list of nations at high risk for financial crime. Credit Suisse bank held tens of billions of euros of dirty money for decades, a new cross-border media investigation claimed Sunday. The investigation was coordinated by the Organised…

Credit Suisse Faces Money Laundering Charges in Bulgarian Cocaine Traffickers Trial

Drug Trafficking, Money Laundering
ZURICH, Feb 7 (Reuters) – Credit Suisse faced charges in a Swiss court on Monday of allowing an alleged Bulgarian cocaine trafficking gang to launder millions of euros, some of it stuffed into suitcases. In the first criminal trial of a major bank in Switzerland, Swiss prosecutors are seeking around 42.4 million Swiss francs ($45.86 million) in compensation from Credit Suisse (CSGN.S). They say the country’s second-biggest bank and one of its former relationship managers did not take all necessary steps to prevent the alleged drug traffickers from hiding and laundering cash between 2004 and 2008. “Credit Suisse unreservedly rejects…

Why the U.K. Needs to Accelerate its AML/CTF Efforts on Crypto Assets

Digital Currencies, Money Laundering, Terrorism
As money-laundering risks rise with the increased adoption of cryptocurrencies, the UK needs to accelerate its response to maintain its future as a centre for financial innovation. It’s been two years since the UK rolled out its anti-money laundering and countering the financing of terrorism (AML/CFT) regime for cryptoassets. And there’s been one clear lesson in that time: getting it right isn’t easy. As the Treasury Select Committee report on Economic Crime (TSC Report) launched on 2 February noted, ‘registration of crypto-asset firms for money laundering has been slow’, leading the Committee to urge quicker progress. However, UK progress should…

Estate Agents See 64% Rise in AML Registrations

Money Laundering, Terrorism
With the property market long being a target for money laundering, new data reveals that UK estate agents are stepping up to the challenge and have seen the largest annual increase in the number of newly AML registered businesses. The government’s latest risk assessment of money laundering and terrorist financing increased the risk score for money laundering within the UK property market to high, with the specific risk to both estate and letting agents also increasing. Despite this risk, HMRC revealed that estate agents had been slow out the blocks when it came to AML compliance, estimating back in 2019…

Court Approves £5.6m Seizure Over Money Laundering

Money Laundering
The National Crime Agency can seize £5.6m from a sophisticated global money laundering scheme involving UK companies, a court has ruled. Financial investigators can take the money from the London-based family of Javanshir Feyziyev, an MP in the Azerbaijan parliament. The NCA had hoped to seize over £15m but hailed Monday’s ruling a success. It comes as campaigners criticise the government for delaying new laws to target allegedly dirty money in the UK. The investigation was launched after the exposure of a corruption scandal dubbed the Azerbaijani laundromat. The NCA pored over thousands of leaked documents from Den Danske Bank,…

No 10 Pressured Me to Drop Anti-Money Laundering Measures, Says Ex-Minister

Money Laundering, Regulation
A former Conservative minister, once at the heart of efforts to clamp down on money laundering in London, has revealed that during Theresa May’s premiership, No 10 “leant on him” when he tabled amendments to introduce a public register of overseas property owners. Lord Faulks said he had first tried to put the register into the criminal finances bill in 2017 and then again into a government bill on money laundering in 2018. He had described the overseas ownership of “dirty money” in London as an obscenity. Faulks, a distinguished barrister and now an independent peer, told the Guardian he…

U.K. Seizes Millions from Lawmaker Linked to the Azerbaijani Laundromat

Money Laundering
The U.K. authorities have seized from an Azerbaijani lawmaker 5.6 million pounds (US$7.56 million) derived from a sophisticated international money laundering scheme that was revealed by the OCCRP and its partners in 2017, the National Crime Agency (NCA) said in a statement on Monday. Based on the results of an investigation conducted by the agency, a court ruled that the money can be seized from six bank accounts belonging to Javanshir Feyziyev, his wife, one of his children and a nephew. Feyziyev is a serving member of Azerbaijan’s Parliament, Chair of the UK-Azerbaijan All Parliamentary Cooperation Committee, and Co-chair of…

