Examining the practical viability of internationally recognised standards in preventing the movement of money for the purposes of terrorism

2017 ◽  
Vol 24 (2) ◽  
pp. 260-276 ◽  
Author(s):  
Nicholas Gilmour ◽  
Tristram Hicks ◽  
Simon Dilloway
Keyword(s):  
Case Studies ◽  
Money Laundering ◽  
International Standards ◽  
Routine Practice ◽  
Content Type ◽  
Terrorist Financing ◽  
Script Analysis ◽  
Terrorist Finance ◽  
Crime Script ◽  
Crime Script Analysis

Purpose The purpose of this paper is to examine – using crime script analysis – the practical effectiveness of internationally endorsed and universally recognised counter-terrorism financing (CTF) standards in preventing the movement of money for the purposes of terrorism. The paper does not seek to examine the originating circumstances of terrorist finances or how laundered value is assigned. Design/methodology/approach Preliminary evaluation focuses on the discrepancies between the practices of money laundering and terrorist financing. Following an introduction to crime scripts, internationally endorsed anti money laundering (AML)/CTF practices are discussed to identify the process used to trace, prevent and limit money laundering and terrorist financing. Several terrorist financing case studies are then aligned to the process of crime script analysis to determine whether existing AML/CTF practices are effective in preventing terrorist financing. Findings The AML model “Placement, layering, integration” is only relevant to CTF in the comparatively rare cases when the origin of the money is crime. This creates a false sense of security through over reliance on AML/CTF for CTF purposes. A crime script approach can be applied to terrorist finance, but it is currently hindered by insufficient reporting of low level financing of terrorists, their addresses and associates. Law enforcement make insufficient use of financial intelligence – as a routine practice – in their crime and terrorist investigations; they have not adopted parallel investigation as a routine approach and consequently remain largely unconnected with the AML/CTF regime. Practical implications Utilising terrorist financing case studies, this paper identifies that existing AML/CTF international standards and practices are not adequate for controlling the movement of funds for financing terrorism because of the lack of focus on a specific script that aligns to known terrorist finance methodologies. While the paper identifies that existing AML/CTF international standards are thorough, the process underpinning the financing of terrorism is too dissimilar to the process of money laundering, namely, placement, layering, and integration, to support practices associated with terrorism prevention and detection. Originality/value This paper provides an examination of the practicalities behind the countering of terrorist financing from a compliance and investigative perspective. The paper is of interest to those involved in policy, compliance and investigations associated with terrorist financing.

Crime scripting the criminal activities of money laundering – holistically

2021 ◽  
Vol ahead-of-print (ahead-of-print) ◽  
Author(s):  
Nicholas Gilmour
Keyword(s):  
Money Laundering ◽  
Law Enforcement Agencies ◽  
Content Type ◽  
Preventative Measures ◽  
Script Analysis ◽  
Significant Research ◽  
Crime Types ◽  
First Time ◽  
Crime Script ◽  
Crime Script Analysis

Purpose This paper aims to demonstrate the benefit of applying crime script analysis at a macro level to expose money laundering as an interconnected series of events that contradict understanding which defines money laundering as a series of typological studies. Design/methodology/approach Using previously captured data and detailed research studies alongside the professional experience of the author, this study creates a horizontal crime script for three distinct methods of money laundering – to determine characteristic nodes and identify pathways. Findings Despite significant research into money laundering typologies, this paper demonstrates that the process of money laundering cannot be separated into typological studies. By applying crime script analysis to each method of money laundering prior to analysing the nodes, activities and behaviours, money laundering can be identified as a series of interconnected services, business formalities and management activities. Practical implications This study is of value to government policymakers, regulators and financial institutions considering future preventative measures. It is also of value to financial investigators and law enforcement agencies intent on investigating money laundering. By applying the method of analysis outlined in this paper to each method of money laundering and then combining them together, it is possible to understand money laundering as a holistic process, in which webs of interconnected criminal events can be identified for investigative and preventative purposes. Originality/value Interest in crime script analysis is now supporting understanding of different crime types. This study goes beyond the analysis of individual types of money laundering and applies it in a “test format” against three methods of money laundering to create, for the first time, a holistic or macro appreciation of the interconnected series of events, activities and behaviours which exist beyond the characteristics routinely captured in money laundering typology reports.

