TYPOLOGICAL STUDIES OF THE STATE FINANCIAL MONITORING SERVICE OF UKRAINE 2017 The State Financial Monitoring Service of Ukraine State Financial Monitoring Service of Ukraine State Institution of Post-Graduate Education “Academy of Financial Monitoring” TYPOLOGICAL STUDIES OF THE STATE FINANCIAL MONITORING SERVICE OF UKRAINE 2017 Kyiv 2018 Recommended by the Inter-branch Scientific and Methodical Council of the State Institution of Post- Graduate Education “Academy of Financial Monitoring” (Protocol of 29.01.2018 № 1) Publication and translation into English was made with the assistance of the European Union Anti- Corruption Initiative (EUACI) Typological Stydies of the State Financial Service of Ukraine for 2017– K., 2018. – 148 p. The publication deals with the most common trends and shemes of money laundering and terrorist financing in 2017. In particular, examples of real cases of money laundering and terrorist financing associated with the risks of cash use and the risks of terrorism and separatism are given. Typological studies include information on the results of the work of state authorities – participants of the national financial monitoring system. The publication is designed for employees of reporting entities and state financial monitoring entities, law enforcement, intelligence and judicial authorities, as well as scientists and practitioners in the area of financial monitoring. TYPOLOGICAL STUDIES OF THE STATE FINANCIAL MONITORING SERVICE OF UKRAINE CONTENTS Foreword of the Head of the State Financial Monitoring Service of Ukraine Mr. Igor Cherkaskyi . 8 PART I. RISKS OF CASH USE . .11 INTRODUCTION TO THE FIRST PART . .12 SECTION І. USE OF CASH IN UKRAINIAN ECONOMY. GENERAL OVERVIEW . 17 1.1. Overview of cash market trends in Ukrainian economy . .18 1.2. Use of payment cards . .21 1.3. Factors contributing to the use of cash . 23 1.4. Cash transaction threshold values for inter-entity transactions . 24 1.5. Cash in money laundering . 27 1.6. Cryptocurrency as a tool in money laundering . 27 SECTION IІ. DETECTION OF RISKY CASH TRANSACTIONS . 29 SECTION ІІІ. INTERNATIONAL MONEY LAUNDERING PLATFORMS. 35 SECTION ІV. CONVERSION CENTRES AND THEIR OPERATIONS . 39 SECTION V. USE OF PRESUMABLY SHELL COMPANIES IN MONEY LAUNDERING OR FINANCING OF TERRORISM . .51 SECTION VI. BUDGET FUND THEFT WITH FURTHER CONVERSION OF FUNDS TO CASH . 57 SECTION VII. USE OF CASH BY PEP’S, RELATED PERSONS AND OTHER CIVIC SERVANTS . .61 SECTION VIII. MONEY LAUNDERING THROUGH REAL ESTATE PROCUREMENTS . 67 SECTION IX. USE OF CASH IN THE SCHEMES RELATED TO TRADE IN NARCOTIC (PSYCHOTROPIC) SUBSTANCES, THEIR ANALOGUES AND PRECURSORS . .71 SECTION X. ILLICIT CASH MOVEMENT . 77 3 TYPOLOGICAL STUDIES OF THE STATE FINANCIAL MONITORING SERVICE OF UKRAINE SECTION XI. CASH COMBINED WITH OTHER TOOLS . 81 CONCLUSION TO PART I . 83 PART II. RISKS OF TERRORISM AND SEPARATISM . 85 INTRODUCTION TO THE SECOND PART . 86 SECTION I. RATIONALE . .89 SECTION II. TERRORIST-RELATED RISKS AND THREATS. GENERAL OVERVIEW . 93 2.1. Risks and threats related to terrorism and terrorism financing in Ukraine. Overview . 95 2.2. World trends to counter terrorism and terrorism financing . 97 2.3. TF risks related to ISIL’s activities. 98 2.4. Use of foreign militants in financing of terrorism . 99 2.5. Counteraction to risks and threats related to terrorism and terrorism financing in Ukraine . .100 SECTION III. STANDARD METHODS, SCHEMES AND TOOLS FOR TERRORISM FINANCING . 103 3.1. Use of NPOs in terrorism financing . .106 3.2. Indirect terrorism financing . 111 3.3. FT sources . 113 3.4. Illicit funds in terrorism financing. .115 3.4.1. Use of proceeds earned from drug trafficking in terrorism financing . 115 3.4.2. Use of proceeds from credit card fraud in terrorism financing . 116 3.4.3. Use of proceeds from cheque fraud in terrorism financing . 117 3.4.4. Use of proceeds from extortion in terrorism financing . 117 3.4.5. Use of various sourced illicit proceeds for terrorism financing . 118 3.5. Movement of funds to finance terrorism. .119 3.5.1. Use of a state financial system in terrorism financing . 120 3.5.2. Use of trade in terrorism financing . 122 3.5.3. Use of payment systems in terrorism financing. .125 3.5.4. Use of cash transporters (cash couriers) for terrorism financign . 129 3.6. Emerging terrorist risks . 13 0 3.6.1. Fundraising with the use of social networks in terrorism financing . 13 0 3.6.2. Use of virtual currencies in terrorism financing. .132 3.6.3. Use of prepaid cards for terrorism financing. .134 3.6.4. Use of revenues from the exploitation of natural resources and mineral deposits for terrorism financing . 135 3.6.5. Use of the oil and gas industry for terrorism financing . 137 4 TYPOLOGICAL STUDIES OF THE STATE FINANCIAL MONITORING SERVICE OF UKRAINE 3.6.6. Use of the mining industry for terrorism financing . 