A Guide to AML for Cross-Border Payments & Remittance
How should compliance teams in remittance and cross-border payment firms build and scale their anti-money laundering (AML) programs?
Download the ReportSixteen people involved in an organized crime group that smuggled millions in suspected drug profits out of the UK and illegally transported migrants, including children, across the border have been handed prison sentences.
“The NCA mounted a long and complex investigation … and … we were able to evidence their involvement in money laundering and organized immigration crime,” explained National Crime Agency (NCA) senior investigating officer Chris Hill. “The sentences handed down today marks the culmination of that investigation and years of work by our officers.”
The case involved collaborative efforts between UK and Dutch authorities, who intercepted a human smuggling van in 2019 before it could reach a Netherlands ferry. Ringleader Charan Singh was also arrested in 2019 during a series of London raids that uncovered cash, drugs, and luxury cars.
Before the raids, investigators had followed evidence of organized immigration crime and drug sale profits being sent covertly to Dubai. They recovered £1.5 million, along with evidence that the ring had sent many times that amount before. According to authorities, Singh had kept a detailed log of the cash shipments the ring sent via couriers. Investigators estimate that from 2017 to 2019, the ring had shipped around £70 million to Dubai over hundreds of trips.
More suspects were detained following the raids, and by the time trials began in January 2023, 18 people had been charged in connection with the case. In April, the end of the first trial saw Singh and six others convicted of various combinations of money laundering and facilitating illegal immigration.
On September 15, Singh and 17 others were handed prison terms. Singh was sentenced to over 12 years, with his two closest associates receiving 10 and 15 years respectively. Others received sentences ranging from 11 months to nine years.
Although the smuggling of migrants (SOM) and the trafficking of humans (TOH) differ conceptually and legally, in practice, they overlap significantly. In theory, a trafficked person is recruited or captured unwillingly for exploitation. They can originate within or outside of the country where they are exploited. In contrast, a smuggled migrant agrees to be transported, and the relationship with smugglers ends when they’ve reached their destination – always in another country than their own.
Understanding these distinctions is important because the two crimes have very different legal and moral consequences. However, they rarely remain separate: in 2016, Europol found that human smugglers sometimes participate in other types of crime – and of those that do, 20 percent engage in human trafficking.
While the Financial Action Task Force (FATF) urges a clear distinction between SOM and TOH, it also points out that voluntary migrants along irregular migration routes can become trafficking victims en route. A 2017 United Nations report revealed that 75 percent of adult migrants traveling the Central Mediterranean route had experienced at least one indicator of trafficking or exploitation.
Among children, that figure rose to 88 percent. A 2016 UNICEF report found that unaccompanied refugee and migrant youth in France along the English Channel did not always differentiate between a trafficker and a smuggler. At all surveyed sites, the study found that the children were exploited under a “grey economy” for labor, sex, or criminal activity to pay off supposed debts.
Because smuggling and human trafficking are predicate crimes for money laundering and may involve other types of financial crime, financial institutions can look for key red flags that may indicate such activity is occurring. The FATF and the US Financial Crimes Enforcement Network (FinCEN) have issued indicators and case examples to help firms better grasp what they’re looking for. It’s important to note that these indicators can overlap with other types of crime and are inconclusive without further investigation.
Some signs include:
How should compliance teams in remittance and cross-border payment firms build and scale their anti-money laundering (AML) programs?
Download the ReportOriginally published 22 September 2023, updated 08 February 2024
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