Critical Evaluation Of The Eu Directives

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02 Nov 2017

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(f) "Customer due diligence" and "Reporting of Suspicious Transaction" are two very important recommendations of the FATF. These two recommendations have created a theory of "Crying Wolf"176 in which each and every time, a transaction is reported suspicious without any investigation or proof which negates to catch the chances of real suspicious transaction. One can see this through the statistics that after joining FATF in August 2007, China has reported suspicious transactions

175 Supra (n 4)180.

176 .Supra (n 2)32. 52

more than the 16 big economies of the world including USA, UK, Japan and Switzerland177 because some financial institutions think it better to reporting than non-reporting. Other reasons to increase the trend are that there are certain fines on banks if they are unsuccessful to report a transaction which is proved later suspicious. So fear of fines and other penalties are working in this regard. While "Customer due diligence is also avoided by so many financial institutions on several grounds including; (I) some financial institutions do not want to lose their clients with big accounts and do not bother to ask the sources of the money. (II) Some senior citizens and old account holder also do not want to have this headache of identifications and banks oblige them to keep their accounts. (III) Elite also do not like to go under this kind of investigation and again financial institutions do not want to lose these clients178.

177 .Supra (n 101)268.

178 .Supra (n 46)651.

179 .Supre (n 46)657.

180 .Supra (n 46)656.

11.3 Critical Evaluation of the EU Directives:

EU as the member of the FATF enacted all the recommendations of the FATF in EU through Directives and now state members are required to enact the provisions of the Directive into their domestic law. Problems with EU Directive related to "Customer due diligence and Report of Suspicious Transactions" are same as mentioned in the FATF section because there are also penalties and fines on the banks/financial institutions on not reporting the suspicious transactions. But in West, mostly finance crimes are in the form of bank card fraud (Credit/Debit) and sometime selling of counterfeit goods. This is really difficult to report these kinds of activities for any financial institution or body investigating in this field. Other important thing is that these cases are so many to differentiate that which will be used for terrorist activities179.

Conflict of interests is also another important factor. Data transfer from Europe to USA has been a big issue for the corporate sector. This issue arose in 2006 when inter-Bank cooperative "SWIFT" (Based in Belgium but also regulated in USA as well) transferred some data related to the inter-banks transactions. Later it was revealed that bank transferred that data to CIA which ultimately transferred it to the USA’s companies which were in competition with the European financial sector from 2001 to 2006180. So this created concerns in European countries and a discussion is still going on in European Parliament over the data sharing with the USA. Same is the case with the UNSC resolution implementation which has been explained in Yasin Abdullah Kadi and Al Barakaat International Foundation v. Council of the European Unioin and Commision of the the European Communities. 53

It is also very difficult to monitor and check those persons who are travelling with the traveller cheques on the name of family members. Same is the case with the beneficiary owner if he or she is the family member. In this case, it is really difficult to monitor and report the intentions of the person or institutions whether they are going to use that traveller cheque and foreign exchange for criminal activities or not.

11.4 Critical Evaluation of the AML Act 2010 in Pakistan:

Pakistan passed its first Act related to money laundering and financing of terrorism to enact all the recommendations of the FATF in 2010. The main feature of this Act was the establishment of the "Financial monitoring Unit". Although it has been declared that unit will work independently but the problem is there are so many other institutions involved in investigation about the suspicious transactions or money laundering case. For example, FIA (Federal Investigation Agency) and NAB (National Accountability Bureau) are two main institutions that work to investigate any suspicious case but unfortunately both these institutions are under the Ministry of Interior and minister for this is always a politician who has the authority to appoint the chief in FIA. So a politically motivated chief can never investigate cases against its own government or people affiliated with the government. Same is the case with the NAB, whose head is also appointed by the Head of the State (Recently appointed by Sitting President who has severe charges of Money Laundering). So how a politically appointed head can work against his own appointing authority? Pakistan is in a transition phase of development in every aspect. Institutions are not much strong like in Europe or other developed countries and data sharing mechanism is also very poor among institutions.

Pakistan is a multi-ethnic Islamic country with a big network of Islamic education institutions called Madrassahs. The funding to these Madrassahs is always from people on the name of Islam. So it is really difficult to suspect and stop this funding in terms of suspected use in criminal activities. It is also very difficult to know the intentions of donator and intentions of recipient.

Charities are also another important factor in the Pakistani society. People give donations/charities and Zakat (Basic Part of Islamic religion) to poor and Madrassahs which make it more complicated to implement the legislation of anti-money laundering and financing of terrorism. Unless it is proved that their intention is to finance terrorist activities, it is almost impossible to stop these people to give donations181. Same is the case with all other Islamic countries as well.

181 Supra (46) 657.

People of Pakistan are not enough educated and infrastructure in Pakistan is not up to date in every town and village. Millions of Pakistanis are working overseas including Europe, USA, UK and Arab countries. They are sending money through these Hawala institutions because they are quick in service, cheaper and trusted to those people living in 54

the remote areas of Pakistan. Although SBP has started to register these institutions but still there are a lot of illegal working in different cities and towns. It is very difficult for investigating authorities to monitor and control all the Hawala transactions.

Pakistan has a special geographical location. Russian entrance in Afghanistan started a holy war "Jihad" against Russians fully funded and helped by CIA of USA. USA herself trained and gave money/weapons to these groups to fight against Russians. Russian left the Afghanistan and these groups came in power names as Taliban (Now Terrorist Groups announced by USA). These groups are fighting in Afghanistan against USA and have suspected links with Al-Qaida as well. Pakistan’s borders with Afghanistan are vulnerable for these groups. Heroine is a big product in Afghanistan and money gained by this is laundered and used in terrorist activities (suspected).

Corruption has been a big problem of Pakistan. A lot of Pakistani politicians, Government Officers and other individuals gained money and put them in the European and UK institutions through money laundering but these countries are facilitating them through their banking laws. These countries always welcome those even exposed persons to invest in their countries and have safe havens for their illegally gained wealth.

