The Egmont Group is an association of Financial Intelligence Units with a global membership. Although loosely associated with the FATF, it is not a policy making group, but rather a mutual assistance group. Members agree upon information exchange and other inter-agency issues, internationally.

For a number of years, when the number of members was small, the Egmont group was an informal association that met and operated on a very "chummy" basis. But more recently, as its membership and importance has grown, it has acquired a permanent home and a secretariat - and even a website.

The Egmont Group's "sanitised" case studies are expressed to be in the public domain. Although we have added titles to the cases, we do not claim any property in them. The original "100 Sanitised cases" were available only in pdf format in a single document. Quick To Learn More converted them to individual, quick-loading html pages for our users as a free resource. Since the launch of the original 100 cases, a small additional number have been added, again in pdf format, and we have added those to the html collection for ease of reference.

The "sanitisation" means that all names have been changed, that some facts have been changed, that locations of offences have been changed.

For more information on The Egmont Group, visit http://www.egmontgroup.org.

For more information on Quick To Learn More Anti Money Laundering Training, visit www.quicktolearnmore.com.

For more information on the work of The Anti Money Laundering Network, visit www.antimoneylaundering.net

Introduction to "FIUs in Action" - the original 100 sanitised cases

In 1999, the Egmont Training Working Group undertook an initiative to draw together a compilation of sanitised cases about the fight against money laundering undertaken by the Egmont Group member FIUs. The compilation was to reflect in part the Egmont Group’s fifth anniversary in 2000. We are pleased that almost every member FIU contributed at least one case. We would, therefore, like to thank all members for their co-operation. Without such efforts we would not have been able to produce the compilation.

Our special thanks go to Gavin Coles (NCIS), Joanna Brown (FinCEN), Liesbeth Nieuwenkamp (MOT) and Gonnie van Dijk (MOT), who comprised the editorial team and drew the cases together into one unified text.

Mr. Andrew Blezzard, Chairman Training & Communication Working Group [Head of the Economic Crime Unit at the UK's National Criminal Intelligence Unit ]

The first typology is typified by laundering schemes that seek to conceal criminal funds within the normal activity of existing businesses or companies controlled by the criminal organisation. Attempting to move funds through the financial system by intermingling them with the transactions of a controlled existing business has several advantages for the launderer.

Firstly, the criminal has more control over the company being used, either by beneficial ownership or a close relationship with the actual owner, which decreases the risk of information being passed to law enforcement from within the company itself.

Secondly, the financial institution through which funds are passed may well view sizeable fluctuations in account activity with less suspicion than similar activity on a personal account, as most financial services staff expect some increases and decreases in business cycles .

Thirdly, businesses often have legitimate reasons for fund transfers to or from other jurisdictions, and in different currencies, which further decreases the level of suspicion at financial institutions.

Fourthly, a number of businesses - such as nightclubs and restaurants - deal mostly in cash, and financial institutions are less likely to view large cash deposits with suspicion.

Fifthly, the links between the criminals and the company can be concealed by means of company ownership structures, whereas with a personal bank account specific identification documents for individuals are often required by financial institutions.

Lastly, the cost of company formation in some countries can be only a few hundred dollars, and a number of company formation agents exist worldwide that can facilitate company creation and management even for criminals with minimal professional experience of such matters.

Of the one hundred cases, the largest subsection of cases fell into this category, representing the attractiveness of company structures to the launderer. One of the problems for launderers reported across a number of cases seemed to be that the creation of a new company and subsequent rapid increase in business sometimes triggered disclosure to t h e national FIU by financial institutions. The risk exists that other launderers may seek to use long-existent companies owned by associates, believing that financial institutions may be less likely to view long standing business customers as possible concerns.