FINANCIAL Action Task Force (FATF) considers business relationship between a
politically exposed person (PEP) in a country with foreign PEPs to be inherently
high risk from the standpoint of laundering corruption proceeds.
In a
Paper captioned ‘Specific Risk Factors in the Laundering of Proceeds of
Corruption- Assistance to Reporting Institutions', FATF says: “any accounts
beneficially owned or controlled by foreign PIP should be considered to be
subject enhanced scrutiny under its anti-money laundering (AML) and countering
the financing of terrorism (CFT) recommendations.
FATF
says entities such as banks that are required to file reports under AML/CFT
framework must be capable of detecting and investigating a wide-range of
potentially suspicious transactions. “They must be able to do so regardless of
whether a party to the transaction has been identified as PEP.”
Corruption-related money laundering can use many of the same techniques
as other types of money laundering, particularly the use of corporate vehicles
and trusts, gatekeepers, nominees and family members and cash.
Reporting entities must be on the lookout for those patterns present in
typical money laundering: transactions that vary from those the clients would be
expected to make, that appear to be lack a legitimate business purpose, or are
by their very nature higher risk, the paper says.
Any
transaction which appears to be overly and uselessly complex, with an unclear
economic purpose, involving multiple parties or tools – such as multiple
corporate vehicles or transactions involving multiple jurisdictions for no
apparent economic purpose - should be probed further, it adds.
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