By Dardan Kocani

Despite efforts to prevent illicit finance – such as the adoption of international frameworks, Financial Action Task Force (FATF) standards, and the EU’s anti-money laundering (AML) directives – financial institutions in the Western Balkans remain highly vulnerable to sophisticated criminals and the inherent risks in the formal financial system. Financial institutions such as banks, microfinance institutions, cryptocurrency services, and money transfer services are frequently exploited by criminals to move illicit money across borders. This report delves into the structural weaknesses and vulnerabilities that facilitate money laundering in the Western Balkans. One major insight is the impact of cryptocurrency, where regulatory shortcomings enable anonymous, cross-border transactions that are hard to trace. Financial technology, while promising innovation, also introduces fresh risks, especially where compliance and monitoring frameworks have yet to catch up. With no centralized registry for politically exposed persons (PEPs) or beneficial owners, financial institutions often lack critical information, inadvertently providing cover for criminal actors. The study identifies specific methods used to launder money, such as smurfing through bank accounts, taking out suspicious bank loans, engaging in real estate purchases, and employing frontmen. Notable cases in the region expose systemic vulnerabilities in banks, where criminal actors leverage insider support or regulatory gaps to move substantial amounts undetected. Furthermore, public-private partnerships in AML enforcement remain insufficient, creating weak links that are frequently exploited. This report provides strategic recommendations for governments, financial institutions, and non-state actors in the region to address these gaps, emphasizing the need for robust inter-agency collaboration, stronger regulatory frameworks, and consistent training for AML officers. The region needs a heightened, collaborative effort to prevent local financial institutions from becoming conduits for transnational organized crime and dirty money laundering.

Geneva: Global Initiative Against Transnational Organized Crime (GI-TOC)’s Observatory of Illicit Economies in South Eastern Europe.  2024. 40p.

By Jo‑Anne Kramer,  Arjan A. J. Blokland, ·Edward R. Kleemans, Melvin R. J. Soudijn

In order to launder large amounts of money, (drug) criminals can seek help from financial facilitators. According to the FATF, these facilitators are operating increasingly business like and even participate in professional money laundering networks. This study examines the extent to which financial facilitators in the Netherlands exhibit business-like charac teristics and the extent to which they organize themselves in money laundering networks. We further examine the relationship between business-like behavior and individual money launderers’ position in the social network. Using police intelligence data, we were able to analyze the contacts of 198 financial facilitators who were active in the Netherlands in the period 2016–2020, all having worked for drug criminals. Based on social network analysis, this research shows that financial facilitators in the Netherlands can be linked in extensive money laundering networks. Based on the facilitators’ area of expertise, roughly two main types of professional money laundering networks can be discerned. Some subnetworks operate in the real estate sector, while others primarily engage in underground banking. Furthermore, the application of regression models to predict business-like behavior using individual network measures shows that facilitators with more central positions in the net work and those who collaborate with financial facilitators from varying expertise groups tend to behave more business-like than other financial facilitators

Kramer JA, Blokland AAJ, Kleemans ER & Soudijn MRJ 2023. Money laundering as a service: Investigating business-like behavior in money laundering networks in the Netherlands. Trends in Organized Crime.

By Joras Ferwerda, Alexander van Saase, Brigitte Unger & Michael Getzner

 It is important to understand the amounts and types of money laundering flows, since they have very different effects and, therefore, need different enforcement strategies. Countries that mainly deal with criminals laundering their proceeds locally, need other measures than countries that mainly deal with foreign illegal investments or dirty money just flowing through the country. This paper has two main contributions. First, we unveil the country preferences of money launderers empirically in a systematic way. Former money laundering estimates used assumptions on which country characteristics money launderers are looking for when deciding where to send their ill‑gotten gains. Thanks to a unique dataset of transactions suspicious of money laundering, provided by the Dutch Institute infobox Criminal and Unexplained Wealth (iCOV), we can empirically test these assumptions with an econometric gravity model estimation. We use this information for our second contribution: iteratively simulating all money laundering flows around the world. This allows us, for the first time, to provide estimates that distinguish between three different policy challenges: the laundering of domestic crime proceeds, international investment of dirty money and money just flowing through a country  

Ferwerda J, van Saase A, Unger B & Getzner M 2020. Estimating money laundering flows with a gravity model-based simulation. Scientific Reports 10(1).