Legal analysis of Qatar’santi-money laundering and combating terrorist financing legislation and regulation amidst the summer 2017 GCC crisis

2020 ◽  
Vol 23 (4) ◽  
pp. 793-804
Author(s):  
Mohammed Ahmad Naheem
Keyword(s):  
Money Laundering ◽  
International Standards ◽  
Legal Analysis ◽  
Content Type ◽  
Non Profit ◽  
Terrorist Financing ◽  
The Past ◽  
Regulatory Bodies ◽  
The Government ◽  
Financing Of Terrorism

Purpose The recent diplomatic split between members of the Gulf Cooperation Council (GCC) and Qatar with accusations of terrorist financing (TF). This paper aims to study Qatar’s domestic legislations, which specifically targets money laundering and TF activities. The country has stringently worked in compliance with international standards on combating financing of terrorism (CFT) and anti-money laundering (AML) practices by imparting autonomous power to regulatory bodies, such as the Qatar Central Bank and other agencies. Design/methodology/approach This paper studies independent legislations passed under the Emir’s decree over the past decade advancing Qatar’s AML ranking, with significant effort in CFT regulations. The paper also analyses the advancement in AML/CFT regulation and their validity with respect to international standards set by various governmental, intergovernmental and non-profit agencies. Findings The analysis finds Qatar in compliance with strong AML/CFT regulations. Further, it finds the government to have provided transparent oversight to international organizations that attest to the findings of the legislative efforts. This paper disproves claims and accusations that have possibly been presented to the GCC and subsequently led members to abruptly end diplomatic relations with Qatar over allegations of TF activities, amongst others. Originality/value The paper offers insight into Qatar’s legislative and regulatory advancement with respect to the AML/CTF in the past decade. The paper also discusses Qatar’s legislative advancement in relation to the evolutions of the country’s financial system, adopting a more robust mechanism to combat financing of terrorism and ML.

The State of Kuwait’s anti-money laundering & combatting terrorist financing infrastructure and performance evaluation

2020 ◽  
Vol 23 (2) ◽  
pp. 441-456
Author(s):  
Mohammed Ahmad Naheem
Keyword(s):  
Middle East ◽  
Money Laundering ◽  
The State ◽  
International Standards ◽  
Assessment Tools ◽  
Gulf Region ◽  
Content Type ◽  
Terrorist Financing ◽  
Northern Border ◽  
The State Of Kuwait

Purpose The State of Kuwait operates a US$110bn economy and serves as an integral part of the global energy trade, holding over 9% of the world’s oil reserves. In addition, Kuwait is making attempts to open its economy, working towards domestic diversification. This paper aims to understand Kuwait’s internal financial protection mechanisms and their compliance to international standards. It is imperative to understand Kuwait’s legal and regulatory system that combats money laundering and terrorist financing concerns, which further extends to the region’s security discourse. This paper focuses on the State of Kuwait’s internal efforts to propel anti-money laundering/combating terrorist financing (AML/CTF) measures, and further evaluate these measures with respect to international evaluations. Design/methodology/approach Anti-money laundering and combatting terrorist financing mechanisms require a layered analysis to understand the legislative and bureaucratic organization of enforcement. Further, these measures, taken within the domestic framework, must be compared to international standards, and thus taken into account by observers. This paper studies Kuwait AML/CTF mechanisms by studying the country’s legislation, regulation and implementation. The country’s legislation will offer insight into the basic foundation of the country’s stance against money laundering and terrorist financing. Kuwait’s regulation against money laundering/terrorist financing (ML/TF) will represent the enforcement mechanisms and risk-assessment tools mandated by the independent regulatory authorities. Finally, the country’s enforcement levels will provide a deeper understanding of the country’s systemic approach to successfully combatting ML and TF activities. In addition, this paper also studies international evaluations that present an independent and factual view regarding Kuwait’s AML/CTF structure and its implementation. Findings Following a thorough examination of primary and secondary literature, this paper finds the State of Kuwait to have taken significant steps in implementing recommended legislative and regulatory mechanisms. The paper found significant strategic deficiencies within internal mechanisms pre-2014, which have been largely resolved in the state’s ex post approach to the Financial Action Task Force’s recommendations. There is also evidence of an improving enforcement mechanism in the state’s recent efforts in reducing exposure to ML and TF risks. However, the paper finds certain “strategic deficiencies” within the country’s internal reporting and external publishing administration. Practical implications The State of Kuwait is an important member in the route to regional stability and security in the Middle-East and Arabian Gulf region. Kuwait’s northern border abuts with Iraq, and connects the country with the rest of the Middle-East. The upward regional instability could create internal security risks for Kuwait. In addition, the State of Kuwait has taken the onus, in addition to the Sultanate of Oman, to mediate the diplomatic lapse between members of the Gulf Cooperation Council. The aforementioned positions ascertain a need to examine, and further recommend measures that promote a strong regional financial system. Originality/value This paper finds the government of Kuwait to have taken major steps to create a framework that is parallel to international standards. However, there have been significant delays in activating and implementing several regulatory procedures. The delay of certain procedures has since been rectified by the state. This paper presents a comprehensive qualitative analysis of the country’s legislative, regulatory and enforcement structures and further evaluates the internal performance.

