Anti Money Laundering Compliance Program Essay Paper

Money laundering is the world’s third largest industry (Jeffrey Robinson (1995)) and may occur almost anywhere in the world. Given the nature of this phenomenon, money laundering has gained in significant proportion. Be they drug traffickers, terrorists, arm traffickers, blackmailers or credit card swindlers, all criminals demand for money laundering. This criminal activity erodes profits of all financial institutions, increases corruption and fuel social injustice. Anti Money Laundering Compliance Program Essay Paper

Money laundering has thus serious social and economic consequences that need to be fought against. Many international authorities have made considerable efforts to set up appropriate AML counter measures. Likewise, Mauritius in preserving its reputation has enacted the FIAMLA (2002) and has enforced the FIU to avoid the country being a vehicle of illegal fund. However, money launderers are always a step forward than any law enforcement agencies and organisations.

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This has been compounded with globalisation and sophisticated technologies. The aim of this dissertation is to assess the perception of money laundering among the Mauritian population. The result from the question-based data collection method used supported that the population do believe in a money laundering economy in the country. However, few of them do know all matters concerning this crime and therefore, more awareness must be drawn. There is still a long way to go for its elimination but things are being done to improve the effectiveness of its combat.Anti Money Laundering Compliance Program Essay Paper

Chapter 1:

Introduction

Money laundering exists for centuries but since the 11^th September 2001 events, combating money laundering and terrorist financing has became more important. Countries realised it is urgent to combat this sophisticated criminal activity. Money laundering is the process of disguising illegal profits derived from illicit activities without compromising the criminals for them to enjoy from their proceeds without the authorities being able to detect the activities that produced them. Increasing awareness is being drawn for people realise that money laundering fuels crime. Money laundering erodes the economy of one’s country and as mentioned by Quirk (1997) its impacts are more measurable than its figure.

Money laundering affects individuals, businesses and countries, thus of global concern. 25 years ago, the international community has done much effort to combat this evil. In many countries, efforts made starts bearing its fruits and are now taking importance in many jurisdictions. In fact, if one country does not take action to combat money laundering, it may find itself lagging behind since it will be difficult for it to trade with the rest of the complying world. The latter may fear to trade with a non-complying country due to this element of non-combating money laundering. In effect, the non-complying country’s economic growth may be far behind as compared to complying countries. Low corruption affects growth positively (Mauro’s (1995)).Anti Money Laundering Compliance Program Essay Paper

However, despite the setting up of international instruments and laws to restrain this crime, its evil activities still exits and are even increasing in most cases. With new advanced technologies compounded with globalisation, it is easier for sophisticated launderers to continuously look for opportunities available worldwide in laundering their proceeds.

Although, Briscoe (1999) said that Mauritius is not considered as having a significant money laundering problem, since the island has a developing local drug consumption problem and a vibrant growing offshore financial services sector, it is clear that opportunities exist. Thus, following other countries initiations, Mauritius has set up the necessary infrastructures to combat money laundering and prevent terrorist financing. Actually, to protect itself and to maintain a good reputation, it has promulgated, among others, the FIAMLA (2002) which criminalises money laundering and its offenders. Drug trafficking, terrorist activities and financial crime are examples of illicit activities.Anti Money Laundering Compliance Program Essay Paper

The main aim of this study is to assess the perception of money laundering among the Mauritian population. While reviewing the literature, it was noticed that for Mauritius the only local survey done was by the FIU in 2006. This was published in its annual report 2006 and was helpful for this study. Additionally, references from other studies, journals and literatures done on this topic were used.

• Benefits of the study

• provide a general idea on the perception of money laundering among the Mauritian population,

• provide an overview about any research done on this topic,

• provide an insight whether the population is aware about the laws and institutions combating money laundering in Mauritius.Anti Money Laundering Compliance Program Essay Paper

• Chapters Outlines

Chapter 1 – Introduction

This chapter provides a brief introduction of the study including a short definition and its benefits.

Chapter 2 -Literature review

The definition, the process and techniques used to launder ill-gotten money, the importance of combating money laundering, the international actions took and reports done internationally and locally are provided in this chapter.

Chapter 3 – Methodology

This chapter explains the methodology used to collect the data necessary for this study.

Chapter 4 – Analysis

It provides an analysis of the data collected, the interpretation of the results and the hypothesis testing done.