6.0 Establishment of International Norms and Regulations to Counter Money Laundering and Financing of Terrorism:

Figure 3: Diagram showing four different layers of anti-money laundering regulations

UN

UN Sub Organisations

FATF

EU

World Bank

IMF

Domestic law

After the WW2, there was an increasing tendency towards the legislator’s behaviour to make criminals Acts related to those crimes which did not harm any individual directly or in which victims were not identifiable. There were a lot of crimes regarding environmental, fiscal or economic issues which did not have direct victims at that time but legislators started to criminalize those acts. Confiscation of proceeds of crime was the solution to deprive the offender in those cases but most of legal systems were used to traditional confiscation known as "forfeiture" which had meaning of "confiscation of instrument" or "Subject of crime" rather than proceeds of crime at that time48. As there were no identifiable victims, only legal instruments were confiscation of proceeds of crime but most systems could not do it as it was stated in 1981, in England, where court 22

acknowledged her incompetence to take away profits of drug trafficking in R.v.Cuthberston49 case. It was stated in that case that s27 (1) of "Misuse of Drug Act 1971"only allows to confiscate the instruments of crime rather proceedings of crime50. In Belgium, this confiscation of proceeds of crime was provided but this was limited only to drug trafficking51, according to the "Belgian Drug Offences Act 1921". England was the first country to take initiative in this regard. On the recommendation of the "Hodgson Committee", Parliament empowered the courts to confiscate the proceeds of the crime as well according to the "Drug Trafficking Offences Act of 1986"52.

49 .[1981]AC470.

50 .Supra(n 48)4.

51 .(RDP(1986),910) Belgian Supreme Court.

52 Supra(n 48)5.

53< http://www.unodc.org/pdf/convention_1988_en.pdf> accessed on 18-08-2011.

54< http://www.un.org/law/cod/finterr.htm> accessed on 18-08-2011.

International efforts to set norms, standards and regulations to counter money laundering and finance of terrorism can be seen in four different layers which are as follows;

ï‚· UN (Through its Resolutions and sub-organisations like World Bank and IMF)

ï‚· FATF(An international Organisation)

ï‚· EU (Through it 3 Directives) or Regional Agreements

ï‚· Domestic law of the Land (Every country has its own law to counter money laundering according to UN Resolutions and FATF Recommendations)

6.1 United Nations and Money Laundering:

UN has four Conventions regarding money laundering and financing of terrorism which are as follows.

6.1.1 United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances 1988.

In the General Assembly meeting of United Nations 1988, several countries of the world showed their deep concerns over the increasing trend of drug abuse and drug trafficking across the world which led the General Assembly to adopt the Resolution 39/141 of December 14, 1984 entitled as "Draft Convention against Trafficking in Narcotic Drugs and Psychotropic Substances"53 .It was the first legal instrument and international convention which criminalises the money laundering.

6.1.2 International Convention for the Suppression of the Financing of Terrorism199954:

This convention has 28 Articles in which guidelines have been given to counter financing of terrorism. In this instrument, activities linked to the terrorism and funding of it were mandated as offences. 23

6.1.3 United Nations Convention against Organised Transnational Crimes in Palermo Italy 2000.

UN "Convention against organised transnational crimes" known as "Palermo Convention" had same importance as the 1988 Convention. This convention was important because not only fight against organised crime was reinforced but countries were advised to implement it in their domestic law55. This convention had relations with anti-money laundering in a way that every obligatory to this convention was supposed to do these things56;

55 Norman Mugarura,"The Institutional Framework against money laundering and its underlying predicate crimes"(2011)JFRC179.

56 .< http://www.unodc.org/documents/treaties/UNTOC/Publications/TOC%20Convention/TOCebook-e.pdf> accessed on 18-08-2011.

57< http://www.unodc.org/documents/treaties/UNCAC/Publications/Convention/08-50026_E.pdf> accessed on 19-08-2011.

58 .Supra (n 4)177.

59 .Ibid.

(I) Criminalise all types of money laundering, whether it happens in domestic jurisdiction or some other country.

(II) All obligatory states were supposed to establish such regulatory institutions to monitor every kind of money laundering including reporting of suspicious transaction.

(III) All obligatory states were supposed to do this in cooperation with other institutions of the world to exchange important information to counter money laundering.

6.1.4 Convention on Corruption 2003:

This Convention has 71 Articles and VII Chapters. This was adopted through General Assembly Resolution 58/4 on 31st October 200357. In this convention, it was declared that this strategy will apply to all offences, whether related to corruption or not58.

UN Conventions were product of wide participation of experts and states. These conventions have consensual and authoritative character. States with different political, social, ethnic and economic backgrounds have agreed at some minimum agenda in these conventions which make it authoritative in character59.

6.2 Unites Nations Security Council Resolution:

Incident of 9/11 was a turning point in the history of anti-money laundering legislation. Before this sad incident, UN Security Council played a little role to develop the norms or obligation to its member states but 9/11 gave a shock to the world. It not only attracted the world’s attention to make anti-money laundering legislation but also gave a conceptual shift of money laundering from drug trafficking to financing of terrorism. Before this, efforts were only focussing to counter money laundering and it’s proceed based upon 24

criminal activities like drug smuggling, fraud, corruption and tax evasion. But after this incident, financing of terrorism became priority in the eyes of legislators.

After the attacks on US, UN Security Council meeting were called on September 28th 2001,in which a Resolution was passed unanimously under the "Chapter VII of UN Charter", named Resolution 137360, having binding effects on all its member states. The Resolution 137361, September 2001, played a role of catalyst towards the international efforts to combat the money laundering and financing of terrorism. Important thing about this Resolution was that it was imposed to all its member states while other Resolutions are usually binding on the voluntarily signature of the concerned states.

60 .2001 UNSC Res.1373.

61 <. http://www.un.org/News/Press/docs/2001/sc7158.doc.htm> accessed on 20-08-2011.

62 .M.Michelle Gallant, "Promise and perils:the making of global money laundering,terrorist finance norms" (2010)JMLC181.

63 . <http://www.un.org/en/sc/ctc/aboutus.html > accessed on 20-08-2011.

6.2.1 Aim of Resolution 1373:

UNSC Resolution 1373 commands all its member states to take certain actions and measures which can help in following means62;

(a) To prevent and strictly suppress the acts involving the financing of terrorists or terrorist groups.

(b) To criminalise the funding to terrorism

(c) Assets or other resources freezing related to terrorism

(d) Ban on collection of funds for or on behalf of terrorist activities.

