The Egmont Group of FIU reports that the recent Plenary endorsed the Egmont Information Exchange Working Group’s (IEWG) Bulletin on Professional Money Laundering Facilitators dated 30th June.  This focuses on the shadow market of professional facilitators, who provide services of moving, redistributing and laundering illicit funds. Professional money laundering facilitators work with money irrespective of its origin, providing expertise to hide, conceal and disguise illicit funds, providing “Money Laundering-as-a-service”.  It is said that it should assist authorities and reporting entities in better detecting, investigating, and reporting the proceeds of professional money laundering activities.

The Bulletin says that the main characteristic that makes Professional Money Laundering (PML) unique is the provision of money laundering services in exchange for a commission, fee or other type of profit; and that PML can belong to 3 categories: individuals, organisations (a professional money laundering organisation or PMLO – and laundering funds may be the core activity of the organisation, but not necessarily the only activity) and networks (professional money laundering network or PMLN).  One of the services mentioned is record-keeping (shadow accountancy).

The Bulletin defines a PMLN as a collection of associates or contacts working together to facilitate PML schemes and/or subcontract their services for specific tasks.  These networks usually operate globally and can include 2 or more PMLO that work together.  They may also operate as informal networks of individuals that provide the criminal client with a range of ML services.  These interpersonal relationships are not always organised and are often flexible in nature.

The Bulletin provides a list of red flags for FIU and the private sector to contemplate.


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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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