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The Financial Intelligence Agency (AIF), in the National Strategy for the Prevention of Money Laundering and Terrorist Financing 2024-2030, provides information on the mechanisms used by politically exposed persons to launder money obtained through criminal acts of corruption or embezzlement of duty.
According to AIF, these persons, after completing their duties or public functions, make high value investments in a business, without a clear source of income. Another form of money laundering is the declaration of immediate high profits from businesses owned by former politically exposed persons.
Another phenomenon observed by AIF is the high turnover of funds in individual accounts declared as business income, but which are not justified by business income.
Another typology found by AIF is the initial placement of administrators or legal representatives, but also of partners of legal entities with no record of criminal activity, but obviously without proper preparation in economic or educational culture to own or develop such commercial activities , which are owned de facto by politically exposed persons and which are then transferred in their name. A part of these companies, in sporadic cases, are involved in the field of public procurement.
An important segment of corruption money laundering remains real estate. AIF notes that these individuals make investments in real estate after leaving office without a clear source of income, or make investments in real estate at declared prices that are below market value.
Regarding other entities, AIF estimates that resident individuals continue to be the largest group of entities involved in activities with potential money laundering.
The highest risk scenarios related to individuals are the purchase of assets with an unknown or unjustified source; the benefit of frequent and small value transfers from individuals without a clear connection between them; depositing cash amounts with an unknown source in a bank account; purchase of real estate under value and revaluation within a short time; financial actions (including deposits, transfers, investment in real or movable property) by persons suspected of being involved in criminal activity; high value investment in real estate through the use of third parties.
For non-resident individuals, the main scenarios related to money laundering are the creation and registration of resident legal entities and the use of their bank accounts for receiving or sending transfers from/to different jurisdictions without a clear connection to the object of the activity. society, with suspicions mainly related to fiscal evasion; making investments, mainly in real estate, without a clear source of income.
Resident legal entities, according to AIF, continue to represent the second largest number of subjects involved in possible money laundering activity, mainly with the source of income from crimes in the tax field, fraud, organized crime, corruption. Key scenarios include:
- placement of funds of unknown origin in real commercial circulation;
- investment in real estate in the name of the existing company owned by persons suspected of being involved in criminal activity at unjustified values ??with legal sources;
- the benefit of large transfers to the business account of the person suspected of being involved in criminal activity from society without a clear connection between the service or goods offered and the payment;
- the involvement of a single individual in several entities that have the same object of activity or the same address and carrying out transactions without a clear connection between the parties to the transaction;
- suspicious transfers received on account of a company that has no real economic activity;
- the use of legal entities for the benefit of transfers from abroad through fraud where the vast majority of funds are channeled abroad and a part is withdrawn in cash./ Monitor Magazine
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