6.2.2 Establishment of Counter Terrorism Committee:

In Resolution 1373, a counter terrorism Committee63 was established to monitor the implementation of the Resolution. All the 15 members of the Security Council were the members of this committee. Committee also requested all the member states of UNSC to cooperate among them to counter terrorism at every level including legal, social and economic level. It also emphasized to play a pro-active role in fight against terrorism and terrorist funding activities.

6.2.3 Resolution 1373 and Definition of Terrorism:

This Resolution was passed in a single meeting of the UNSC and a monitoring committee was also established at that time without defining the definition of the terrorism. The Resolution just listed two groups (Al-Qaida led by Osama Bin Laden and Taliban led Government in Afghanistan) on "sanction list" without completely defining terrorism and its related aspects. It created a chance, in future, any big power or authoritative regime, anywhere in the world, can declare any group a terrorist, working against her wishes and desires, which can be a non-violent. This can lead to the violation of the human rights and Charter of UN itself. 25

6.3 World Bank and IMF:

Money laundering and finance of terrorism happens through the loopholes of banking and financial system. If the banking and financial systems are not strong, resistant, transparent and reformed, there are always chances to abuse these systems by launderers or terrorists. World Bank and IMF are playing their role by promoting reforms and giving their guidelines to these sectors to counter money laundering and combat the financing of terrorism. Both organisations are running hundreds of programmes to develop and reform the international, regional and domestic financial institutions64.

64 . <http://www.imf.org/external/about.htm> accessed on 24-08-2011.

65 .< http://www.imf.org/external/np/exr/facts/fsap.htm> accessed on 24-08-2011.

66 .Supra (n 55)187.

67 .Ibid.

68 .Ibid.

6.3.1 IMF:

IMF (International Monetary Fund) usually works to identify the vulnerabilities present in the financial system of all its member states. IMF’s staffs visit their members’ states and examine their system to help them and give them the guidelines to eradicate loopholes present in their system. IMF also takes a look into the legal system of its member states to make them invulnerable. Its role to prevent the global crises at different stages and at different regions of the world is admirable. "Financial Sector Assessment Programmes"65 started as a joint venture of IMF and World Bank in 1999, helped to inquire the financial stability and vulnerabilities of its member states, was one of the step taken by these organisations. IMF helps to assess financial markets, payment systems, regulatory and supervisory bodies, banks security exchange and legal systems dealing with the financial sectors of the member states66. Suggestion and advises are given by this organisation after assessing these frameworks.

6.3.2 World Bank:

World Bank runs programmes to help its member states to counter corruption, maintaining good governance in financial institutions and public financial management programmes. IMF has done more than 600 programmes (lending or non-lending), in more than 90 of its member states, to make governance at its best level and reduce corruption through institutional restructuring and reforms67. These programmes include training and assistance to tax and custom authorities, management system of financial institutions, gross root level reforms in public sector programmes, reforms in legal and regulatory system and help to establish the mechanism to eradicate corruption in the public welfare sector system and programmes68. World Bank has shifted its focus to small and third world countries which are more vulnerable to money laundering and abuse of financial markets. It has also supported and encouraged all its member states to establish law on money laundering, tax 26

evasion, lending and development issues. To help its member states in these above mentioned directions, it has established "Institutional Development Fund"69.

69.<http://web.worldbank.org/WBSITE/EXTERNAL/PROJECTS/0,,contentMDK:21016577~pagePK:41367~piPK:51533~theSitePK:40941,00.html accessed on 21-08-2011.>

70 .Supra (n 55)188.

71 .Supra (n 48)17.

72 .Supra (n 55)182.

73 .Supra (n 62)177.

74 .< http://www.fatf-gafi.org/pages/0,3417,en_32250379_32236836_1_1_1_1_1,00.html> accessed on 20-08-2011.

75 . Ibid.

76 .< http://www.fatf-gafi.org/document/52/0,3746,en_32250379_32236869_34027188_1_1_1_1,00.html > accessed on 20-08-2011.

77< http://www.fatf-gafi.org/pages/0,3417,en_32250379_32236879_1_1_1_1_1,00.html > accessed on 20-08-2011.

IMF and World Bank have helped all its member states to identify the problems in their financial and regulatory institutions which make them more vulnerable for money laundering and other financial abuses. Their efforts are to make integral financial institutions with better regulatory and supervisory norms in the world70.

7.0 Money Laundering and FATF (Financial Action Task Force):

The Financial Action Task Force (FATF) is an inter-governmental body known as "Crown Jewel of Soft Law"71. It is also known as "Groupe d’ action financiere (GAFI). This was founded in 1989 on the initiative of the G7 (seven big industrialised states). At G7 summit in 1989, in Paris, these industrialised states had deep concerns over threat to their financial institutions and banking system by drug trafficking and its proceeds, organised transnational crimes and money laundering72 . The G7 members were not afraid of drug trade itself in their jurisdictions but the money gained by these activities was the prime concern of G7 members because that money was threat to the financial institutions of the world73. The head of states or government of G7, president of European Commission and eight other member countries were present at G7 summit when FATF was established in 198974. . It has its head office in Paris, at OECD (Organisation of Economic Co-operation and Development) headquarters. Although it has its head office at OECD secretariat but it is independent body from the OECD75. At present, the members of the FATF are 36, including 34 countries and 2 regional organisations. These organisations include "European Commission and Gulf Cooperation Council". Apart from these members, there are 27 Associate members or observers in it including regional and international organisations (including IMF and World Bank), which are working with the FATF at the moment76. Giancarlo Del Bufalo (from Italia) is the current president of FATF from July 2011, for the period of one year77. 27

7.1 Objective/Aim of the FATF:

The Mandate of FATF is;

"[…….] to assess the results of cooperation already undertaken in order to prevent the utilization of the banking system and financial institutions for the purpose of money laundering, and to consider additional preventive efforts in this field, including the adaption of the legal and regulatory systems so as to enhance multilateral judicial assistance"78.FATF is not a treaty organisation or body but it is a voluntary organisation79 mainly a principal AML multilateral organisation80. The objective behind the establishment of the FATF is to make and establish international norms, standards to promote the policies of counter money laundering and financing of terrorism. Initially, the purpose of its establishment was to review all the old methods and techniques used at regional or international level to counter money laundering and financing of terrorism. After examining the previous techniques and all its loopholes, development of new guidelines were the prime objective of the FATF.

