Search results

The purpose of this paper is to systematically study the research and development history of suspicious transaction reporting (STR) system in China, and introduce the core elements in constructing an intelligent surveillance system which could provide a solution to the situation of low effectiveness and efficiency in Chinese Financial Institutions (FIs) STR procedure nowadays. The solution outputs those falling out of the normal customer behavior profiles instead of only extracting data by the rules issued by authorities.

This paper reviews the latest literature, regulations and guidelines of STR gathered domestically and overseas, and hands out questionnaire surveys to hundreds of software vendors, regulators and FIs, details the current situation of poor deployment of intelligent in China and tells the difficulties of subjective STR decision procedures.

Few Chinese FIs have deployed real intelligent STR systems, most are using rule-based filtering systems conformed to the objective STR supervisory regulations. To change the embarrassing situation, the regulators have tried to introduce self-regulatory mode which allows the FIs to define STR decision procedures themselves. Limited by the FIs’ ability of information sharing and investigation scope, FIs could hardly unveil the whole schema of a money laundering organization. The pursuant objective FIs can reach is to construct a system that could tell what the normal customer behaviors look like and extract all those falling out of the system’s expectations as suspicious activities.

Only the core elements of the total intelligent STR system are discussed, that is, what, why and how about the customer behavior pattern recognition system. Besides this, a total solution should also use a watch list, reporting decision, cases management, risk control, etc.

This paper for the first time argues that the orientation of regulatory rules in China has actually hindered the spreading of really effective intelligent system for these years. The author creatively puts forward a solution to the difficult problem for FIs to spot criminal schema directly, instead the FIs should only be required to determine whether the transactions carrying out currently are falling within the expected behavior pattern scopes, which is under the FIs’ capabilities due to the internationally accepted obligations of “Know Your Customer”.

In 2019, FIU-the Netherlands celebrated its 25th anniversary. This study takes the occasion to reflect on the role of the FIU in financial surveillance and to describe its core practices of collecting, analysing and disseminating financial intelligence.

Because FIU practices are often secret and its transaction data classified as state secrets, the FIU’s daily operational activities remain obscure. Drawing on interviews, public reports and an online training course, this study encircles secrecy and offers a fine-grained analysis of the FIU's core activities.

The article finds that the FIU plays a pivotal role in financial surveillance because it can operate at various intersections. An FIU operates at the intersection of finance and security, in between the public and private sector and at the national and international domain. This pivotal role makes the FIU indispensable in the surveillance of payment systems and spending behavior.

The article poses that the desirability and effectiveness of financial surveillance has to date not received sufficient consideration, while it affects (the privacy of) anyone with a bank account. The article asks: is it ethically justifiable that transaction information is declared suspect, investigated, and shared nationally and internationally, without the individual or entity concerned officially being notified and legally named a suspect?

This case-study is not only relevant for the study of finance/security, AML/CFT and financial surveillance, but also to policy makers and the broader public who merit an understanding of how their financial behaviour is being surveilled.

This chapter examines the ‘new lateral surveillance’, spearheaded by government anti-terrorism campaigns urging citizens to report any suspicious people and objects they encounter. Drawing a comparison between this and the community crime prevention (CCP) programmes of past decades, the chapter discusses the likely effectiveness of such campaigns in controlling crime and increasing security, suggests an alternative interpretation and discusses the consequences of the culture of suspicion generated by this form of surveillance. It concludes that the new lateral surveillance is a form of ‘high policing’ that is both political and dangerous in its vulnerability to errors.

This paper consists of two parts, the second of which will be published in the next issue of this Journal (Volume 3, Number 3). The second part of this paper will deal with the legal framework of the European Union.

To raise awareness of money laundering and terrorism financing (ML/TF) controls and regulations in Singapore for digital payment token (DPT) service providers.

This article summarizes the key points in the guidance infographic published by the Monetary Authority of Singapore on strengthening the AML/CFT controls of DPT service providers (Infographic). In line with the Infographic, these points pertain to: (1) recent developments in the Financial Action Task Force (FATF) Standards; (2) ML/TF risks in the DPT sector; and (3) an overview of MAS’ measures to address such risks, which include (i) licensing and supervision; (ii) AML/CFT notice and guidelines; and (iii) surveillance.

To combat illicit activities in Singapore’s DPT sector, the MAS has introduced AML/CFT measures that are aligned with the FATF Standards. DPT service providers should be cognizant of these regulations in developing their own internal measures.

Practical guidance from experienced lawyers in the Technology Transactions and Financial Services Regulatory & Enforcement practices.

Apart from presenting an overview and background on anti-money laundering (AML) rules and procedures for casinos in both Macao and the USA, this paper aims to examine the differences in their regulatory approaches with regard to their existing AML reporting processes and discusses possible weaknesses in their respective regulatory regime.

Given that the regulations and statistics on the AML issues may not all be publicly available, the authors managed to secure some data from the bureaus concerned through published reports and interviews with government officials. Regarding the AML procedures in casinos, the authors attempted to go over the annual reports published by the casinos for submission to the Hong Kong Stock Exchanges and Clearing Limited because all these casinos are listed companies in Hong Kong.

