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International Money Laundering Information Network

The International Money Laundering Information Network (IMoLIN) is a non-profit web-based network which assists and cooperates with governments, organisations and individuals to provide knowledge and promote Anti Money Laundering activities. This global website consists of information regarding laws and regulations of financing terrorism and contacts for assistance within countries, these Legislations across the globe are stored within a database, as well as an annual event stored on a calendar within the anti-money laundering field.

"Money Laundering"

This multi-faceted website also suggests ways to improve, especially in regard to; involvement of domestic laws, countermeasure and worldwide co-operation. These types of information are widely and freely available to all internet users. However, in regard to Anti-Money Laundering International Database (AMLID) , these data are considered private files which the public cannot gain access to.

History

IMoLIN was founded in 1998 by the UN, established through combinations of various anti-money laundering organisations across the globe. In particular, the Global Programme against Money laundering, Proceeds of Crime and the Financing of Terrorism (GPML) of the United Nations Office on Drugs and Crime (UNODC) had a substantial involvement in the maintenance and regulation of IMoLIN.

In the first half of 2004, GMPL performed an extensive remodel of the website’s appearance and its functions were updated alongside its content ensuring it was compliant with UNODC’s IT section. Later on, In April 2005 AMLU analysed the following round in the review of the implemented questionnaire mentioned. Following year later in February 2006, the UNODC launched the AMLID legal analysis the second time.

Partner Organisations

The GPML of the UNODC being the administers, involves the maintenance of this website – IMoLIN. The administers maintain in the interest of the following eleven partner organisations:

• Asia Pacific Group on Money Laundering (APG)
• Caribbean Financial Action Task Force (CFATF)
• Commonwealth Secretariat
• Council of Europe - MONEYVAL
• Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG)
• EuroAsian Group (EAG)
• Financial Action Task Force (FATF)
• Financial Action Task Force on Money Laundering in South America (GAFISUD)
• Inter-Governmental Action Group Against Money Laundering in West Africa (GIABA)
• Interpol
• Organisation of American States - Inter-American Drug Abuse Control Commission (OAS/CICAD)

Key Features

Within the IMoLIN site there is a AMLID section, this section includes a multilingual database (English and French) and has a compiled analysis of money laundering laws and regulations across almost every nation. There is involvement of two classes of anti-money laundering control measures:

i. Domestic laws

ii. International laws

The IMoLIN has a feature of the AMLID questionnaire, which is put in place to for updates in new anti-money laundering statistics, such as terrorists financing account provisions and current trends like the revised FATF 40 Recommendations. Additionally, this questionnaire includes a section called – Conventions Framework, it involves overviews of the current state of a nation to the international conventions relevant to the anti-money laundering and the financing of terrorism (AML/CFT).  

A national legislation section is also included, it involves an interactive click on map which consists of the regional lists within that of that nation’s legislations. Currently, this database contains legislations from 163 jurisdictions and as of 2005, greater than 250 altered AML/CFT laws were also placed into the database and eventually this section will consist of the entirety of links and full texts of the anti-money laundering of terrorism (AML/CFT) regulations worldwide.

Moreover, worldwide events noted within a calendar includes lists the mentoring events and conferences occurring currently from various levels – regional to international.   

Finally, there is a section dedicated to the references and links to the websites of related organisations; with detailed to the UN’s most recent findings, abstracts of the most relevant research from government and international organisations.

Case Law Database

Within this section, it includes the 76 cases regarding situation which involved the crime – money laundering. Each section includes: the date, facts of which took place and the main issue of each case. These cases assist in conciliating the knowledge from money laundering methodologies and applies to real situations and sentencing.

There are several sections, organised into the type of case:

• Decision/Verdict Date
• The Legal System - Civil Law and Common Law
• Latest Court Ruling - Appellate Court and Supreme Court
• Liability for/based on/involvements
• Offending details

eLearning Resources

Within this website, there is a section dedicated to learning about this money laundering crime. It is linked directly to the United Nations Office on Drugs and Crime (UNODC), more specifically on the Anti Money Laundering eLearning Course (AML).

This Program was launched in early 2016, however, currently only available for registration by Member States’ users. This AML course consists of 13 modules and an extensive eLibrary, and module involves: 

• Understanding AML
• Traditional financial institutions
• Non-traditional financial institutions
• Money laundering havens
• Financial intelligence unit
• Financial records
• Informants
• Undercover operations
• Net worth analysis
• Search operations
• Financial interviewing
• Finally, laundering methods

Money Laundering Methodologies

A frequent reoccurrence with how money laundering methods are formed are derived from the careful analysis of case studies. Based off of these methods, further illustrations of case studies were in use.

In Australia, the common methods illustrated from case studies are:   

• Betting Accounts   
• Domestic Electronic Transfers   
• False and Fraudulent Identification   
• Gatekeepers
• Wire Transfers   
• Finally, cash being the most frequent money laundering methodology.

Cash

This method still remains the most frequently adapted within the money laundering process, derived from the above-mentioned case studies worldwide.