78 .G-7 Summit,Paris,July 14-16,1989,available at ; http://www.g8.utoronto.ca/summit/1989paris/communique/monetary.html accessed on 21-08-2011.

79 .Supra (n 55)182.

80 .Ibid.

81 .Supra (n 62)177.

82 .Inquiry into EU and International Cooperation to Counter Money Laundering and the Financing of Terrorism,E/08-09/f99 ML.

7.2 FATF Methodologies and Strategies:

FAFT adopted two methodologies at its start which helped it to make an inter-governmental prominent body due to which all the member states paid heed to its recommendation to implement them in their domestic law.

(I) FATF did detailed study on the problems of legislation and loopholes present in the financial system/anti-criminal and financial laws of different countries and presented a set of detailed recommendations and guidelines to help them in fight against money laundering and financing of terrorism.

(II) It established and started a process of evaluation of different countries, how they are implementing FATF recommendations which made this body more prominent and worthy. Different countries focussed its recommendations to enact them in their domestic law by different amendments in domestic anti-criminal financial laws81.

While FATF has three main strategies which are as follows82;

(a) Standard setting for International community

(b) Evaluation and assessing the compliance with its recommendations at global level

28

(c) Assessing and evaluating financial institutions in terms of vulnerable to financing of terrorism.

7.3 FATF Recommendations:

After the creation of FATF, within less than one year, in April 1990, FATF presented its first set of 40 recommendations .These recommendations were lengthy and detailed. These recommendations were the guidelines/measures for the countries to counter the phenomenon of money laundering83.In these recommendations, all the related concerns were discussed and their solution was presented like "criminal justice system and enforcement" and regulations for the international financial systems and cooperation among states of the world .These recommendations were not too much complicated so almost every international body/organisation endorsed and promised to implement them fully. These recommendations were neither against the freedom to make legitimate economic development /transactions nor they forced states to implement them at once. But they were flexible set of guidelines/recommendations which a state or government was recommended to implement in its domestic and financial laws according to its own circumstances. This is the reason; it is called "Crown Jewel of Soft Law"84.

http://www.fatf-gafi.org/dataoecd/7/40/34849567.PDF > accessed on accessed on 23-08-2011.

84 .Supra (n 48)17.

85.< http://www.fatf-gafi.org/dataoecd/7/40/34849567.PDF > accessed on 27-08-2011.

86 .Ibid.

87 .Supra ( n 55)8.

7.4 40 Recommendations:

Here is the brief explanation about the 40 Recommendations of FATF presented in 1990.

ï‚· Recommendation 1,2:

Recommendations 1 and 2 are related to introduction/scope of money laundering, its criminal offence85.

ï‚· Recommendation3:

This Recommendation deals with the legal provision of measures and confiscation. First 3 recommendations are about the legal system and provision of money laundering86.

ï‚· Recommendations4:

Recommendation 4 emphasizes that secrecy laws present in financial institutions of the different states should not inhibit the transparent recommendations of the FATF to implement87. 29

2.1 Dirty Money:

The simplest definition of the dirty money is that any kind of money that is in any way "referable to a civil wrong"8.

Illicit Wealth

Drug Smuggling

Corruption/Fraud/Bribery

Human Trafficking

Tax Evasion

8 .Barry A K Rider, "The practical and legal aspects of interdicting the flow of dirty money" (1996)JFC237.

9 . http://www.legislation.gov.uk/ukpga/2002/29/section/340 accessed on 23-06-2011.

2.2 Criminal Property:

According to the s.340 (3) of the POCA 2002, "(3) Property is criminal property if-

(a) it constitutes a person’s benefit from criminal conduct or it represents such a benefit (in whole or part and whether directly or indirectly),and

(b) the alleged offender knows or suspects that it constitutes or represents such a benefit"9.

3.0 Sources of illegal money:

Usually criminal sources of money like drug smuggling, human trafficking; terrorist activities, corruption, fraud and tax evasion are usually concealed because they are criminal offences.

Figure 1 : diagram showing sources of illegal money

The verb ‘laundering’ is used for washing and here it refers the washing of dirty money through a series of transactions so that at the end of the day, it appears to be legitimate. It is a sophisticated process of money transfers through multiple and complex transactions using global markets and infrastructure so that the original criminal source of money is 11

difficult to detect in future10. This transfer of illicit money involves two processes which are as follows;

10 .Supra(n 6)337.

11 .Elod Takats , "A theory of "crying wolf": the economics of money laundering enforcement"(2011)JLE&O60.

12 . http://articles.sfgate.com/2010-12-27/news/26287701_1_coins-dime-and-quarter-soda-machines San Francisco Chronicle(27th December 2010)

ï‚· This involves the traditional money laundering in which money is transferred through different accounts for a particular time and finally it leads back to original account holder which appears to have different and legal origin.

ï‚· Money laundering does not mean that it always involve illicit money or money derived from illegal activities but second form of money laundering is that legal money is transferred for illegal activities like terrorism but it is transferred in such a way that the connection behind such transactions are not detectable11.

So money laundering involves transfer of both legal and illegal money but the purposes behind these transactions are always criminal.

(Money laundering in its literal meanings is also used in such a way that since 1938, at "West St. Francis’ Hotel", San Francisco coins are washed and cleaned in a specially made machine so that the possible dirt present on coins is not transferred to the white gloves of the ladies12).

4.0 Stages of Money Laundering:

There are three main stages of money laundering which are as follows;

ï‚· Placement

ï‚· Layering

ï‚· Integration

4.1 Placement:

Corruption also plays an important role to keep these kinds of transactions secret13. Money launders are always ready to spend or cost extra amount to keep their money out of reach from the local jurisdictions where the money was originated. When the money is transferred offshore, it is very easy to get enter into the conventional banking system of that jurisdiction, directly or indirectly.

13 .Supra (n 8)238.

14 .Ping He, "A typological study on money laundering" (2010) JMLC 1-9.

15 Ibid2.

16 Ibid3.

17 ."The Hawala,Alternative Remittance system and its Role in Money Launderin" Financial Crimes Enforcement Network (FinCEN)5. Available at http://www.treasury.gov/resource-center/terrorist-illicit-finance/Documents/FinCEN-Hawala-rpt.pdf accessed on 08-06-2011

For this purpose, banking institutions, underground banks, insurance institutions, international trade based agreements, realty or lottery businesses, shell or front companies, offshore corporations or financial institutions, electronic or e-gaming, cash smuggling, through professionals(Lawyers or Accountants)methods are used14. Here is the brief discussion, how these institutions are used and different methods are applied to place the dirty money.