Presenting a legal and regulatory analysis of the United Arab Emirates’ past, present and future legislation on combating money laundering (ML) and terrorist financing (TF)

2020 ◽  
Vol ahead-of-print (ahead-of-print) ◽  
Author(s):  
Mohammed Ahmad Naheem
Keyword(s):  
Free Trade ◽  
United Arab Emirates ◽  
Money Laundering ◽  
Financial Institutions ◽  
International Standards ◽  
Regulatory Oversight ◽  
Content Type ◽  
Terrorist Financing ◽  
Financial Centre ◽  
Regulatory Analysis

Purpose This paper aims to study the three levels of anti-money laundering (AML) and combating of terrorist financing (CTF) regulations that apply to banks and financial institutions listed within the country. The paper aims to determine risks arising from globalised financial centres within the United Arab Emirates (UAE) and potential improvements deficiencies that may otherwise serve as conduits for criminal and terrorist organisations. There is a significant body of literature that covers the advance of AML/CTF legislation in the Dubai-based free trade zone, the Dubai International Financial Centre (DIFC). Though free trade zones are scattered across the UAE, the DIFC has the highest foreign investment in the country with an expanded international network. Design/methodology/approach The UAE has made progress as part of its fight against money laundering (ML) and terrorist financing (TF). This paper studies the legislative stance by analysing the country’s AML/CTF laws. Also, the advances of global financial centres in the UAE have created layers of regulation, each regulator with their own set of rules. This paper attempts to study the regulations and the level of their enforcement to combat ML and TF. Findings This paper finds significant regulatory oversight in certain frameworks set within the UAE’s financial system. However, the paper finds secondary literature and evaluations conducted by international bodies that suggest some deficiencies within the mechanisms, that are being resolved by the country’s regulatory agencies. The UAE’s advancing network of financial institutions has created a global chain of monetary transfers, which offers some possibility of ML also extending to TF. Though the country has made progress, there remain a few flaws that can be exploited by criminal and terrorist organisations. Practical implications ML has the possibility to damage markets if allowed in excess. This is not the case with the UAE, and large unverified transactions are investigated by the regular authorities. ML is now a matter of concern when funds acquired through illegal means may be used to directly finance terrorism. Originality/value This paper tests the UAE’s mechanisms to combat ML and TF in the context of the country’s advancing of a global central financial market. There is a need to understand these regulations as investors within the UAE and abroad may sometimes face risk if ML/TF deficiencies are exploited by criminal and terrorist organisations. This paper provides an insight into the country’s infrastructure to combat ML and TF and also weighs its performance as per international standards and guidelines.

