draining development.pdf - Khazar University

How Well Do Anti–Money Laundering Controls Work in Developing Countries? 41126. Though the declaration of interests can simply demonstrate a sense of impunityby elites.27. There is a useful typology of levels of corrupt penetration and possible responses(see table 12.1).28. Presumably, if a customer profile suggests the proceeds of crime are involved,the financial institution should skip directly to the penultimate step.29. After the event, regulators may apply hindsight standards, but the collateral consequencesof bringing down large multinational or national financial institutionsmay deter heavy corporate sanctions beyond fines and restrictions on theaccess of particular individuals to fill banking posts that need to be approved.30. The fact that PEPs may have accounts with several institutions means thatcounting PEP accounts within a jurisdiction is a poor guide to the number ofPEPs because there will be double counting unless the names and other personaland corporate account identifiers are available. Meanwhile, undisclosed beneficialownership may generate an undercount.31. In 2011, a similar deal was concluded between Chinese firms and Namibia,but without the involvement of Teko Trading. See Smit, N., “Namibia: TenderExemption for Chinese Firms,” AllAfrica.com, November 18, 2011, http://allafrica.com/stories/201111180336.html.32. Yom-Tov, S., “Kobi Alexander Will Be Facing Charges of Money-Laundering,”Haaretz, September 29, 2006.33. Confidential interviews by the author among FIU staff, 2009.34. The levels of support for AML are hard to determine. One of the interestingaspects of the phenomenon, notable more strongly in discussions about terroristfinance, is the way—even in Islamic countries—the perception that moneylaundering is harmful and that AML is needed have become the conventionalwisdom. One consequence is that it is difficult to find officials who express skepticismabout keeping the proceeds of crimes out of their economies, thoughcritical discussion is commonplace about the impracticality of mechanisms todevelop and report suspicions and act upon them.35. “Money laundering typologies” is rather an elastic construct lacking in the rigornormally associated with the noun typology in scientific usage. In the AMLworld, a typology normally refers simply to a method of laundering. See Goredemaand Madzima (2009) for a review of money laundering and measuresagainst corruption in that region (for example, table 12.1): these connectionsare found in other FATF-Style Regional Bodies.36. Personal communication to the author.ReferencesADB (Asian Development Bank) and OECD (Organisation for Economic Cooperationand Development). 2007. Mutual Legal Assistance, Extradition andRecovery of Proceeds of Corruption in Asia and the Pacific. ADB/OECD Anti-Corruption Initiative for Asia and the Pacific. Paris: OECD.