Towards a stronger AML/CTF framework in the EU

Money Laundering, Terrorism
The EU framework for the prevention of the use of the financial system for the purposes of money laundering and terrorist financing already has a long history. It is more than 30 years now since the first Anti-money Laundering Directive was published in June 1991. Since then, the framework has undergone many improvements, with the previous – fifth – AML Directive being published in May 2018. The framework grew both in terms of the number and the forms of the regulatory instruments involved, incorporating both regulations and directives, as well as regulatory technical standards and guidelines developed by the European…

Money Laundering via Cryptocurrencies up 30% in 2021

Digital Currencies, Money Laundering
Money laundering via cryptocurrencies increased in 2021 by 30% and is estimated to account for US$8.6 billion, claims a report recently published by blockchain analysis firm Chainalysis. Although only 0.05% of all cryptocurrency transactions worldwide are linked to the laundering of money, Europol says it could get much worse in the future. Criminals are becoming more sophisticated in their use of cryptocurrency transactions and their money laundering schemes are becoming increasingly complex, the European police agency said. The Chainalysis report indicates the origin of money being laundered to stem from darknet sales and potential ransomware attacks. Cryptocurrency transactions are supposed…

EBA Unveils New Central Database for AML and CFT

Money Laundering, Terrorism
The European Banking Authority (EBA) has launched EuReCA, a new central database for anti-money laundering and counter-terrorism financing. According to the EBA, EuReCA will be central to coordinating efforts by competent authorities and the EBA to prevent and counter money laundering and terrorist financing risks in the EU. EuReCA will hold information on material weaknesses in individual financial institutions in the EU that competent authorities have previously identified. Competent authorities will also be reporting the measures they have imposed on financial institutions to rectify those weaknesses. Such weaknesses include the lack of adequate AML/CFT policies and procedures including the absence…

The Contract Factory – Inside Danske Bank Estonia Money Laundering Machine

Money Laundering
Skype user Maxim.Canning was a veritable one-stop-shop for anyone looking to launder illicit funds. For a fee, he would not only sell you a company registered on an offshore paradise island, but also help you to disguise who really owned it. If you needed to transfer suspect money, he could make fake contracts to give it a semblance of legality, or rapidly funnel the cash through dozens of offshore accounts. “Maxim” could even find you proxy directors to add to company paperwork — for a price. “We have for 1000 euros per piece a Kazakh until 2022,” he wrote to…

Will 2022 be a Year of Action on Illicit Finance?

Bribery, Corruption, Fraud, Money Laundering
The US Strategy on Countering Corruption promises a step change in its response to illicit finance. Can the UK government step up too? There was a time in the not so distant past when the UK was genuinely a leader in the global response to illicit finance. Yes, the country has been a magnet for dirty money and its beneficiaries for decades as a result of policy decisions (for example, investor visas) and neglect (such as underinvestment in the policing response, the national Financial Intelligence Unit and suspicious activity reporting system). But awareness of the challenges posed by illicit finance…

How the Kazakh Elite Put its Wealth Into U.K. Property

Corruption, Money Laundering, Unexplained Wealth Orders
Ministers face claims they have allowed the ruling elite of Kazakhstan to secretly invest vast chunks of the country’s wealth in the London property market after failing to introduce promised new transparency laws. Former prime minister David Cameron pledged at an anti-corruption summit in London in 2016 that the UK would end the secret offshore ownership of property. More than five years later, a proposed register of foreign owners of UK property has still not been introduced. The uprisings in Kazakhstan last week reflected widespread anger at former president Nursultan Nazarbayev’s three decades of rule and the vast fortunes amassed…

Crypto Giant Binance Kept Weak Money Laundering Checks

Money Laundering
ATTARD, Malta – In the courtyard of a secluded limestone palace, Malta’s political elite welcomed a guest: Changpeng Zhao, chief executive of Binance, the world’s largest cryptocurrency exchange. It was October 2018. Zhao was in Malta to find Binance a new home, having quit mainland China the year before when regulators there began cracking down on cryptocurrencies. Zhao praised Malta for opening its doors to crypto firms. “Binance got really lucky,” Zhao told the audience, in filmed remarks. “Malta came at a time when regulatory clarity was very much needed.” That same month Binance notified Malta’s financial regulator it planned…