4.1.1 Banking Institutions:

As the world has become global, the global economy and market has made it easier to transfer money across the borders. Once the crimes like drug smuggling, human trafficking, bribery, tax evasions etc. are converted into money, it is transferred to conventional banking system. As it is mentioned before, for this purpose, banking institutions outside the local jurisdictions are preferred. Usually accounts are opened on dummy names or on the names of the frontmen15. Launderers use the banking institutions more and often because there are so many other advantages in banking institutions like deposits, foreign exchange, loan facilities and other settlements. Some banks also offer different ways for the resources transition. This is the reason, in every anti-money laundering document, financial or banking institutions are mentioned most vulnerable to money laundering. Keeping these points in eyes, 11 major international/multinational banks of the world decided to do cooperate among themselves to counter this phenomenon in 2000. They include "Chase Manhattan Bank, Union Bank of Switzerland, Societe Generale Bank of France, ABN AMRO Bank, Hong Kong Bank and Shanghai Bank16.

4.1.2 Underground Banks:

Underground banks are those bank which provide the alternative remittance network and which do not come under the supervision of the financial supervisors of that jurisdiction or any other financial supervisor. They have different names according to their origins and mechanism. In Pakistan, these are called ‘Hundi’ while in India; these kinds of networks are called ‘Hawala’17. The terms ‘Hawala and ‘Hundi’ are the same and interchangeable according to the relative locations where they are applied. In these kinds of 13

networks, money is not moved actually but it is transferred without physical movement of the money. This makes it easier for the launderers to move their money anywhere.

4.1.3 Insurance Institutions:

Insurance institutions are also used to launder the dirty money. In this situation, criminals get different insurance policies to disguise the source of illegal money. Usually they buy the policies from these institutions, after a particular time period, they alter them and at some specific points they claim these policies to avert the origin. For this purpose, they pay huge commissions to the agents. Agents do not pay much attention to the source of the money, easy for the criminals to get them18.

18 Supra (n 14)4.

19 .The Financial Action Task Force (FATF) Report, June 23, 2006. Available at < http://www.fatf-gafi.org/dataoecd/60/25/37038272.pdf > accessed on 12-08-2011.

20 .< http://articles.baltimoresun.com/2011-04-27/news/bs-md-blackwell-indictment-20110427_1_tahirah-carter-blackwell-case-alleged-drug-dealer> accessed 30-04-2011.

4.1.4 International Trade based Agreements:

International trade based agreements money laundering is another way of money laundering in which fake trade agreements and invoices are made. It is also very attractive way of money laundering for the criminal because after finishing such a deal or agreement, it becomes difficult to trace the original source of money. Usually in these kinds of agreements, fake invoices and price of the products are made and shown to the authorities so that certain amount of money can be brought to the legal terms. International trade involves so many other steps like foreign exchange; insurance etc. which makes the matter more complex and complicated which always favours the launderer. Other issues like cross border jurisdictions, information exchange mechanism, transnational language systems and information sharing systems make it more difficult to proceed19.

4.1.5 Realty or Lottery Businesses:

As the circle around the criminals is made more tightened, they are always after the search of new ways and means to launder their money. Laundering the money through realty or lottery businesses is another way used by them. There are no checks on the source of money in these businesses, so they are proved to be more vulnerable for money laundering. These kinds of businesses have no potential or capacity to combat the money laundering and there are not recommendations or guidelines for these kinds of businesses. Another advantage for criminal in these kinds of businesses is that these businesses involve property and cash, presenting more chances for the criminals. On 27th April 2011, Steven Blackwell20 , a notorious drug dealer, was accused of money laundering through "Maryland’s National Lottery". In this kind of situation, the winning lottery tickets are bought from the 14

original winners to make the dirty money legitimate. Some extra amount and amount equal to the winning amount is given to the real winner to make him satisfied. Extra cost works to make the dirty money legitimate.

4.1.6 Shell or Front Companies:

Shell banks are those banks which do not have branches or offices physically. They have their infrastructure just on papers to fulfil paperwork and some basic requirements21. These kinds of companies do not have even organisational structure or permanent premises for their operation. On the other hand, front companies usually do have the fixed premises for production and infrastructure. These companies have legal activities, operating systems and establishment.

21 . Baylor L.Rev, "Bringing Out the Big Guns: The USA PATRIOT ACT, Money Laundering, and the War on Terrorism" (2003) 971.

22 .Supra (n 14)8.

23 Ibid.

The difference between these two companies is distinct from their apparatus. Front companies having all legal infrastructure is used to launder the proceeds of crime. Criminals use these kinds of companies to make all their dirty money clean. They make excuse of getting more and more income coming from these companies. These front companies have following advantages22 for the criminals;

(i) Criminals have usually close relationships with the actual owner or "beneficial ownership" which helps to keep information secret with the company.

(ii) Through these companies, transactions are less suspicious.

(iii) Huge amount of funds can be transferred on behalf of companies account and it seems absolutely legitimate.

(iv) These kinds of businesses (restaurants, casinos, and clubs) involve cash transactions and hereby creating more advantage for the criminals.

(v) The connection between criminal and company structure is difficult to find.

(vi) It costs very low to form a company and it does not matter how professional experience one does have to form and establish a new company23.

4.1.7 Offshore corporations or Financial Institutions:

Corporations that can be operated from anywhere in the world, without the presence of the investors at the corporation site, not compulsory even at the time of formation, are called offshore corporations. Some countries like Bahamas, Virgin Islands 15

and Bermuda24 have established some economic zones where economic regulations are very soft. These economic zones are called "offshore jurisdiction area" and corporations working here are called offshore corporations. Offshore companies are attractive for the money launderers because they are always outside the original jurisdiction. Other advantages which an offshore company or corporation offers are;

24 .Supra(n 14)9.

25 Ibid.

26 . .The Financial Action Task Force (FATF) Report, "Money Laundering and Terrorist Financing Vulnerabilities of commercial websites and internet payment systems",June 18.2008. available at http://www.fatf-gafi.org/dataoecd/57/21/40997818.pdf accessed at 17-08-2011.

