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

See all articles by Ehi Esoimeme

Ehi Esoimeme

University of Wales System - Cardiff Law School

Date Written: December 5, 2021

Abstract


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

Suggested Citation

Esoimeme, Ehi, The Pandora Papers: How Anti-Money Laundering Procedures and Controls Should Have Flagged $300 Million Earlier (December 5, 2021). Available at SSRN: https://ssrn.com/abstract=3978080 or http://dx.doi.org/10.2139/ssrn.3978080

Ehi Esoimeme (Contact Author)

University of Wales System - Cardiff Law School ( email )

PO Box 427
Cardiff, Wales CF10 3AX
United Kingdom

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