Top UK Law Firm Fined Record Sum for Breaching Money Laundering Rules

Money Laundering, Regulatory Fines
Mishcon de Reya, one of the UK’s most prestigious law firms, has been fined a record amount for committing “serious breaches” of money-laundering rules. The London-based firm has agreed to pay a fine of £232,500, plus a further £50,000 towards the costs of the investigation, which was carried out by the Solicitors Regulation Authority (SRA). In its decision, published on Wednesday, the regulator said Mishcon de Reya’s conduct had “potential to cause significant harm by facilitating transactions that gave rise to a risk of facilitating money laundering”. The SRA investigation concerned work the firm carried out for two unnamed individual…

EBA Alerts on the Detrimental Impact of Unwarranted De-Risking

Money Laundering, Terrorism
The European Banking Authority (EBA) published today its Opinion on the scale and impact of de-risking in the EU and the steps competent authorities should take to tackle unwarranted de-risking. Providing access to at least basic financial products and services is a prerequisite for the participation in modern economic and social life and de-risking, when unwarranted, can cause the financial exclusion of legitimate customers. It can also affect competition and financial stability. De-risking refers to decisions taken by financial institutions not to provide services to customers in certain risk categories. De-risking can be a legitimate risk management tool but it…

Swedbank ex Chief Charged Over Money Laundering Scandal

Fraud, Money Laundering, Prosecutions
The former chief executive of Swedbank has been charged with fraud, market manipulation and the unauthorised disclosure of inside information, after an investigation into a large-scale money laundering scandal in the Baltics. Birgitte Bonnesen, who was sacked as chief executive two years ago when the scandal came to light, “repeatedly spread misleading information” that the bank did not have any issues with its anti-money laundering (AML) processes in Estonia, according to Sweden’s Economic Crime Authority. Thomas Langrot, the chief prosecutor and head of the investigation, said Bonnesen either intentionally or through gross negligence disseminated misleading information about the state of…

Millions Seized in Gibraltar Money Laundering Operations

Money Laundering
Since 2016, the Gibraltar Money Laundering Investigation Unit has seized almost 2.4 million euros, as well as luxury yachts and apartments, from the proceeds of organised crime. Chief Inspector Tunbridge of the Economic Crimes Unit has attributed a collaborative relationship with Spain to its success, but admits that Brexit has made investigations all the more difficult. A huge amount of drugs is trafficked from Morocco to Spain, and foreign criminal organisations have money laundering through illegal activities in Gibraltar down to a fine art. Mr Tunbridge explained that criminals know very well that if they commit a crime in one…

Chinese Police Make First Arrest For CBDC Money Laundering

Money Laundering
Chinese officials have hunted down a gang suspected of laundering money using the digital yuan. Chinese officials have arrested members of a criminal group charged with alleged money laundering using the country’s CBDC, the digital yuan. The news implies the Chinese government and law enforcement will have greater control and oversight over financial activities in the country with its CBDC. China Records First Illegal Use Case of e-CNY The Xinmi Public Security Department arrested members of a gang, composed of 11 members, in the Fujian Province for allegedly scamming a person for 200,000 yuan ($32,000). Reportedly the victim, named Qu,…

U.K. Hands Down Largest Sentences for Money Laundering

Money Laundering, Prosecutions
A U.K. court sent two men behind bars for a total of 33 years for laundering the equivalent of nearly US$95 million and fraudulently claimed $13.44 million in COVID-19 Bounce Back Loans for their fake companies, the National Crime Agency reported. Artem Terzyan, 38, from Russia was sentenced to 17 and Deivis Grochiatskij, 44, from Lithuania to 16 years in prison after a seven-weeks-long trial in September. Their sentences are believed to be one of the largest ever handed down in the U.K. for money laundering, the NCA said. The investigation started in October 2017 when the police noticed another…

NatWest Fined £264.8 Million Over Anti-Money Laundering ‘Failures’

Money Laundering, Prosecutions
NatWest received a £264.8 million fine after failing to comply with account-monitoring requirements, becoming the first bank to be criminally convicted under the UK’s anti-money laundering regulations. The fine relates to NatWest’s failure to properly monitor its business relationship with jewellery firm Fowler Oldfield. Over a period of less than four years, the Fowler Oldfield deposited around £365 million—mostly in cash—despite having an estimated annual turnover of just £15 million In sentencing remarks published on Monday, Mrs Justice Cockerill accused NatWest of “failing to comply” with its legal obligations, but without “any deliberate flouting of the rules or any criminal…

