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2021 APG Yearly Typologies Report

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2021 APG Yearly Typologies Report APG Yearly Typologies Report 2021 Methods and Trends of Money Laundering and Terrorism Financing Asia/Pacific Group on Money Laundering July 2021 Applications for permission to reproduce all or part of this publication should be made to: DISCLAIMER: APG Secretariat Locked Bag A3000 Under Article 1 of the APG Terms of Reference 2012, the APG is a Sydney South non-political, technical body, whose members are committed to the effective implementation and enforcement of the New South Wales 1232 internationally accepted standards against money laundering, AUSTRALIA financing of terrorism and proliferation financing set by the Financial Action Task Force. This document, any expression Tel: +61 2 5126 9100 herein, and/or any map included herein, are without prejudice to Email: [email protected] the status of, or sovereignty over, any territory, to the delimitation of international frontiers and boundaries and to the name of any Web: www.apgml.org territory, city or area. © July 2021/All rights reserved 2 CONTENTS CONTENTS .................................................................................................................................... 3 INTRODUCTION .......................................................................................................................... 5 1. PROLIFERATION FINANCING RISK .............................................................................. 6 1.1 Risk Assessments and Proliferation Financing ..................................................................................................... 6 1.2 Amendments to the Standards ........................................................................................................................... 7 1.3 UN Panel of Experts Reports ............................................................................................................................... 7 1.4 PF Risk Assessments in the Asia Pacific ............................................................................................................. 10 1.5 Guidance and training provided to FIs and DNFBPs .......................................................................................... 14 2. UPDATE ON COVID-19 IMPACT ON ML/TF TYPOLOGIES ..................................... 16 3. APG WORKSHOPS AND PROJECTS 2020 - 2021 ............................................................ 17 3.1 Typologies Projects ............................................................................................................................................ 17 3.2 22nd Typologies and Capacity Building Workshop ............................................................................................ 18 4. FATF, FSRBS AND OBSERVERS’ PROJECTS ................................................................ 19 4.1 FATF Typology Projects ...................................................................................................................................... 19 4.2 Middle East and North Africa Financial Action Task Force ................................................................................ 24 4.3 Eurasian Group on combating money laundering and financing of terrorism .................................................. 25 4.4 Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism ........................................................................................................................................................................... 26 4.5 Egmont Group ................................................................................................................................................... 27 4.6 Inter-Governmental Action Group against Money Laundering in West Africa ................................................. 29 5. MONEY LAUNDERING AND TERRORISM FINANCING METHODS ..................... 30 5.1 Use of offshore banks, international business companies, and offshore trusts, including trust company service providers............................................................................................................................................................ 30 5.2 Use of virtual assets (cryptocurrencies). ........................................................................................................... 32 5.3 Use of professional services (lawyers, notaries, accountants). ........................................................................ 36 5.4 Trade-based money laundering and transfer pricing. ...................................................................................... 37 5.5 Underground banking / alternative remittance services / hawala. .................................................................. 40 5.6 Use of the internet (encryption, access to IDs, international banking etc). ..................................................... 43 5.7 Use of new payment methods / systems. ........................................................................................................ 43 5.8 Laundering of proceeds from tax offences. ...................................................................................................... 45 5.9 Real estate, including roles of real estate agents. ............................................................................................ 47 5.10 Trade in gems and precious metals. ................................................................................................................. 49 5.11 Association with human trafficking and people smuggling. ............................................................................. 50 5.12 Use of nominees, trusts, family members or third parties etc. ........................................................................ 50 5.13 Gambling activities (horse racing, internet gambling, etc). .............................................................................. 52 5.14 Purchase of valuable assets (art works, antiquities, race horses, vehicles, etc)............................................... 54 5.15 Investment in capital markets, use of brokers. ................................................................................................ 54 5.16 Mingling (business investment). ....................................................................................................................... 56 5.17 Use of shell companies/corporations. .............................................................................................................. 56 5.18 Association with environmental crimes (illegal logging, extraction, wildlife trafficking, etc.). ........................ 59 5.19 Currency exchanges / cash conversion. ............................................................................................................ 61 5.20 Use of credit facilities, credit cards, cheques, promissory notes etc. ............................................................... 62 5.21 Wire transfers / Use of foreign bank accounts. ................................................................................................ 64 5.22 Use of false identification. ................................................................................................................................ 65 5.23 Association with corruption/bribery ................................................................................................................ 67 5.24 Abuse of non-profit organisations (NPOs). ....................................................................................................... 72 6. PROLIFERATION FINANCING METHODS & TRENDS ............................................ 73 6.1 Case studies of breaches, non-implementation or evasion of targeted financial sanctions related to proliferation financing. ...................................................................................................................................... 73 7. MONEY LAUNDERING & TERRORISM FINANCING TRENDS .............................. 76 7.1 Recent research or studies on ML/TF methods and trends. ............................................................................. 76 7.2 Association of types of ML or TF with particular predicate activities (eg terrorist organisations, terrorist training, corruption, drugs, fraud, smuggling, etc). ........................................................................................... 82 3 7.3 Emerging trends; declining trends; continuing trends. ..................................................................................... 92 8. EFFECTS OF AML/CFT COUNTER-MEASURES ........................................................ 96 8.1 The impact of legislative or regulatory developments on detecting and/or preventing particular methods (eg tracing proceeds of crime, asset forfeiture etc). ............................................................................................... 96 8.2 Cases developed directly from suspicious or cash/threshold transaction reports. ......................................... 102 9. COVID-19 RELATED ML & TF TRENDS ..................................................................... 106 9.1 Association of types of ML or TF with particular predicate activities linked to COVID-19 (e.g. welfare fraud, scams, counterfeit medicines, corruption, drugs, smuggling, etc). ................................................................. 106 9.2 Displacement of ML or TF methodologies to established typologies (e.g. increase in reporting of the internet for ML/TF as use of cash decreases,
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