In his speech at the November 2011 Anti-money laundering and counter-terrorism financing conference, ACC Chief Executive Officer John Lawler highlighted the new and unexpected methods organised criminals are using to hide their money.
He said that tax havens and the finance industry have been regarded as the traditional means of hiding proceeds of crime. However, with law enforcement and regulatory agencies having access to more information, organised criminals are looking elsewhere to launder money.
So, how are they doing it? Mr Lawler suggests looking anywhere there is money to be found.
'There are vast sums of money passing through thousands of small, medium and large enterprises and through the delivery of government services, on a daily basis. Each of these sectors is vulnerable to exploitation by organised crime,' Mr Lawler said.
'I don't want us to be constrained in where we look for organised criminal activity because there is no chance the criminals are sticking to the rule book.'
The ACC has implemented two key initiatives in conjunction with their partners to stay one step ahead of the criminals and identify potential vulnerabilities early.
The first of these is a high risk funds methodology, which focuses on the movement of money.
'By analysing data on offshore money movements we can identify anomalies which might indicate illicit funds,' Mr Lawler said.
'This is where our partnerships with agencies such as AUSTRAC, and the private sector come in, and the benefits are very tangible.'
These partnerships allow the ACC to identify more opportunities to confiscate illicit funds, better target law enforcement efforts to disrupt criminal enterprise and contribute to an enhanced strategic intelligence picture to inform long term prevention strategies.
The second initiative is the National Criminal Intelligence Fusion Capability. Fusion builds on the high risk funds methodology by drawing on a much wider data set available across government agencies.
Since July 2010 to 31 December 2011, fusion has identified 73 organised criminal targets previously unknown to law enforcement. Several of these have been identified as laundering suspected criminal proceeds in excess of $100 million annually.
Case Study: Following the money
Last year, two women were charged with running a tax avoidance syndicate on behalf of a number of clothing manufacturers. It followed a referral to the Australian Federal Police (AFP) from the Financial Intelligence Assessment Team (part of the National Criminal Intelligence Fusion Capability) which had identified a syndicate allegedly facilitating avoidance of taxation obligations for a large number of clothing manufacturing businesses.
AFP members investigated the syndicate and executed eight search warrants on residential and business premises in western Sydney, seizing over $800,000 in cash and restraining more than $200,000 in bank accounts allegedly associated with the scheme.
It will be alleged in court that the women facilitated a scheme which allowed a number of businesses to siphon legitimate company funds through a series of 'shell companies'.
Anti-money laundering and counter-terrorism financing conference
2011 marked the second conference co-hosted by the Australian Transaction Reports and Analysis Centre, ACC, AFP, the Attorney General's Department and the Australian Bankers' Association.
The conference's theme, Financial intelligence: Global and domestic partnership and practices, success and challenges, focused on how government and industry can develop partnerships to prevent and disrupt money laundering and counter terrorism financing activities.
The conference brought together domestic and international speakers from government, law enforcement and the financial services industry. Video highlights from the conference can be viewed at: www.amlconference.com.au/podcasts.