Saudi Arabia’s efforts on combating money laundering and terrorist financing

2019 ◽  
Vol 22 (2) ◽  
pp. 233-246 ◽  
Author(s):  
Mohammed Ahmad Naheem
Keyword(s):  
Saudi Arabia ◽  
Money Laundering ◽  
Global Economy ◽  
International Standards ◽  
Content Type ◽  
Terrorist Financing ◽  
Independent Evaluation ◽  
Financing Risk ◽  
Regulatory Analysis ◽  
Combat Money Laundering

Purpose This paper aims to study Saudi Arabia’s approach to combat money laundering and terrorist financing through legislation, regulation and implementation. Saudi Arabia is an integral part of the global economy and energy market. Saudi Arabia is also an important nexus for incoming foreign investment in the region. The country has, for many years, confronted negative exposure on challenging money laundering and terrorist financing. This paper analyses Saudi Arabia’s efforts to maintain international standards of AML/CTF and distinguishes regulatory practice from the existing comments and conjecture on the country’s performance. Design/methodology/approach The paper uses a qualitative study of Saudi Arabia’s approach to combat money laundering and terrorist financing. The approach is spread across three stages of AML/CTF policy – namely, legislative, regulatory and implementation. Further, the paper also uses independent evaluation to understand Saudi Arabia’s performance in comparison to the international standards of good AML/CTF practice. Findings The paper finds Saudi Arabia in compliance with international standards of AML/CTF practice. The paper also traces strengthening of AML/CTF-related legislation and regulation in Saudi Arabia over the past two decades. The paper also finds significant evidence that suggests a biased representation of Saudi Arabia’s AML/CTF practices. The factual analysis of Saudi Arabia and its AML/CTF practice is in contradiction of the established discourse on the country’s money laundering and terrorist financing risk profile. Practical implications The paper presents a legislative and regulatory analysis of Saudi Arabia’s AML/CTF practice. It is important to understand the implications of injudicious conjecture on Saudi Arabia’s financial strategy to diversify the country’s economy (Mouawad, 2005). Commentators and observers must consider the evidence presented in this paper and reassess the discourse regarding Saudi Arabia’s adherence to international standards of AML/CTF. Originality/value Understanding Saudi Arabia’s approach to combat money laundering and terrorist financing is essential to the factors that maintain stability in the Middle East. Saudi Arabia has participated in the region with government forces to maintain stability. The paper examines the overall risk as per international standards, which can be attributed to Saudi Arabia’s AML/CTF profile.

Analysis of Bahrain’s anti-money laundering (AML) and combatting of terrorist financing (CTF) practices

2020 ◽  
Vol ahead-of-print (ahead-of-print) ◽  
Author(s):  
Mohammed Ahmad Naheem
Keyword(s):  
Money Laundering ◽  
Financial Services ◽  
Legal Framework ◽  
International Standards ◽  
Content Type ◽  
Terrorist Financing ◽  
East Region ◽  
Compliance Level ◽  
Terrorism Financing ◽  
Enforcement Mechanisms

Purpose This paper aims to examine the level of anti-money laundering (AML) and combatting terrorist financing (CTF) practices incorporated within the legal framework of the Kingdom of Bahrain. The paper also studies the application of AML/CTF legislation in regulatory practice and implementation. Bahrain is an important state within the Middle-East region and is an integral part to the Gulf Cooperation Council (GCC). The paper analyzes Bahrain’s compliance to international AML/CTF standards and presents recommendations on remaining deficiencies. Design/methodology/approach The paper studies the level of AML/CTF legislation enacted by the Kingdom of Bahrain by first examining the regulatory application, and then, the level of implementation. To understand the level of AML/CTF implementation, the paper uses literature on increased prosecution, penalties and reports for AML/CTF crimes in the Kingdom of Bahrain. In addition, the paper analyzes Bahrain’s compliance level to international standards of AML/CTF legislation and regulation. Findings The paper finds evidence of significant progress in the application of best practices of AML/CTF within the Kingdom of Bahrain. The paper also finds an increase in levels of implementation – i.e. suspicious transaction reports, investigations and prosecutions – with respect to AML/CTF violations. Additionally, the paper finds a limited number of deficiencies in Bahrain’s effort to establish strong reporting and enforcement mechanisms. Practical implications Bahrain is an important member of the international trade network and one of the fastest growing non-oil economies in the region. The country sought to diversify the economy, with more industry- and service-intensive sectors. The level of AML/CTF implementation represents an important risk-averse approach to financial services in the country. Evidence of the country’s strengthening approach is an important factor in determining foreign investment confidence and the country’s policy on combatting terrorism financing. Originality/value Commentators have previously recognized key deficiencies in Bahrain’s enactment and application of AML/CTF legislation. However, the analysis does not incorporate externalities arising from regulatory delay in domestic AML/CTF policy. The following paper studies the progress made by Bahrain since 2000-2001 and subsequent attempts at improving enforcement to maintain international compliance.