Chapter 5 – Conclusion

This entails the concluding notes of this dissertation and suggests some recommendations.Anti Money Laundering Compliance Program Essay Paper

Chapter 2: Literature Review

Money laundering has been with us for centuries (Graham (2003)). As Lloyd (1997) said, its origins can be traced since the 1930’s, when notable gangsters like Meyer Lansky and Al Capone were prevailing. Their exploits founded money laundering methods still in practice today. Since then, it has gained in proportion and is almost impossible to measure its exact global amount.

KPMG (2004) reported that internationally about US$500 billion to $1 trillion is being laundered and it is estimated that annually, in the U.S and in London, about US$100 billion and £1.8-£2 billion is been laundered respectively. Moreover, IMF estimates that money laundering is about US$500 billion. Nevertheless, Quirk (1997) said that its impacts are more measurable than its figure.

Thus, such illegal activities are increasing and have dangerous effects on a country’s financial services sector, thus, being an issue of both national and international security. Quirk (1997), Barrett (1997), Paradise (1998), Masciandaro, and Portolano (2003) mentioned that money laundering threatens the economic and financial systems of countries.Anti Money Laundering Compliance Program Essay Paper

2.1 Definition

Money laundering is the process by which criminals try to mask the true origin of ill-gotten money into the stream of lawful commerce and finance. If undertaken successfully, beneficiaries will enjoy and maintain control over their proceeds and ultimately be provided with legitimate cover for the source of their income – authorities being unable to detect the activities that produced them.

Illegal profits have to be laundered because the money trail is proof of crimes, thus, vulnerable to seizure. AllDridge (2003) said that clean money is worth more than dirty money.

Hinterseer (2002) stated that money laundering is criminal finance as it corrupts markets, shifts an unfair economic burden in the legal economy, weakens the universal stability of the international financial markets and raises numerous civil liberty related issues.

In Mauritius, the Government enacted the FIAMLA (2002) which gives explicit powers to gather, analyse and disseminate information to the FIU.Anti Money Laundering Compliance Program Essay Paper

Section 3: Money Laundering

(1) Any person who –

(a) engages in a transaction that involves property which is, or in whole or in part directly or indirectly represents, the proceeds of any crime; or

(b)receives, is in possession of, conceals, disguises, transfers, converts, disposes of, removes from or brings into Mauritius any property which is, or in whole or in part directly or indirectly represents, the proceeds of any crime,

where he suspects or has reasonable grounds for suspecting that the property is derived or realized, in whole or in part, directly or indirectly from any crime, shall commit an offence.

2.2 Process of Money Laundering

Peltman (1997) has shown that money laundering has three stages. They may occur as separate and distinct stages or as an overlapping phase. Their usage will depend on the criminals’ accessible laundering mechanisms and requirements.Anti Money Laundering Compliance Program Essay Paper

Figure 1: A Typical Money Laundering Scheme

• Placement

Placement is where most efforts are focused to combat money laundering. This involves the breaking up of large deposits into minute deposits for currency transaction reporting avoidance. This involves single or multiple transactions using one or more bank deposits or the purchasing of investments.

Michael et al (2002) find that placement is the most risky stage for detection – It is where the huge illegal cash profits are presented personally to a financial establishment. This can pose an enormous problem as dealing with cash in bulk and in regularity is difficult.

• Layering

Steel (1998) found that layering stage is the most complex stage and the most international in nature. Graham (2003) said that layering relies on the negotiation of paper, electronic or digital records through a series of transactions which will make it difficult, if not impossible the reconstruction of paper trail detailing previous cash movements.Anti Money Laundering Compliance Program Essay Paper

2.2.3 Integration

Integration follows a successful layering process and is the final stage according to Schneider (1994). Moreover, for Graham (2003), transactions can no longer be linked to criminal cash and the secrecy of the source of funding is guaranteed. The criminal cash in the legitimate economy appears as money naturally originated from legal transactions.

Araujo and Moreira (2005), Masciandaro (1999) stated that it is expected when cleaning has been done the money is ready to get back into the formal economy, thus, providing funds for investment or consumption.

