A national FIU in Western Europe received a suspicious transaction report from a bank concerning a wire transfer of USD2,500,000 into the account of a Swiss trust company. A bank in a major European financial centre had issued the wire transfer, and the sender was a man with an Asian name. At the same time the bank account was debited by a cash withdrawal of almost USD100,000, as well as by a number of wire transfers to various individuals via bank accounts in different Western European and American countries.

No explanation was given for the movement of this large amount of money or the subsequent ‘splitting’ of the funds to the various individual accounts. Beginning with this information the FIU started to make inquiries and learnt that the individuals acting on behalf of the trust company which had receives the funds were Debbie and Harold, two citizens of a Western European country. Debbie was already known to law enforcement for involvement with illegal prostitution, fraud, and falsification of documents, and Harold had been involved in a money laundering inquiry conducted by the police in his home country in 1995. Through the Egmont group, the FIU contacted other national FIUs in Europe and America with a view to exchanging intelligence on the case. These FIUs were able to provide extensive intelligence concerning Debbie and Harold.

A European FIU also provided the requesting FIU with information about two possibly related wire transfers of USD40,000 to Derrick, which had been disclosed to them by an institution at around the same time. Derrick was a citizen of the same country as Debbie and Harold, but he lived on a Mediterranean island. The FIU learnt that the bank account on the island had been opened by a wire transfer of USD50,000 from a city in Eastern Europe. The FIU also learnt that Derrick was known by the local police for involvement in minor fraud schemes and falsification of documents.

At the same time, the enquiring FIU received information from another European FIU concerning the sender of the initial USD2,500,000 - a Mr. Chang. Mr. Chang was originally from Asia but had established himself in a large European financial centre. The money had been transferred from one of his bank accounts after being credited by a wire transfer from America via Asia. Harry, a citizen of the same European country with a long history of criminal activity, had been the individual who had actually sent the funds. An American FIU informed the requesting FIU that the USD2,500,000 had originally come from Chang’s bank account in an Asian city. The Asian police informed the inquiring FIU that Chang’s bank account currently contained just USD80,000.

At this stage, the FIU referred the case to the public prosecutor, requesting that he restrained the remaining moneys in the account on which the inquiry first started, which he agreed to do. At the time of writing, the police in the country where the inquiry was being conducted had taken Debbie and Harold into custody. Debbie and Harold are awaiting trial on charges of laundering the proceeds of fraud.

Indicators:
Atypical or uneconomical fund transfer to or from foreign jurisdiction
Large and/or rapid movements of funds
Unexplained dispersal of funds to multiple beneficiaries