Saturday, March 29, 2014

Money Laundering Typologies

The Accounting Research Institute thanks ASP Mohd Noor Firdaus from the Royal Malaysia Police for sharing his AMLA-related investigations and experiences with students from the Master in Forensic Accounting and Financial Criminology program of Universiti Teknologi MARA. The class was told that one of the most important competencies that investigating officers need to know is the ability to develop typologies. Typologies refer to the methods or trends used by criminals to launder proceeds of criminal activities and finance illicit activities. In most cases, the methodologies are in constant evolution.  ASP Firdaus shared two famous typologies.  Firstly, the use of the traditional "Hawala" system remains a popular tool used by money launderers for transfer and receipt of funds.  Without "actual movement" of cash, funds are transferred from one country to another. The use of  "Contra Transactions" often makes audit trail difficult to do. Sometimes, such cash movement is settled through trade exchange and "cash contra".  Premised on the concept of trust, some "net settlement" may cover a long period of time. What makes them distinct from other money transmitters is their use of non-bank settlement methods. Secondly, money launderer criminals seek the advice or services of legal and accounting professionals to help in laundering criminal assets. As reporting institutions, it is crucial that these professionals be aware of their responsibilities to mitigate money laundering activities by their clients. Three specific responsibilities are: (i) to know their clients by conducting due diligence, (ii) to maintain full record of their tasks for at least six years and (iii) to submit "Suspicious Transaction Report or STR" to the Central Bank in the event that they become suspicious that their clients might be involved in possible money laundering activities.