2.3 Techniques of Money Laundering

Briscoe (1999) stated that money laundering is not considered as a significant problem in Mauritius and that the country is not a major narcotics production or trans-shipment centre. Nevertheless, since the island has a developing domestic drug consumption problem and a vibrant growing offshore financial services sector, it is clear that opportunities exist.Anti Money Laundering Compliance Program Essay Paper

Results obtained by Mauro, (1995), (1997), Leite and Weidmann, (1999), Alesina and Weder, (2002), Damania, Fredriksson and Muthukumara, (2003) from the World Bank’s Governance Indicators and Transparency International’s Corruption Perception Index (CPI) indicate that corruption indexes is now a very profitable source of research.

Similar to money laundering has no frontier, money launderers have unlimited originality to launder their money. Hence, launderers will seek where the weakest link in the chain is, targeting the weakest point of defenses and where detection is less likely to arise. Masciandaro (2001) said that financial industries are the major concern of money laundering fighters since money actually needs to pass through them. Money laundering techniques are very long, sophisticated and difficult to determine precisely. Some of them are summarised below.Anti Money Laundering Compliance Program Essay Paper

2.3.1 Banking Services

Considering their activities, banks represent a natural and logical vehicle for launderers. Graham, Bell & Elliott (2003) stated that cash deposits, basic banking services and wire transfer facilities are the core means of money laundering. The wealthier launderers will look for specialist private bank services and investment houses that offer wealth management services.

Following the Basel Committee statement (1988), Johnson and Lim (2002) stated that financial institutions including banks may be willingly or unconsciously be used as intermediaries for money laundering since they remain an important mechanism for its disposal. Mascaindaro (1995) strengthen this theory by stating that money laundering occurs either by passively using bank agents or by actively using criminal banks.

In contrast, Quirk (1997) empirically observed a shift in money laundering techniques and concluded that launderers are going away from the banking system. Bauer and Peter (2002) mentioned that banks are actively combating money laundering and these initiatives may well be a model for international cooperation.Anti Money Laundering Compliance Program Essay Paper

2.3.2 Money Services Businesses

Graham, Bell & Elliott (2003) stated that criminals use ‘bureau de change’ to convert cash to other currencies or consolidated smaller amounts. Usage of remittance services or giro houses enables criminals to transfer cash between jurisdictions. Duyne’s empirical findings show that in both Bosphorus case and Mozart case, money launderers involved an extensive network of currency exchange offices.Anti Money Laundering Compliance Program Essay Paper

2.3.3 Lawyers, Accountants and other Intermediaries

Graham, Bell & Elliott (2003) found that launderers usually use professionals to set up corporate and trustees to act as nominee shareholders or directors. These are of growing international concern. The client’s account provides the launderer a hidden vehicle for depositing funds into the banking system. In selling their personal investment products, professionals provide useful means for money laundering.Anti Money Laundering Compliance Program Essay Paper

Johnson and Lim (2002) found that money launderers use more non-bank financial institutions and non-financial business like lawyers for money laundering. Their evidence supported that a weakening of the bank/illegal economy relationship, implies a lesser participation of the banking sector for laundering money.

2.3.4 Non-Financial Sector Services

Graham, Bell & Elliott (2003) also found that casinos, metal dealers and other high valuable goods sellers are money laundering techniques. These are done especially in cash purchase or substantial cash deposits.

• Distinguishing dirty money from legitimate gambling profits or losses will be quite difficult if the dirty money is changed into casino chips and then back into cash.

• Lloyd (1997) stated that whatever be the form of the jewelry, its value remains constant. Thus, a single piece of gold can be changed various times to disguise its origins without any significant change in its value.Anti Money Laundering Compliance Program Essay Paper

2.3.5 Alternative Remitting Systems

As per Graham, Bell & Elliott (2003), popular within some ethnic groups, Hawala or hundi are alternative remittance systems used to transfer funds abroad. These systems function outside the regulated banking sector. Graham, Bell and Elliot (2003) added that it is believed that the Al-Quaeda terrorist organisation have used the hawala for the financing of 11 September 2001 event.Anti Money Laundering Compliance Program Essay Paper

2.3.6 Exploitation of Internet Banking Services

Exploitation of banking services and the use of developments in the internet are techniques used for laundering money. Actually, some banks dispense their clients of all contacts, thus no control over transactions exists. Example, the Fortis Bank in Luxembourg, offers complete e-banking services.