scholarly journals Using crime script analysis to elucidate the details of Amur tiger poaching in the Russian Far East

Crime Science ◽  
2021 ◽  
Vol 10 (1) ◽  
Author(s):  
Allison Skidmore
Keyword(s):  
Russian Far East ◽  
Far East ◽  
Structured Interviews ◽  
Wildlife Crime ◽  
Script Analysis ◽  
Forest Regions ◽  
Weak Points ◽  
Crime Script ◽  
Crime Script Analysis ◽  
The Russian Far East

AbstractPoaching is the most direct threat to the persistence of Amur tigers. However, little empirical evidence exists about the modus operandi of the offenders associated with this wildlife crime. Crime science can aid conservation efforts by identifying the patterns and opportunity structures that facilitate poaching. By employing semi-structured interviews and participants observation with those directly involved in the poaching and trafficking of Amur tigers in the Russian Far East (RFE), this article utilizes crime script analysis to break down this criminal event into a process of sequential acts. By using this framework, it is possible account for the decisions made and actions taken by offenders before, during and after a tiger poaching event, with the goal of identifying weak points in the chain of actions to develop targeted intervention strategies. Findings indicate poaching is facilitated by the ability to acquire a firearm, presence of roads that enable access to remote forest regions, availability of specific types of tools/equipment, including heat vision googles or a spotlight and a 4 × 4 car, and a culture that fosters corruption. This crime script analysis elucidates possible intervention points, which are discussed alongside each step in the poaching process.

Measures to combat money laundering and terrorist financing in Palestine

2021 ◽  
Vol ahead-of-print (ahead-of-print) ◽  
Author(s):  
Murrar Firas
Keyword(s):  
Money Laundering ◽  
Task Force ◽  
Evaluation Process ◽  
Vital Role ◽  
Assessment Process ◽  
National Committee ◽  
Content Type ◽  
Terrorist Financing ◽  
Mutual Evaluation ◽  
Combat Money Laundering

Purpose The purpose of this paper is to analyse the evolution of anti-money laundering/combating the financing of terrorism (AML/CFT) procedures in Palestine since 2004 in accordance with the standards issued by the Financial Action Task Force (FATF). Design/methodology/approach This study is qualitative in nature and involves studying the most important improvements made by Palestinian authorities in the state’s legislative and institutional frameworks to enhance the AML/CFT regime. Findings Palestine has established the necessary legal basis to combat money laundering and terrorist financing crimes. At the institutional level, the Financial Follow-up Unit was granted all the required powers of Financial Intelligence Units. The National Committee for Combating Money Laundering and Financing Terrorism has also played a vital role in issuing policies and plans to respond to the outcomes of the National Risk Assessment process. In contrast, a number of challenges still exist mainly with respect to the political factors and their expected consequences on the process of preparing for and conducting the mutual evaluation process for Palestine. Originality/value This study focusses on the AML/CFT efforts in Palestine owing to the nature and specificity of the Palestinian situation, as Palestine’s AML/CFT procedures have not been subject to any previous mutual evaluation process by the MENAFATF. Such efforts have rarely addressed the Palestinian case, making this study important to researchers and those interested in this field.

Porch pirates: examining unattended package theft through crime script analysis

2022 ◽  
pp. 106-122
Author(s):  
Ben Stickle ◽  
Melody Hicks ◽  
Amy Stickle ◽  
Zachary Hutchinson
Keyword(s):  
Script Analysis ◽  
Crime Script ◽  
Crime Script Analysis
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