Author: Aleksandra Richartz, Director – LuxFin Advisory
In Europe, 80% trafficking occurs mainly for the purpose of sexual exploitation of women and girls and forced labour. Traffickers seem to commonly use victims to perpetrate their laundering operations.
We have conducted research on Money Laundering relating to People Trafficking. We have identified a significant number of key indicators that are recognized within banking data, transactions, and profiles from many years of investigations and experience. We have examined many data sets and trafficking individuals and we highlight some of those indicators in this article.
The traffickers / smugglers have great use of cash-intensive businesses, money service businesses, cash couriers, Hawala (informal banking) systems, front companies, and investments in high value goods such as cars and real estate.
Three patterns often emerge:
- Money sent back to the country of origin of the traffickers where it is often invested in legal businesses such as restaurants, bars, or properties such as apartments or houses.
- Money used both in the country of origin and the country of destination to support a lavish lifestyle for those involved.
- Money invested in other criminal or legitimate activities in the destination country.
The indicators we have identified occur within a customer profile, for example:
- Unexplained/unjustified lifestyle, mismatch between amounts paid and the occupation of the person.
- Unexplained/unjustified large profits for a company, and of course the significant use of forged documents.
For Money Service Business, we have identified that transfers of cash in small amounts, structuring funds below threshold, repetitive transfers of like nature, transfers to sensitive countries of destination, transfers from different regions to the same persons or same beneficiaries.
As regards the use of companies and business often the criminals will incorporate illegal funds into the as a cash intensive operation such as a bar or beauty salon. That in turn makes the financial turnover incommensurate with the commercial turnover. This is best recognised by the company balance sheet showing assets in cash and profits with no legitimate trade justification which, in itself, is good evidence of criminal money laundering behaviour.
Other methods include structuring via commercial entities and transfers of money using contracts for loans, as well as the use of fictitious loans where loans are provided by a shareholder to the related legal person and subsequent transfer back. This is a common favourite among Organised Crime Networks in Europe.
The use of intermediates or third parties are often used to execute various transactions within a banking system using a wire transfer service, where a third party participates in a transaction and frequently takes a superior position (money distributing or trading) or where the criminals use of the victims to execute transactions such as opening an account in the name of an unqualified minor.
Whilst for Financial Institutions the indicators can vary depending on the type of account, and the account activity. We do see clear patterns emerge. For example, transfers followed by cash withdrawals, the use of fictitious loans, proceeds used to guarantee loans later repaid with the same proceeds, or the use of fictitious donations. Criminals like to flaunt their wealth with investment in high value goods, or frequent real estate deals carried out by straw persons often with the use of cash for real estate deals and payment of the mortgages.
A girl or woman working for a criminal network in Europe can start at about 100,000euro per year from prostitution, however as she is under control of the gang, she is a much more valuable asset. She may have credit cards, bank loans, and government funds/state aid as well as a car or other assets in her name that she is completely unaware of.
And whilst many are aware that they are trafficked for the purpose of prostitution it is the control that the gang exerts on them, their families and friends that makes the process dangerous. They become dehumanised and commercialised, they are a commodity to be exploited, and whilst for many of us the concept is abhorrent and distasteful for some it is just a business enterprise.
Featured photo by Alycia Fung, Pexels.