2.3.7 Use of Correspondent Banks

Several international trustworthy banks have been involved in money laundering due to insufficient controls. Examples:

• Russian banking (Rawlinson,1996; Burlingame, 1997)

• Banco Ambrosiano (Cornwell, 1983)

• BCCI (Adams and Franz, 1992)

• Banque Crédit Lyonnais: case of Parretti and Fiorini (d’Aubert, 1993). Anti Money Laundering Compliance Program Essay Paper

2.4 Importance of Combating Money Laundering

Over the last 25 years, the international community has made considerable efforts to combat money laundering. Countries realise that if they allow money laundering or fail in adapting correctly the AML procedures and the KYC principles, they run the risk of civil and criminal liability, reputation and regulatory risks. Moreover, Lasco (1997) mention that if governments are reluctant to accept the universal application of money laundering countermeasures, then its ills associated will damage the society. Bauer (2002) and Peter (2002) stated that in some countries like USA, the KYC principle has not been established firmly in legislation as it is under some European rules.

Some intermediaries view money laundering regulations and laws as an annoying obstacle for trading. For example, it was feared that recent efforts in the Channel Islands for strict laws would decrease business volumes, but finally, the Channel Islands attracted more businesses.Anti Money Laundering Compliance Program Essay Paper

The Commonwealth Model of Best Practice for Combating Money Laundering in the Financial Sector suggests four principle reasons for money laundering (Graham, Bell & Elliott (2003)).

• Failure to prevent money laundering allows criminals enjoying their proceeds, making crimes especially attractive. It also permits criminal organisations to finance other criminal activities, which eventually increase the level of crime.

• Unchecked use of the financial system has potential powers to weaken individual financial institutions, and finally the reliability of the whole financial sector. Moreover, it has adverse macro-economic effects affecting exchange rates during large capital flows and thus distorts resource allocation.

• Unchecked laundering may create contempt for the law hence, declining the confidence public has in the legal and financial system, resulting finally in a rise in economic crime.

• Money laundering eases corruption. Eventually, accumulation of economic and financial powers by immoral politicians or criminal organisations may undermine the country.Anti Money Laundering Compliance Program Essay Paper

Below are some summarised reasons why AML laws are required.

2.4.1 Unfair Competition

Money launderers often use their proceeds to finance certain companies. This allows them to undercut innocent rivals and force them out of the market. Therefore, if left unchecked, money laundering may unfairly affect the pricing mechanism of the market system and create unnecessary distortion. Quirk (1997) studied that crime highly explains differences among the industrial countries; a 10% raise in crime leads to a 10% reduction in currency demand and a 6% reduction in overall money demand.

2.4.2 One crime generates further crimes

Money laundering allows criminals to take full advantage of their crimes if not properly tracked down. This makes such criminal activities more attractive, resulting in its rise. Thus, one crime generates other crimes. Masciandaro (1998) stated that banks in regions of higher criminality have greater association with money laundering than banks in region of low criminality. From his hypothesis, Masciandaro (1998) proved that ‘the positive association observed between the banking sector and the illegal economy allows an assumption of an increase in laundered funds when illegal activities increase’. Moreover, Masciandaro (1998) results showed that money laundering is a multiplier of criminal activities by providing criminals with cleaned money for reinvestment in their illicit activities. Masciandaro (1999) results also showed that there is an inverse relationship between the degree of diffusion of money laundering activities and the effectiveness of AML regulation in a given economy.Anti Money Laundering Compliance Program Essay Paper

2.4.3 Corruption and Growth

With large amount of money involved, money laundering has direct effects on economic crimes. Once corruption infiltrates the system, the whole machinery is affected and functions improperly. Public confidence in some fundamental institutions may be at risk and this can only promote crimes. Obviously, a corrupt society has no great hope for prosperity. Empirical results confirmed Mauro’s (1995) findings that low corruption affects growth positively. Mauro (1995) himself followed Barro (1991), and Levine and Renelt (1992) specifications which assess investment and growth responses to corruption. Quirk (1996) empirical evidence showed for the period 1983-90, significant reductionsin annual GDP growth rates and increase in money laundering are related.

