The Pandora Papers: How Anti-Money Laundering Procedures and Controls Should Have Flagged $300 Million Earlier
19 Pages Posted: 9 Feb 2022 Last revised: 14 Feb 2022
Date Written: December 5, 2021
PURPOSE – This paper aims to discuss the risk-based policies, procedures, and controls reasonably designed to identify and minimize money laundering and other illicit financing risks associated with Non-profit Organizations.
DESIGN/METHODOLOGY/APPROACH – This paper uses the “Pandora Papers” to illustrate the vulnerability of the banking system to money laundering and other illicit financing risks associated with Non-Profit Organizations, and to solidify the hypothesis that effective implementation of risk-based policies, procedures, and controls can help flag illicit funds before a lengthy asset recovery process becomes necessary.
FINDINGS – This paper determined that adequate policies, procedures, and controls, if implemented, could help manage the money laundering and other illicit financing risks associated with Non-Profit Organizations, and ensure monitoring systems are set up to adequately detect suspicious transactions.
ORIGINALITY/VALUE – This paper uses the “Pandora Papers” to help build awareness with the regulatory, enforcement and customs authorities as well as reporting entities about the risks and vulnerabilities of Non-Profit Organizations, and how to mitigate them. This is the only Article to adopt this kind of approach.
Keywords: Pandora Papers, Money Laundering, Offshore Structures, Banks, Transaction Monitoring system, Manual-Monitoring Process, Filtering Criteria, Thresholds, Training, Independent Testing
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