137 3.6.7. Use of informal payment systems for terrorism financing . .13 8 SECTION IV. TOOLS AND METHODS TO FINANCE TERRORISM IN UKRAINE. .141 CONCLUSION TO THE PART II . .146 LIST OF ABBREVIATIONS . .147 5 TYPOLOGICAL STUDIES OF THE STATE FINANCIAL MONITORING SERVICE OF UKRAINE FOREWORD 7 FOREWORD OF THE HEAD OF THE STATE FINANCIAL MONITORING SERVICE OF UKRAINE MR. IGOR CHERKASKYI Dear colleagues! We are pleased to pay your attention to Typological studies of the State Financial Monitoring Service of Ukraine for 2017 within highlight the results of the work of the Financial Intelligence Unit of Ukraine and other participants of the national financial monitoring system on the exposure of modern schemes and methods used by criminals to legalize (launder) the proceeds from crime, and terrorist financing. It should be noted that Ukraine continues to use the reinforced practical measures for the development and improvement of the national financial monitoring system in accordance with international standards. The previous year was notable for the evaluation of Ukraine within the 5th round of Mutual Evaluation by the Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism. One of the key risks that were highlighted by the experts of the Council of Europe and which, were detected in 2016 based on the results of the first National AML/CFT Risk Assessment in the area of prevention and counteraction to the legalization (laundering) of the proceeds from crime and the financing of terrorism, became the risks of widespread use of cash and terrorist financing. TYPOLOGICAL STUDIES OF THE STATE FINANCIAL MONITORING SERVICE OF UKRAINE Taking into account the above mentioned and other factors underlying the study of modern risks in the financial monitoring system, the SFMS generalize and publishes standard schemes of legalization of the proceeds from crime. In addition, the need to conduct such a work is directly provided for the legislation of Ukraine and the FATF Recommendations. In 2017, the SFMS taking into account the enhanced cooperation with MONEYVAL within the mutual evaluation, not traditionally, has conducted two typological studies instead of one. Thus, the presented publication collected in itself typological stydies of the State Financial Monitoring Service of Ukraine for the last year, which relate to: • risks of cash use; • risks of terrorism and separatism. Taking into account the typologies of the recent years (Laundering the proceeds from corruption [2016], Current instruments, methods, and mechanisms of illegal funds allocation and laundering [2015], Current techniques, methods, and financial instruments of terrorism and separatism financing [2014]), we have consciously focused on the analysis of the most fundamental risks that exist today. That are the use of cash and new forms of financing terrorism and separatism. I am convinced that typological studies prepared by the SFMS, with the participation of other state authorities and the private sector, will be useful to practitioners of the state and private sector as well as the public, who deal with the protection of the financial system from the invations of criminals. Igor Cherkaskyi 9 ТИПОЛОГІЧНІ ДОСЛІДЖЕННЯ ДЕРЖАВНОЇ СЛУЖБИ ФІНАНСОВОГО МОНІТОРИНГУ УКРАЇНИ 10 TYPOLOGICAL STUDIES OF THE STATE FINANCIAL MONITORING SERVICE OF UKRAINE PART I RISKS OF CASH USE 11 TYPOLOGICAL STUDIES OF THE STATE FINANCIAL MONITORING SERVICE OF UKRAINE INTRODUCTION TO THE FIRST PART The use of cash as the major facilitator (a tool simplifying a task at hand) within the money laundering cycle is a serious relevant issue tracked in both developed and developing countries. Cross-border cash flows have been under careful analysis of supranational institutions (FATF, Europol, European Commission, MONEYVAL, etc.) for the last decade. Despite stable expansion of cashless payments and related technologies, the rates of cash transactions all over the world have diminished only a very little. Pan-European trends prove that the total value of Euro banknotes in circulation has been growing annually, and the above rates have been even higher than European inflation values. Global trends provide evidence that cash (banknotes of low par value) is commonly used with payments for low-valued goods and services. In this context, a mere 1/3 of par value in circulation is spent. At the same time, there is a stable demand for high par value banknotes. With the above cash trend in mind, the latter banknotes are not used for daily payments spent on common goods and services. The anomalies detected can be directly related to illicit activities of organized criminal groups. One of the most important preliminary conclusions related to supranational cash use analysis would lie in the claim that there is substantial lack of information regarding the use of cash for reaching both legal and illicit goals. The use of cash remains the basic reason for suspicions regarding financial transactions implemented within financial and economic systems of both EU member-states and Ukraine. Another aspect which is worth mentioning states that despite the fact that not all the cash transactions are a matter of crime, all the players involved in socially dangerous illicit activities (criminal actors) use cash at a certain stage of money laundering.