It involves profits in forms of “fake cash” made from criminal activities which requires re-introduction to the mainstream financial system to appear legitimate. In other words, this method involves three steps to disguise the illegal profits for them to become usable:

i. Placement of the money, introducing it into the financial system in various ways (e.g. investments, deposits etc.)

ii. Layering, where the profits are spaced and shuffled around; thus, having them distanced apart

iii. Perpetrators, through the integration the money is then brought back into the perpetrators hands to then become legitimate profits; or “clean” money.

Electronic Transfers

Electronic transfers are another common money laundering method. This method is increasingly becoming the more popular form of money laundering criminal activity, as the involvement of banking transfers are related to the internet/technology. Several forms under electronic transfers are used, these include: The use of legitimate, cash-based businesses which are owned by criminal organisations. These types of operations are frequently referred to as “fronts”, these fronts are a gateway for the illegal profits to funnel in through the business and into their business’ bank account. Which then is processed through as legitimate funds and are withdrawn out again.

Another popular form of money laundering through electronic transfers is known as “smurfing” or “structuring”. This involves the large illegal profits to be broken up into small deposits, these funds are deposited into multiple banking accounts in avoidance of red flags. Further, deposits of large illegal funds can be wired across borders and placed into foreign accounts where the anti-money laundering enforcement are not as firm. An example of where the use of electronic transfers for money laundering is seen through the catastrophic events in the United States on September 11, 2001 (9/11). This traumatic historic event based on a 2005 PBS Frontline investigation, was funded through Islamic charities in Europe and the U.S. which was laundered through the European banking system to further clean their money to plan the devastating event. The 9/11 attacks were allegedly half a million USD.

Technology's Impact on Money Laundering

Technological advancements in our digital society have grown in vast ways and continue to increase, and as it does so, criminals are continuously discovering creative ways to exploit new technologies to launder their illegal profits. Where there is money tied with criminal activity, there is the need to legitimise/clean the money to be moved throughout the world’s financial system, with little to no red flags detected.

With the internet becoming a part of everyday life, it has “updated” old ways of banking transactions through applications of banking online. Online banking has risen with popular institutions, this allows anonymous payment services and transfers within these applications on mobile phones. This updated way of banking has major weaknesses in detecting illegal transfers of profits. In conjunction with other software, this makes the detection of money transactions almost completely anonymous. This is due to third party intervention/integration with the use of proxies to anonymise the detection of IP addresses, which are used to transfer money.

This observation is derived from several cases across the globe. In early 2003, there was the largest money-laundering bust in U.S. history involving allegedly $6 billion USD. This event occurred arresting seven people involved in a cyber-crime operation which consisted of an online bank for criminals which dealt with drugs, identity theft, and the list goes on. This online bank connected through the anonymous exchange of digital currencies to “legitimate” illegal profits.

This increasing issue of money laundering tied with advancements in technology prompted an announcement in late November 2012 by the U.S. Treasury’s Under Secretary for Terrorism and Financial Intelligence, David Cohen. In just over a year from the 9/11 attacks, David stated, “Money-laundering schemes themselves are also becoming increasingly sophisticated and international in nature. The same hugely beneficial technology and financial advancements have had the unfortunate side effect of amplifying potential AML [anti-money-laundering] risk.”

Prevention of Money Laundering

Anti-money laundering laws are still currently heavily focused on the detection of “dirty profits” through traditional ways in depositing into banking institutions. With technological advancements, it has become increasingly difficult to catch up to these crimes taking place digitally. With this digital age, there is a greater urgency for the destabilising of the financial health of nations worldwide, in particular countries with ineffective or intentionally loose financial controls. These ineffective, intentionally loose financial controls put in place for the benefit of the criminals, involved in money laundering tactics. Through the concern of cancer-like impacts which money laundering can have on broader financial system, government officials across the globe have come together to provide preventative measures on this continuous rising issue.

Regulations in partnership with financial institutions occurred in recent decades, in efforts to incorporate systems in the detection and reporting of sceptical activity. Shortly following the 9/11 terrorist attacks, the USA Patriot Act extended their law by applying investigative tools; these tools adhering in terrorist cases.

Banking

Bank institutions have increased their protocols in anti-money laundering and have adapted a three-pronged strategy to check money laundering; alongside fraud.

These include:   

• Profiling
• Transaction monitoring
• Database match

Technology

There are numerous challenges with the sophistication of money laundering activities in conjunction with technology, however, there are also technological advancements tools to prevent these situations from going out of control. These tools put in place to promote anti-money laundering include:

• The ability to process large data on screens, in order to detect trends.
• Greater data visualisations to assist in identifying links between accounts.
• Statistical modelling tools, for predictive measures viewed by clusters in dataset.
• Unstructured data assessment, through tools to trace digital footprints in criminals which do not offset this through third party interventions.
• Finally, through the development of regtech and edutech for e-training and development for the workforce.

Non-profit organisations such as the International Money Laundering Information Network, alongside numerous online websites are another method which are now readily available worldwide due to the internet. Now more than ever there is information stored online, in databases. IMoLIN in particular has stored information which is put in place for the general public as well as professionals with the goal to prevent money laundering.