27 .Supra (n 14)1.

28 .Ibid.

(i) There is no need of minimum capital to open an offshore corporation.

(ii) There is no obligation of publishing annual report and profit. No need for annual meeting and showing financial status.

(iii) Shares can be bought and sold at any time freely.

(iv) No need to show the names of shareholders and corporations information.

(v) In some offshore jurisdictions, these corporations have extra facilities like tax exemption as well25.

4.1.8 Electronic or E-gaming Resources:

Scientific development and InfoTech have proved a sword with two sided effects. It has improved the human life standard, making life easier than the ancient times, inventing new things to make human life more comfortable. On the other hand, it has made it easy for criminals to proceed. With the dawn of 21st century, in a globalised world, in a digital era, it is easier to launder the money. Internet banking has made it easier to transfer the money with a single click without any identification or checks. Multinational banking system has made it easier to transfer the money across the borders. E-banking and internet casino are more vulnerable for money laundering. It is very difficult to report the suspicious transactions in e-banking. It is very complicated in such a way that it is difficult to decide about the jurisdiction of the criminal, location of the accounts and server. No immediate clarity about the authority and jurisdiction to investigate makes it more vulnerable to launderers26.

4.1.9 Cash Smuggling:

The first cash smuggling case through human body was reported in 1991 in USA at "John F Kennedy"27 airport where authorities caught a Ghanaian woman carrying a lot of cash in her body and other luggage. At the start of interrogation, she admitted to carry just $9000 in cash (according to customs declaration, $10,000 were allowed to carry in cash during travelling). Later when she was searched, authorities found $ 24,000 in small notes packed as sheets, $224,000 in shampoo bottles and $53,000 in her stomach in the forms of some small bags28. Authorities detected these bags of notes through the x-ray test after 16

getting suspicious. This was the first time; authorities found some form of money laundering through human body.

Although criminals have opted new and modern technologies to transfer the cash but cash smuggling through human is still in existence. In this case, individuals cross the borders and deposit their proceeds of crime to financial institutions. Different people use different methods to smuggle the cash like in USA, people were caught who swallowed the notes of $500. Some people use the specially made shoes with high ankle to do this. This kind of smuggling was reported in France. Some people use clothing, motor vehicles, cargo consignments, go-fast vessels and accompanied luggage29. To avoid this kind of smuggling different countries have a limit to carry cash at the time of crossing a border like USA, Canada, Japan, and Italy have this limit up to $10,000 while in China, this limit is up to RMB20,000 which is equal to US$5000. Smugglers prefer to carry the big value notes because carrying and hiding so many small notes is difficult. Keeping this thing in mind, some of the countries have stop to issue big value notes like in Canada, issuing of 1000 Canadian dollar has been terminated due to this factor. Same is the case with USA, where the $500 note has been stopped to issue since 1969 due to American-Mexico border smuggling.

29 . http://www.aic.gov.au/publications/current%20series/tandi/401-420/tandi402.aspx accessed at 19-08-2011.

30 . http://www.fatf-gafi.org/glossary/0,3414,en_32250379_32236920_34295666_1_1_1_1,00.html#34276864 accessed 0n 19-08-2011.

4.1.10 Professional Accountants /Lawyers:

Criminals are always in search of new ways and methods to proceeds their crimes. With the passage of time, law enforcement authorities detected ways of laundering money. This has pushed criminal to use new techniques to go on with their proceedings. Among them, use of expertise of professional accountants and lawyers is most important. These professionals not only give their professional advice to hide the crimes to the criminal but also use their own trust account to facilitate the criminals. In this case, criminal at first stage deposit their dirty money to the account of professionals and then these professional make regular payments to any property bought or got through mortgages. But these kinds of properties are owned beneficially by the criminals. The definition of beneficial owner is stated by FATF recommendation as follows;

"the natural person(s) who ultimately owns or controls a customer and/or the person on whose behalf a transaction is being conducted. It also incorporates those persons who exercise ultimate effective control over a legal person or arrangement"30. (This definition was taken from the FATF Recommendations, Glossary: FATF Methodology).

Criminals use the professionals to minimize the suspicion on them through their skills and advices. These professionals provide a lot of services like buying or selling a property, creation of a corporation and doing financial transactions on their behalf. This is 17

not necessary that these professional are always intentionally involved in this matter, sometimes they do this unconsciously as well.

This kind of money laundering is so important that in every national and international anti-money laundering norms and regulations, there are obligations for professionals related to this field31.

31 .FATF Recommendations,33.availablae at http://www.fatf-gafi.org/dataoecd/7/40/34849567.PDF accessed on 19-08-2011.

32 Supra (n 8)239.

33 .Arun Srivastava,Mark Simpson and Nicole Smith, " International Guide to Money Laundering Law & Practice"(3rd ed 2010,Bloomsbury Professional)193-94.

4.2 Layering:

The prime objective of the money laundering is to obscure the original source of the money. Once the money has been placed in any bank or financial institution preferably in a jurisdiction other than local, transactions are made through different channels. These transactions are so complex and random that after a particular time it becomes difficult or impossible to reach the original derivative of the money. These transactions are made among different accounts with different and dummy names of the persons and shell companies in such a way that if there is some investigation, court always finds it difficult to get clear evidence to trail the original source and name. Sometimes the process of layering is so simple. Transactions are made in a parallel way which establishes the mutual obligations among the different account holders. It is just like a "stone gradually dropping to the bottom of a pond"32 means longer the money will remain in the system, more difficult it will be to detect and identify its origin. But important point is that as soon as the money will touch the bottom first time, it is the right time to notice this kind of transaction and reach its trail.

4.3 Integration:

As soon as, the money is placed in some financial institution for a particular time and it has been moved through complex and complicated mode of transactions to make it clean (having no traces of its original source), criminal always try to get this money back to their system, especially the local jurisdictions, with some new background33. This process will require again a series of transactions to get back this ‘clean’ money to original source in such a way that if needed, the original source can describe some of its explanation. Mostly, shell companies and puppet shareholders are used to complete this process same as they are used to place the money in initial stages but at the end, objective of these kinds of activities is totally reverse. 18

This picture shows overall process of money laundering including its all three important stages34.

