Tom was a member of the Chamber of Deputies in his home country. He was able to support his family on his modest government salary until he began to develop a severe gambling habit.

Increasingly in debt, and increasingly desperate for money, he formulated a plan to make him rich enough to carry on gambling indefinitely. As a project planner within the Ministry of Finance, he had the power to propose and approve schemes in a specific sector of the annual public works budget.

It occurred to Tom that offering to approve schemes in return for a small monetary gift was an ideal solution to his money problems. Unsurprisingly, a number of businessmen were willing to pay him well for the guarantee of government business, and Tom became rich very quickly through his corrupt activities.

Tom’s friend Gina, who owned an exchange and tourism-company, was willing to help him launder the bribes that he was receiving. She used her employees as ‘straw men’ to create a number of different bank accounts through which funds could be laundered - more than USD4,000,000 was laundered in total through such accounts. However, the cash payments and subsequent transfer offshore risked attracting attention, and so Tom developed a more sophisticated laundering method - a fruit-delivery company. This company, which was owned by Gina’s husband, laundered USD2,700,000 in three months, disguising the transactions by creating false invoices which, were settled by the businessmen on Tom's instructions.

In this way, there was no direct link between Tom and the corrupt payments, and the businessmen had invoices to justify the payments should any questions be asked. The fruit company could then transfer the funds offshore as ‘settlement’ for fruit importation, attracting few suspicions.

However the earlier transactions had not remain unnoticed by the financial institutions involved. In view of the unusually large amounts of cash deposits and the rapid offshore transfers - especially in view of the declared low-income employment of the account holders - the institutions decided to disclose to the national FIU on a variety of accounts.

Following analysis by the FIU, the police had obtained a clear understanding of Tom and his corrupt activities, and have instigated a full investigation. Enquiries showed that Tom had used assessors of the House of Representatives to assist in the approval of his schemes. One assessor, who did not have any involvement with the criminal operation, had had his signature counterfeited to obtain the necessary authorisation. Another assessor had helped Tom by visiting the exchange and tourism company and receiving cheques in his name. After receiving the cheques, the assessor deposited the money into one of Tom’s accounts .

At the time of writing, the police were trying to link the corruption inquiry into another case currently before the Supreme Court. The total amount of money Tom laundered was estimated to be in the region of USD1,000,000,000. It is worth noting that the disclosures by the institutions took place because of the simple initial laundering scheme, whereas the later scheme involving an established company appeared to have had little risk of disclosure.

Indicators :
Large - scale cash transactions
Rapid off shore transfer after funds deposited
Unrealistic wealth compared to clients profile