2.4.4 Social Cost

Quirk (1996) found that money laundering has important social costs when it facilitates crimes and corruptions within both the developing and developed countries. The International Narcotics Control Strategy (1998) confirmed that money laundering has devastating social costs and threatens the national security and McDowell and Novis (1998) added that money laundering erodes the confidences in markets. Additionally, Alweendo Tom K (2005) stated that crime and criminal activities work towards eroding these very basic individual rights.Anti Money Laundering Compliance Program Essay Paper

2.5 Criminalising Money Laundering

“The key to making an impact in money laundering is to get all of the countries of the world to enact and enforce the same laws dealing with money laundering so the criminals have nowhere to go“, Interpol expert Brown (1998).

With new technologies, it is easier for sophisticated launderers to continuously look for opportunities available worldwide. The loopholes in other jurisdictions can frustrate efforts made by one jurisdiction to combat money laundering. Therefore, it is of global concern since no country’s financial system is protected from it. Quirk (1997) stated that money laundering has a considerable negative impact on the macro-economy, therefore it is urgent to adopt AML measures.

2.5.1 International Actions

The international community are more aware of the dangers of money laundering, and many governments and jurisdictions have committed themselves to take international actions to combat money laundering. These began in 1988.Anti Money Laundering Compliance Program Essay Paper

2.5.1.1 Basel Committee

This statement they adopted in December 1988 outlined the following initiatives and policies that suggest financial services to implement.

• need for compliance with legal laws and guidelines,

• cooperation with national law enforcement authorities,

• implementation of record-keeping and transaction recording,

• staff training,

• KYC approach.

2.5.2 Vienna Convention

Ashe and Reid, (1998) stated that the Vienna Convention established in December 1988 was the first treaty of global reach criminalising money laundering which creates an obligation for signatory states to criminalise such evil. It also includes the production, management and financing of trafficking operations as well as facilitating the commission of drug trafficking offences including money laundering.Anti Money Laundering Compliance Program Essay Paper

2.5.3 United Nation (UN)

2.5.3.1 Global Programme against Money Laundering

Through the GPML, the UN helps its member states with legal advice and assisting them in drafting appropriate legislation and establishing the necessary administrative structure to combat money laundering. The strategies include:

• provision of technical assistance to developing countries,

• organisation of training workshops,

• provision of training materials,

• transferring of expertise between jurisdictions,

• conduction of research,

• analysis and gathering of data.

For its first operating year, the Program aided 20 countries and introduced a global comprehensive database on national money laundering legislation and the International Money Laundering Information Network on the Internet.Anti Money Laundering Compliance Program Essay Paper

2.5.4 Financial Action Task Force

FATF with its 34 members is an inter-governmental body which develops and promotes national and international policies to combat money laundering and terrorist financing. Established in 1989, FATF is a “policy-making body” that works to generate the necessary political willingness to bring about legislative and regulatory reforms.

In 1990, it published 40 + 9 recommendations providing a comprehensive framework to fight money laundering. These were revised in 1996 and 2003 to ensure that they remain up-to-date and relevant to the money laundering growing menace. In 1995, the International Narcotic Control Board advised all governments to implement these 40 recommendations.Anti Money Laundering Compliance Program Essay Paper

2.5.4.1 FATF Responsibilities:

• examination of money laundering techniques and trends,

• reviewing of action which had already been taken at a national or international level,

• setting out of measures that need to be taken to combat money laundering,

• evaluating countries in respect of their AML measures.

Therefore, where weaknesses are found, countries are recommended to remedy the shortcomings the soonest. Failing, they are threatened of being blacklisted as non-cooperative jurisdictions. Naming and shaming them, FATF achieves its objectives of bringing countries to adopt appropriate AML measures.Anti Money Laundering Compliance Program Essay Paper

2.5.4.2 The 40 Recommendations

Recommendations 1-2: Scope of the criminal offence of money laundering

Recommendation 3: Provisional measures and confiscation

These are to be taken by financial and non-financial businesses and Professionals to prevent money laundering and terrorist financing

• Recommendations 4-12: Customer due diligence and record-keeping

• Recommendations 13-16: Reporting of suspicious transactions and compliance

• Recommendations 17-20: Other measure to deter money laundering and terrorist financing

• Recommendations 21-22: Measures to be taken with respect to countries that do not or insufficiently comply with FATF Recommendations

• Recommendations 23-25: Regulations and Supervision. Anti Money Laundering Compliance Program Essay Paper

Institutional and other measures necessary in systems for combating money laundering and terrorist financing