This paper analyzes the trends in reporting numbers and the categorization of the types of suspicious activity reports filed both in Macao and the USA. While the US suspicious activity reporting focuses on efforts to avoid currency reporting, Macao emphasizes improper or inadequate documentation and identification.

This paper is one of the few articles comparing the AML rules and procedures between casinos in the USA and Macao. It seeks to highlight the differences in their regulatory approaches and discusses the expected future direction of AML legislation.

To explore how lawyers are used to launder the proceeds of criminal activity. Regulatory measures that compel legal professionals to report suspected money laundering, and the implications this has for solicitor‐client privilege, are also addressed.

Data were collected from a sample of Royal Canadian Mounted Police proceeds of crime (POC) case files using a standardized questionnaire.

A statistical analysis reveals that lawyers came into contact with the POC in 49.7 percent of all RCMP cases examined. Lawyers are implicated in money laundering (both wittingly and unwittingly) primarily through their role as an intermediary in a commercial or financial transaction. In the majority of these cases, lawyers were facilitating a real property transaction by an individual engaged in drug trafficking. Lawyers were also used by offenders or their nominees to incorporate companies, purchase securities, and conduct bank transactions, including those pertaining to legal trust accounts.

The analysis of money laundering is based exclusively on an analysis reliance of police cases. The RCMP database from which the sample was drawn was not as complete as originally thought.

Associations representing the legal profession have vehemently resisted mandatory reporting obligation, arguing that it abrogates solicitor‐client privilege. This paper supports the tacit consensus emerging internationally that mandatory reporting for legal professionals should apply only to the financial and commercial transactions mediated by lawyers on behalf of clients.

This research helps to inform the debate over the extent to governments should mandate lawyers to report transactions or clients that may be involved in money laundering.

The purpose of this paper is to demonstrate the technical feasibility of implementing multi-view visualization methods to assist auditors in reviewing the integrity of high-volume accounting transactions. Modern enterprise resource planning (ERP) systems record several thousands of transactions daily. This makes it difficult to find a few instances of anomalous activities among legitimate transactions. Although continuous auditing and continuous monitoring systems perform substantial analytics, they often produce lengthy reports that require painstaking post-analysis. Approaches that reduce the burden of excessive information are more likely to contribute to the overall effectiveness of the audit process. The authors address this issue by designing and testing the use of visualization methods to present information graphically, to assist auditors in detecting anomalous and potentially fraudulent accounts payable transactions. The strength of the authors ' approach is its capacity for discovery and recognition of new and unexpected insights.

Data were obtained from the SAP enterprise (ERP) system of a real-world organization. A framework for performing visual analytics was developed and applied to the data to determine its usefulness and effectiveness in identifying anomalous activities.

The paper provides valuable insights into understanding the use of different types of visualizations to effectively identify anomalous activities.

Because this study emphasizes asset misappropriation, generalizing these findings to other categories of fraud, such as accounts receivable, must be made with caution.

This paper provides a framework for developing an automated visualization solution which may have implications in practice.

This paper demonstrates the need to understand the effectiveness of visualizations in detecting accounting fraud. This is directly applicable to organizations investigating methods of improving fraud detection in their ERP systems.

The aim of this paper is to highlight the importance of countering the dangers posed by money laundering activities and the measures taken to date by the Malaysian authorities in this respect.

The paper achieves this by looking at the current money laundering trends in Malaysia, followed by a detailed account of the initiatives taken by the Malaysian authorities to curb such activities. These proactive initiatives range from the enactment and implementation of the Anti‐Money Laundering (AML) Act 2001, the establishment of the Financial Intelligence Unit of the Central Bank of Malaysia and the Southeast Asia Regional Centre for Counter‐Terrorism which work with international enforcement agencies, to the requirement of suspicious transaction reporting amongst professional accountants and lawyers and more.

Malaysia continues to make a broad and sustained effort to combat money laundering and terrorist financing flows within its borders.

The practical implication of this paper is to stress the importance of keeping abreast with the increased challenges posed by money laundering, especially via the internet and the vital need for the banking and financial sector to invest heavily in transaction monitoring devices/software and training in AML detection, in order to tackle the menace.

This paper makes for a useful read for practitioners, academics, policymakers and students alike.

Purpose – This chapter examines the role of payment platforms in the United States in sex censorship in which platforms have a pattern of denying financial services to people and businesses involved in publishing legal sexual content. It answers the following questions: what explains payment platforms’ regulation of lawful sexual content and what are the consequences? Methodology/Approach – Drawing from the platform governance literature, this chapter closely examines the corporate policies for PayPal and the credit card companies that prohibit certain types of sexual content and services. Findings – This chapter argues that payment platforms’ censorship of sexual expression is shaped by the distinctive nature of and market concentration within the online payment industry. Payment actors’ systematic campaign of sexual censorship disproportionately affects small businesses and individual operators in the sex and adult entertainment industries and amounts to “digital redlining,” a form of financial discrimination. Originality/Value – Payment providers’ role in regulating sex online has received considerably less scholarly attention than research on social media platforms. This gap in scholarship is notable as big payment actors have systematically denied services for about a decade relating to sexually oriented goods and services (see Blue, 2015a).