FCA Fines HSBC £64m for Failings in its AML Processes

FCA, Money Laundering, Regulatory Fines
Banking giant HSBC has been fined £63.9 million by the UK’s Financial Conduct Authority (FCA) for failings in its anti-money laundering (AML) processes. The FCA claims HSBC’s transaction monitoring systems showed “serious weaknesses” over a period of eight years from March 2010 to March 2018. The regulator says HSBC did not dispute its findings and agreed to settle “at the earliest possible opportunity”. As a result, the bank’s total fine was discounted by 30% from £91,352,600 down to £63,946,800. In particular, the FCA says HSBC failed to “consider whether the scenarios used to identify indicators of money laundering or terrorist…

FCA Fines Sunrise Brokers LLP £642,400 for Serious Financial Crime Control Failings

FCA, Money Laundering, Regulatory Fines
Sunrise Brokers LLP has been fined over £600,000 for deficient anti money laundering systems and controls. This is the second case brought by the FCA in relation to cum-ex trading, dividend arbitrage and withholding tax (WHT) reclaim schemes. The first FCA case relating to cum-ex trading concluded in May 2021. The FCA found that Sunrise had deficient systems and controls to identify and mitigate the risk of facilitating fraudulent trading and money laundering in relation to business introduced by the Solo Group, between 17 February 2015 and 4 November 2015. On review it was found that the Solo trading throughout…

Gambling Commission Orders Greentube to Pay £685,000 for AML and Safer Gambling Failings

Money Laundering, Regulatory Fines
The GB Gambling Commission has ordered Novomatic subsidiary Greentube Alderney to pay £685,000 (€805,448/$912,304) over social responsibility and money laundering failings. A review of the business’ activities, launched in December 2020, uncovered failings in the anti-money laundering (AML) policies and safer gambling protocols across Greentube’s Admiralcasino.co.uk and Bellfruitcasino.com sites. This amounted to breaches of licence condition 12.1.1, 12.1.2, 15.2.1 of the Licence Conditions and Codes of Practice (LCCP), and provision 3.4.1 of the Social Responsibility Code. The condition 12.1.1 breaches related to Greentube Alderney’s AML processes, with the review finding deficiencies in its record keeping and evaluation of the assessments…

FinCEN Launches Regulatory Process for New Real Estate Sector Reporting Requirements

FinCEN, Money Laundering, Regulation
WASHINGTON—The Financial Crimes Enforcement Network (FinCEN) announced today an Advance Notice of Proposed Rulemaking (ANPRM) to solicit public comment on a potential rule to address the vulnerability of the U.S. real estate market to money laundering and other illicit activity. The systemic money laundering vulnerabilities presented by the U.S. real estate sector, and consequently, the ability of illicit actors to launder criminal proceeds through the purchase of real estate, threatens U.S. national security and the integrity of the U.S. financial system. FinCEN has long been concerned with the potential for corrupt officials and illicit actors to launder the proceeds of…

FinCEN Seeks Comments on Modernization of U.S. AML/CFT Regulatory Regime

FinCEN, Money Laundering, Regulation
WASHINGTON— Today, FinCEN is issuing a request for information (RFI) seeking comments on ways to streamline, modernize, and update the anti-money laundering and countering the financing of terrorism (AML/CFT) regime of the United States. FinCEN is particularly interested in comments on ways to modernize risk-based AML/CFT regulations and guidance, issued pursuant to the Bank Secrecy Act (BSA) so that they, on a continuing basis, protect U.S. national security in a cost-effective and efficient manner. Today’s RFI also supports FinCEN’s efforts to conduct a formal review of BSA regulations and related guidance, which is required by Section 6216 of the Anti-Money…