34 .< http://www.google.co.uk/#hl=en&sclient=psy-ab&q=money+laundering+images&pbx=1&oq=money+laundering+images&aq=f&aqi=g1&aql=&gs_sm=e&gs_upl=2075l6858l0l7217l23l10l0l12l12l0l204l1218l3.6.1l22l0&bav=on.2,or.r_gc.r_pw.,cf.osb&fp=6937bd3c6fe4a933&biw=1280&bih=837> accessed on 14-05-2011.

35 .Financial Havens, Banking Secrecy and Money Laundering, Crime Prevention and Criminal Justice Newsletter(1998)34-35(UN Office for Drug Control and Crime Prevention) available at <http://www.imolin.org/imolin/finhaeng.html > accessed on 19-06-2011.

Figure 2 : Different stages of money laundering

(This picture was taken from the Google source).

5.0 Anti-Money Laundering Measures/Counters:

5.1 Historical Background:

Although the term "money laundering" is not too old in the history of law but it does not mean there was no form of money laundering before the term came out. Law enforcement agencies gave the priority to this term in late 70’s and early 80’s but this was present long before that. It was always there due to political, social, economic or legal bases to hide the money or sources of money35. 19

5.1.1 Ban on Usury Practices:

During Medieval and Roman times, the Catholic Church banned usury declaring it a crime and sin36. Merchants and other people involved in that used this activity to get big interests on loans who were involved in the activities which resemble to move, hide or wash the criminal money in the modern era. The objective behind this activity was to hide the existence of interests or giving them some other form "disguising their nature". This concept was similar to the modern concept of the ‘shell companies’. In that case, capital was used to give to company and then back to original individual in the form of profit (although there was no profit) rather than the agreed interests on the loans given. This practice was there to deceive the Catholic Church as compared to the modern techniques of shell companies to clean money from criminal sources. Compared to today’s offshore jurisdictions, there were also financial havens at that time for the pirates of the Atlantic to receive their money at the start of 17th century37.

36 .Ibid.

37 .Ibid.

38 .< http://www.isyours.com/e/index.html> accessed on 13-07-2011.

39 . BSA (1970)12 U.S.C. §§1829(b), 1951-59(2003); 31 U.S.C. §§ 5311-32(2003).

5.2 First Modern Amnesty to Criminal Money:

At the start of 1612, England offered the amnesty to those pirates who were not any more involved in pirating. They were not only allowed to come back and live safely but they had the right to keep their proceedings of crime. It was announced full pardon for those pirates at that time.

5.3 Swiss Banking Act of 1934:

Switzerland has a history of bank secrecy from the Middle Ages but it was codified first time through the "Banking law Act 1934"38 on November 8th, 1934. In this Act, secrecy in banks of Switzerland was codified. Violation of this Act was criminalized.

5.4 Anti-Money Laundering Measures and USA:

In 1970’s, drug trafficking got attention of the law enforcement agencies. Money derived from drug trafficking activities was used in other criminal activities which got attention of the many nations of the world especially USA. To trace the origins of such money and transactions, USA federal government enacted an anti-money laundering statute named as "Bank Secrecy Act"39 , passed in 1970. This is also known as "Currency and Foreign Transactions Reporting". Through this Act, all the financial institutions and banks were required to keep the record of all transactions. This Act also authorises the "Secretary of the Treasury" to get reports about individuals, institutions and transactions. The rationale at that time behind this record keeping obligation was that these kinds of records are very 20

important and fruitful in tax collecting and other investigation40. The financial institutions were required to keep records of deposit, withdrawal, transfer and money exchange of those transactions which were over the limit of $10,000. Financial institutions were required to report about these transactions as well. The Act presented some regulations for the financial institutions themselves which are/were as follows:

40 .Supra (n 21)963.

41 . Money Laundering Control Act of 1986, Pub.L.NO.99-570,100 Stat.3207-18(1986)(codified as amended in scattered sections of 18 and 31 U.S.C.).

42 .Money Laundering Prosecution Improvements Act of 1988, Pub.L.No.100-690,102Stat.4354 (1988)(codified in various sections of 18 and 31 U.S.C.).

43 .Annunzio-Wylie Anti-Money Laundering Act, 102 Pub.L.No. 550,106 Stat.4044 (1992) (codified in various sections of 12, 18, 31 and 42 U.S.C.).

44 .Money Laundering Suppression Act of 1994, Pub.L. NO. 10-325,108Stat.2243 (1994) (codified in scattered sections of 31 U.S.C.).

45 .Money Laundering and Financial Crimes Strategy Act of 1998, Pub .L.No.105-310,112 Stat.2941, 2942-47(1998) (codified in 31 U.S.C. §§ 5341-42, 5351-52(200)).

(i) Financial institutions were required to establish policies to control themselves internally to ensure BSA.

(ii) Financial institutions were required to monitor the procedure of its compliance with BSA.

(iii) Nomination or designation of a responsible person to supervise the compliance procedure.

(iv) Financial institutions were required to train their staff so that they can comply with BSA.

The BSA is also known as "anti-money laundering" Law. It is also stated jointly as "BSA/AML". USA was the first country in the world to take direct measures against the money laundering.

After BSA, following Acts were also enacted in USA to counter money laundering and combat against finance of terrorism;

ï‚· Money laundering Control Act 198641.

ï‚· Money Laundering Prosecution Improvements Act of 198842.

ï‚· The Annunzio-Wylie Anti-Money Laundering Act 199243.

ï‚· The Money Laundering Suppression Act 199444.

ï‚· Money Laundering and Financial Crimes Strategy Act 199845.

ï‚· The USA PATRIOT Act 2001. (Known as "Patriot Act" was enacted after the tragic incident of 9/11. This stands for "Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2011").

The tragic incident of 9/11 changed the direction and focus of money laundering all over the world in general, In USA particular because USA was the victim of that incident. So focus of money laundering was shifted from drug trafficking to financing of terrorism and USA 21

e for criminal activities or not.

