Corruption generally involves people in position of power abusing their position to self enrich at the expense of the public good. To mitigate risks of corruption related funds getting laundered through banks and financial institutions, it is necessary to identify Politically Exposed Persons to calibrate risk management, mitigation and monitoring efforts.
Refer to the Practitioner's Guides for Due diligence on PEPs and other measures.
Methods
In a corrupt deal, once the public official is in receipt of the funds or assets obtained in exchange for misusing the power of his office, he then uses one or more methods listed below to disguise, hide and launder the funds to avoid the scrutiny of law enforcement and escape the consequences of violating public trust.
- Use of third parties: Corrupt officials often use close relatives and associates to launder illicit funds and conceal ownership of funds and assets. Relatives and associates may launder illicit funds by undertaking transactions and purchasing assets on behalf of the corrupt official. Their names are often recorded on properties, trusts and accounts controlled by the corrupt official in order to distance themselves from illicit funds and avoid detection from authorities.
- Use of professional facilitators: Corrupt officials often use professional facilitators such as lawyers, accountants, real estate agents and service providers to launder illicit funds. Professional facilitators provide specialist knowledge and advice to establish corporate structures and trusts, buy and sell real estate and manage a client’s finances. This enables the corrupt officials to distance themselves from illicit funds, evade tax, legitimise funds and evade detection by authorities. The professional facilitator may be an unwitting participant in the lawful activity or may be reckless to the suspicion of illegal activity. In some cases professional facilitators may derive financial benefit for providing knowledge and assistance.
- Use of corporate vehicles and trusts: The Panama Papers and international case studies have highlighted the use of corporate vehicles to disguise illicit funds obtained by corrupt officials. Trusts, shell companies and corporate structures established either onshore or offshore are often held in the names of friends or relatives of the corrupt official.
- Use of international funds transfers: Illicit funds are commonly transferred overseas in small amounts to avoid detection and transaction threshold reporting requirements. This method is referred to as structuring.
- Another trend in international funds transfers is cuckoo smurfing. This involves transferring illicit funds through the bank accounts of innocent third parties. Money remitters are often used to transfer legitimate funds as a cheaper alternative to using mainstream banks. The money remitter gives details of the transaction and the intended recipient to a criminal syndicate who then transfers illicit funds to the innocent third party. The money remitter then pays the legitimate funds to the criminal, successfully laundering the money.
- Bribery through services payments: Foreign bribery payments can be concealed by trade in services payments to give the appearance of paying a legitimate company for services rendered. Companies linked to, or controlled by corrupt officials are often hired for services such as ‘consulting’ and paid through fraudulent invoices for non-existent services. A legitimate third party service company can also act as an intermediary for the bribe payments by inflating invoices for services rendered and then channeling the difference to accounts controlled by corrupt officials.
- Falsifying documents, invoices etc.: Another method of concealing bribery payments is to set up a false supplier for the purpose of issuing fraudulent invoices to receive payments. The payment is then refunded in cash which can be used to make the bribe.
Corruption Studies and Statistics
Source | Reports |
OECD | OECD Anti-Bribery Typology Reports |
Stanford Law School—FCPA Clearinghouse | Stats on DOJ and SEC Enforcement Actions |
UNODC | Corruption statistics |
Transparency International | Transparency International Corruption Perception Index 2019 |
TI compilation of Corruption statistics | |
World Bank | StAR Corruption Cases Database |
Our World in Data | Corruption Visualized: Indices and other statistics |
Department for international Development | Why Corruption Matters: Understanding causes, effects and how to understand them |