• Recommendations 26-32: Competent authorities, their powers and resources

• Recommendations 33-34: Transparency of legal persons and arrangements

• Recommendation 35: International Co-operation

• Recommendations 36-39: Mutual legal assistance and extradition

• Recommendation 40: Other forms of co-operation

FATF Annual Report 1996-97 added that earnings of offences like fraud and smuggling are also gaining importance. Moreover, commenting on the FATF Annual Reports from 1994, Johnson and Lim (2002) states that AML measures that some governments took, help in minimising money laundering and that with the imposition and enforcement of AML legislation, it will be harder for money launderers to clean their proceeds. Hence, preliminary evidence puts forwards that governments’ attitudes are important in either restricting or encouraging money laundering.Anti Money Laundering Compliance Program Essay Paper

However, Quirk (1997) mentioned that some governments could not implement the FATF “40 Recommendations” as this would go against the IMF’s advice for liberalising financial markets.

2.5.5 International Monetary Fund

The IMF has expertise in conducting financial sector assessments, providing technical assistance in the financial sector, and exercising surveillance over members’ economic systems, which is particularly helpful in evaluating country compliance with the international AML/CFT standards and in developing programs helping them address identified shortcomings.

After the 11^th September 2001 events, IMF continued to broaden and deepen its engagement in the global fight against money laundering and terrorist financing. March 2004 viewed an important moment. The IMF Executive Board agreed to make AML/CFT assessments and technical assistance a regular part of its work and to expand this work to cover the full scope of FATF 40 recommendations.

Other international actions combating money laundering are the Egmont Group, the OECD, the EAG, the Asia-Pacific Group on Anti-Money Laundering and the E.U Directive.Anti Money Laundering Compliance Program Essay Paper

2.5.6 KPMG report on Global Anti-Money Laundering Survey (2004)

Aim: Whether the increasing globalisation of banking groups and of international regulatory cooperation resulted in an increase in consistency in the AML approach

Methodology: The field research was done from 1^st March 2004 to 26^th March 2004 and 209 banks based in 41 countries responded. Consensus Research was charged by KPMG to conduct a telephone survey of banks across the main sectors. These banks were the 1,000 best global banks and local banks from seven regions as shown in figure 2 below.

Figure 2: Analysis of Respondents by Region

The figures 3 & 4 below are a detailed analysis of the respondents by region and country and an analysis of the respondents by industry.

Figure 3: Analysis of Respondents Region by country

Figure 4: Analysis of Respondents by Industry

Results:

• high degree of commitment from the banking sector in the AML cause and provide opportunity for banks worldwide to assess and benchmark their own practices with those of their regional and international peer group.Anti Money Laundering Compliance Program Essay Paper

• most respondents believed that the current AML burden is acceptable

• they were keen to work with regulators and law enforcements for the system to work more successfully.

2.6 In Mauritius

2.6.1 Financial Intelligence and Anti-Money Laundering Act (2002)

The FIAMLA (2002) criminalises money laundering and is the legislation of AML. It provides for the establishment and management of a FIU and a Board to supervise its activities and provides for money laundering offences, reporting of suspicious transactions, gateways for exchange of financial intelligence information and exchange of mutual assistance with overseas bodies, all in relation to money laundering.

FIAMLA (2002) under section 8 imposes high criminal penalty for money laundering offences. Any person who commits any money laundering offence shall, on conviction, be liable to a fine not exceeding 2 millions rupees and to penal servitude for a term not exceeding 10 years. Moreover, any property belonging to or in the procession or under the control of any person who is convicted of an offence of money laundering shall be deemed, unless the contrary is proved, to be derived from a crime and the Court may, in addition to any penalty imposed, order that the property be forfeited.Anti Money Laundering Compliance Program Essay Paper

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It is worth noting that FATF experts concluded that although Mauritius has a regulatory regime for the financial service sector both locally and internationally, certain troubling characteristics were found. These concern the identity of the administrators and the real beneficial owners of offshore companies. However, the law on economic crime and anti-money laundering adopted on 13^th June 2000 which has been taken on board in the FIAMLA (2002) has reinforced the existing legislation with regards to prevention and fight money laundering.

2.6.2 Prevention of Corruption Act (2002)

The corruption component of the Economic Crime and Anti-Money Laundering Act (2000) was taken on board in the POCA (2002) which provides for the investigation of money laundering offences. Anti Money Laundering Compliance Program Essay Paper