During an examination of a company’s export reports, a bank employee detected some questionable transactions in four connected bank accounts. Fifteen different companies deposited their export profits into one of these accounts. The bank employee believed that these bank accounts could be connected to money laundering, and filed a report with the national FIU.

The national FIU initiated an investigation into the fund movements. During the investigation, an analysis of the records indicated that nineteen more bank accounts were related to the four disclosed accounts. The account owners did not appear to have any legitimate relationship with the companies that were performing transactions through these accounts.

In fact, these twenty-three bank accounts, located in seven different banks, were managed and used by a single individual - Gilbert. Varying identities had been used to open the accounts, but Gilbert used all twenty-three accounts to perform transactions for several companies. The real account holders were serving as figureheads. They signed blank sheets of paper that Gilbert used to carry out bank transactions.

Using these accounts, Gilbert was transferring large amounts of money to companies in a number of different countries. Enquiries at these companies revealed that the transferred money served as payment for goods sold. Yet no official records about the supposed trades were discovered. The national companies were importing the goods without paying tax. By using Gilbert’s services, the money paid for the goods was not clearly linked to the companies, facilitating the tax avoidance scheme.

However, that was not the only service that Gilbert was providing. He also seemed to be involved in gold smuggling. Some of the companies for which Gilbert was handling the finances supplied gold to the national market. The records showed that the gold was sold to the national market. Even transactions in the accounts, managed by Gilbert, seemed as if they related to the national gold trade. But the gold was actually sent to a neighbouring country. The suspicion arose that the gold was being smuggled via the neighbouring country to another country in the Asia/Pacific Region and used as payment for heroin shipments. Last but not least, Gilbert used the accounts to deposit cash or cheques. He claimed these to be exportation equivalents, which belonged to several export companies. However, investigation showed that there wasn’t any exportation performed by these companies. The considerable number of cheques came from unknown sources. It was estimated that these cheques originated from drug trafficking activities. By depositing them as exportation profits, the cheques were injected into the legal economy as if they were legitimate proceeds.

Because of the information the FIU gathered, the public prosecutor charged Gilbert and four accomplices with money laundering offences. At time of writing, the trials were still ongoing. The FIU is also undertaking a larger investigation into those financial institutions which made no disclosures in relation to the sizeable funds flowing through their accounts despite what appear to be suspicious circumstances.

Indicators:
Unconnected companies channelling funds to a single account
Use of accounts by apparently unconnected third parties