Money Laundering

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An investigation of a high-risk geographical location can sometimes uncover assets which have been hidden through: nominees; shell companies; cash couriers; wire transfers; credit cards; informal banking systems, etc.  For example, one way the IRS focuses on high-risk locations like tax havens, is to compare the banking information it receives from the Financial Crimes…

I. NOMINEE BANK ACCOUNTS

Beneficial owners can try to use a nominee, (i.e. intermediary/straw owner), to hide money with complete anonymity in a bank account. Through websites like Offshore-Protection.com beneficial owners may purchase a shell company and retain a nominee director for the shell company.  The beneficial owner may then title a bank account in…

“I’m out of the asset forfeiture business and Title-III wiretaps too”, Donnie remarked as we discussed the Drug Enforcement Administration’s on-going effort to find hidden assets related to drug trafficking and other crime.  Donnie had retired from the DEA after serving twenty-one years as a Special Agent.  Now he was deployed to the…

A former Criminal Intelligence Specialist at Scotland Yard confirmed that the divorcing husband was hiding millions from his wife by using bank accounts in Switzerland.  The husband’s true beneficial ownership of these funds had been concealed by a nominee (i.e. intermediary).  This nominee had opened the Swiss bank accounts in the names of shell corporations…

People don’t typically think of the common money laundering indicia when searching for hidden assets the subject of a: divorce; bankruptcy; commercial collection or other legal proceeding.  Such indicia can be effectively used as part of an asset search / recovery effort even in situations where there is no money laundering.  In the United States,…

In the United States, the Financial Crimes Enforcement Network regulates the customer identification procedures, (a.k.a  “know your customer rules”), at banks.  In order to clarify these procedures, the Financial Crimes Enforcement Network issued guidance in January 2004.  These customer identification procedures codified at 31 C.F.R Part 103.121, demonstrate  that there is no discretion…

An asset search covering a number of countries is sometimes necessary if monies the subject of a divorce, bankruptcy, or debt collection proceeding are hidden in a money laundering circuit. This can be true because “[l]arge-scale money laundering schemes invariably contain cross-border elements,” as mentioned by the Financial Action Task Force’s webpage.

Domestic…

Money laundering circuits sometimes operate in the U.S. through domestic bank accounts used as “laundering links”.  It is also true that money laundering circuits washing vast sums of money, will typically do so through offshore bank accounts located in tax havens like Switzerland, Luxembourg, the Cayman Islands, etc.  Such was the case of one divorcing…

The Financial Intelligence Units of the Egmont Group, exchange information worldwide to track terrorist financing and fight crimes like money laundering.  Their exchange of information occurs pursuant to the Egmont Group’s Principles for Information Exchange (June 2001) and Best Practices for the Exchange of Information (updated June 2004).  Sometimes Financial Intelligence Units (“FIU’s”) share information…