Trail of Venezuela’s Stolen Billions Leads to Carribbean Luxury Properties

Bribery, Corruption, Money Laundering
Key Findings A Venezuelan under investigation for laundering stolen oil money acquired a lucrative stake in a luxury hotel in Colombia through a company registered in Luxembourg. He and another woman under investigation, the girlfriend of former Venezuelan energy official Javier Alvarado Ochoa, sat on the board of directors of the company that owns the hotel. Three senior executives at an energy consultancy that received a $23 million contract from Venezuelan state power company Corpolec, which was led by Alvarado, also had stakes in the hotel. A Venezuelan expert in anti-money laundering said the setup was “unusual” and should be…

Nearly Half of UK’s E-Money Firms Red Flagged for Money Laundering Risk

Money Laundering
Nearly 40% of the e-payment sector in the United Kingdom, which made more than £500 billion (US$660.2 billion) worth of transactions in 2020/21, have been flagged red — a warning of money laundering risk, a Transparency International UK research published on Tuesday found. While most e-payment enterprises appear to respect the regulations, the paper warns that without stronger oversight, Electronic Money Institutions (EMI) will become a preferred channel for those trying to launder the proceeds of crime and corruption through Britain — “if they are not already.” Transparency International UK examined all 261 enterprises in the country that had been…

Danish Woman Remanded Over Laundering of $4.5b in Danske Bank Scandal

Money Laundering
A Danish woman was remanded in custody on Wednesday over her alleged involvement in a money laundering case in which more than 30 billion Danish crowns ($4.5 billion) was channelled through Danske Bank’s (DANSKE.CO) Estonian branch, Denmark’s public prosecutor said on Wednesday. The 49-year old Danish citizen faced preliminary questioning at Copenhagen city court on Wednesday, where she was put into custody for 21 days, the prosecutor told Reuters. The woman, whose name is protected by a publication ban, had been extradited to Denmark from Britain, where she had been kept in custody, the prosecutor said, adding she had ties…

Swiss Court Confiscates Funds Linked to Uzbek Ex-President

Money Laundering, Prosecutions
The Federal Criminal Court has ordered the confiscation of over $293 million (around CHF270 million) belonging to a shell company linked to Gulnara Karimova. The company, called Takilant, of which Karimova (daughter of the former president of Uzbekistan Islam Karimov) was the beneficial owner, was linked to two of the five Swiss bank accounts under criminal investigation. The total amount confiscated from the company was over $350 million. The court came to the conclusion that a large part of this sum had to be confiscated, since several of those involved – including Karimova and her assistant – were found guilty…

Notorious Money Launderer Reza Zarrab’s Lavish Life and New Business in Miami

Money Laundering, Organised Crime, Sanctions
Facing 130 years in prison, infamous Turkish-Iranian money launderer Reza Zarrab took a plea deal in 2017 agreeing to testify in U.S. courts. Federal officials have since kept him out of the spotlight, while allowing him to live a government-sanctioned life of luxury under a false identity in Miami. But the man who made his fortune cleaning profits from sanctions evasion and dealing with companies tied to slave labor and organized crime has been anything but idle. An investigation by OCCRP, Law&Crime and the Miami Herald found that Zarrab remains connected to his former criminal network and has received multiple…

Anti-Money Laundering and Counter Terrorist Financing: Supervision Report 2019-20

Money Laundering, Terrorism
Annual report for 2019 to 2020 on anti-money laundering and counter-terrorist financing supervision. Downoad: Anti-money laundering and counter-terrorist financing: Supervision Report 2019-20 This report provides information about the performance of AML/CTF supervisors between 6 April 2019 – 5 April 2020 and fulfils the Treasury’s obligation, under Section 51 of the MLRs, to publish an annual report on supervisory activity. The report includes supervisory and enforcement data on both the statutory and Professional Body Supervisors, highlighting any notable changes in supervisory activity and any fines that supervisors have issued. The report concludes that actions taken by supervisors have remained broadly consistent…

How Goes the War Against Laundering

Money Laundering
If a willingness to do the right thing were the fuel that powered the attack on money launderers, that initiative would be a total success. Compliance professionals, regulators and law enforcement officers are motivated, but we struggle to think outside the box and change our method of operation. It’s time for us to work together and recalibrate. We have a pretty good idea about the amount of illicit funds that slip past the efforts of law enforcement, regulators, and the private sector. One need only assess the findings of the UNODC about their estimates of illicit funds seeking money laundering…