11.4 Critical Evaluation of the AML Act 2010 in Pakistan:

Pakistan passed its first Act related to money laundering and financing of terrorism to enact all the recommendations of the FATF in 2010. The main feature of this Act was the establishment of the "Financial monitoring Unit". Although it has been declared that unit will work independently but the problem is there are so many other institutions involved in investigation about the suspicious transactions or money laundering case. For example, FIA (Federal Investigation Agency) and NAB (National Accountability Bureau) are two main institutions that work to investigate any suspicious case but unfortunately both these institutions are under the Ministry of Interior and minister for this is always a politician who has the authority to appoint the chief in FIA. So a politically motivated chief can never investigate cases against its own government or people affiliated with the government. Same is the case with the NAB, whose head is also appointed by the Head of the State (Recently appointed by Sitting President who has severe charges of Money Laundering). So how a politically appointed head can work against his own appointing authority? Pakistan is in a transition phase of development in every aspect. Institutions are not much strong like in Europe or other developed countries and data sharing mechanism is also very poor among institutions.

Pakistan is a multi-ethnic Islamic country with a big network of Islamic education institutions called Madrassahs. The funding to these Madrassahs is always from people on the name of Islam. So it is really difficult to suspect and stop this funding in terms of suspected use in criminal activities. It is also very difficult to know the intentions of donator and intentions of recipient.

Charities are also another important factor in the Pakistani society. People give donations/charities and Zakat (Basic Part of Islamic religion) to poor and Madrassahs which make it more complicated to implement the legislation of anti-money laundering and financing of terrorism. Unless it is proved that their intention is to finance terrorist activities, it is almost impossible to stop these people to give donations181. Same is the case with all other Islamic countries as well.

181 Supra (46) 657.

People of Pakistan are not enough educated and infrastructure in Pakistan is not up to date in every town and village. Millions of Pakistanis are working overseas including Europe, USA, UK and Arab countries. They are sending money through these Hawala institutions because they are quick in service, cheaper and trusted to those people living in 54

the remote areas of Pakistan. Although SBP has started to register these institutions but still there are a lot of illegal working in different cities and towns. It is very difficult for investigating authorities to monitor and control all the Hawala transactions.

Pakistan has a special geographical location. Russian entrance in Afghanistan started a holy war "Jihad" against Russians fully funded and helped by CIA of USA. USA herself trained and gave money/weapons to these groups to fight against Russians. Russian left the Afghanistan and these groups came in power names as Taliban (Now Terrorist Groups announced by USA). These groups are fighting in Afghanistan against USA and have suspected links with Al-Qaida as well. Pakistan’s borders with Afghanistan are vulnerable for these groups. Heroine is a big product in Afghanistan and money gained by this is laundered and used in terrorist activities (suspected).

Corruption has been a big problem of Pakistan. A lot of Pakistani politicians, Government Officers and other individuals gained money and put them in the European and UK institutions through money laundering but these countries are facilitating them through their banking laws. These countries always welcome those even exposed persons to invest in their countries and have safe havens for their illegally gained wealth.

12.0 Practical Suggestions:

(a) Although there is no single treaty to counter ML and FT among all the member states of the UN and there is no single institution to coordinate among all the member states of the UN but world has woken up to counter ML and FT and this can be done through more cooperation among the intelligence units of all the member states of the UN.

(b) There is a dire need to stop the practice of "crying wolf" in terms of reporting. This can be done by reducing the fines and penalties on the financial institutions if they are unsuccessful to report any suspicious transaction. Banks should not be criticized before checking whether the bank or institution intentionally ignored the reporting or it was a mistake. At the same time, to reduce the reporting, there can be a minimum fee for reporting each suspicious transaction to the investigating institutions.

(c) There should be a list or minimum risk or zero risk customers in every institution to avoid the "know your customer" practice even for those clients who are running their accounts for several years or who are aged enough.

(d) There should be a wider and complete definition of terrorism and terrorist activities through the platform of UNSC and this definition should have consensus from all the member states.

55

(e) There should be a strong network to share intelligence reports among all the member states to counter ML and FT. Currently this network is very poor and not sharing all the data and information on several bases.

(f) Corrupt persons, institutions and their secret accounts should not be welcomed by any jurisdictions. Rulers from third world countries who have their looted wealth in Europe should be exposed and there should be a mechanism to return this wealth to original source/country.

(g) There should be a moderate policy toward Islamic institutions in terms of charities. To distance them from Western society will create more problems for the world. Institutions involved in criminal activities can be deregistered and can be banned from working but after complete investigation and proof.

(h) FAFT is a soft law and does not have the authoritarian nature, not binding to all its members. The mechanism to change this soft law into hard law by implementing in the domestic law of every state should be faster and transparent.

(i) Along with anti-money laundering law, there should be anti-corruption law at universal level as well. There should be a body like FATF who can give guidelines on anti-corruption law to its member states because the wealth gained by corruption is always used in money laundering.

(j) Corporate sector cooperation is also very important to reduce the chances of ML.

(k) With the technological development, money launderers have developed more sophisticated ways to launder money. So investigating agencies also need to use technological assets to counter them.

(l) Although most members of the UN are adopting the UNSC resolution and FATF Recommendations but there are some countries who are creating problems for the development of an international anti-money laundering law by their policies and secrecy laws. There is a need to keep those countries with in the sphere of the UN to cooperate with other countries to counter ML and FT.

(m) There should be a strict policy during the recruitment of staff of financial institutions. No temporary staff should be allowed in financial institutions.

(n) Good training to staff and people working in those institutions which are working against ML and FT will prove very healthy.

(o) Complete data of customers, their identifications, record of transactions analysed at central point will help effectively.

(p) In third world countries like Pakistan, loopholes in law should be removed to tighten the circle around the criminal.

(q) In countries like Pakistan, families related to extremist groups can be monitored to trail the original source.

56

13.0 Conclusion:

After having all these conventions, resolutions, recommendations, directives and laws related to ML and FT, reports show that billions of pounds and dollars are laundered every year and world is facing the threat of terrorism as well. It is difficult to eradicate both problems but rules and laws can be made tough for criminals and criminal activities to minimize them and this is only possible through cooperation among all the member states of UN, their financial institutions. A strong, wider and effective central intelligence sharing institution can help to counter them more effectively. Help from corporate sector, financial institutions, professionals and agencies working to counter ML and FT is also needed to combat this problem. A strong international anti-corruption law will reduce the chances of ML of looted wealth. A comprehensive mechanism and cooperation from all the players involved will make situation better and we can lead to the financial structures having no fears of manipulation and destabilization through ML and FT. 57



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