Money laundering, individuals the largest potential group, then business, the highest risk scenarios

The National Strategy for the Prevention of Money Laundering and Financing of Terrorism 2024-2030 has been part of the tables in recent weeks regarding the policies and measures that can be taken to combat the phenomenon.

In this document, which was for consultation until a few days ago, a part of the presentation is dedicated to the findings that came from the National Risk Assessment, where subjects involved in activities with potential money laundering were analyzed.  Thus, according to a passage included in the strategy, it is underlined:

Resident individuals: In Albania, they continue to be the largest group of subjects involved in activities with money laundering potential.

The highest risk scenarios related to individuals are:

• Purchase of assets from an unknown or unjustified source;

• Taking advantage of frequent and small value transfers from individuals without a clear connection between them;

• Depositing cash amounts from an unknown source in a bank account;

• Purchase of real estate under value and revaluation within a short time;

• Financial actions (deposit/transfer/investment in immovable/movable property) by persons suspected of being involved in criminal activity;

• High value investment in real estate through the use of third parties;

Resident legal entities: They continue to represent the second largest number of subjects involved in the potential activity of the PP, mainly with a source of income from crimes in the tax field, fraud, organized crime, corruption where the main scenarios include:

• Placement of funds of unknown origin in real commercial circulation;

• Investment in real estate in the name of the existing company owned by persons suspected of being involved in criminal activity at unjustified values ​​with legal sources;

• The benefit of large transfers to the business account of the person suspected of being involved in criminal activity from society without a clear connection between the service/goods offered and the payment;

• Involvement of a single individual in several entities that have the same object of activity or the same address and carrying out transactions without a clear connection between the parties to the transaction;

• Suspicious transfers received on account of a company that has no real economic activity;

• The use of legal entities for the benefit of transfers from abroad through fraud where the vast majority of funds are channeled abroad and a part is withdrawn in cash;

Non-resident individuals: The main scenarios related to this category are:

• Creation and registration of resident legal entities and the use of their bank accounts for receiving or sending transfers from/to different jurisdictions without a clear connection with the object of the company's activity with suspicions mainly related to fiscal evasion;

• Realization of mainly residential investments without a clear source of income.

Resident PEP: Due to their function, the suspected cases related to PEP are when the original offense is estimated to have been "Misuse of duty/Corruption" and among the main scenarios are:

• High value investments in a business after the end of the duty (former PEP) without a clear source of income or even the declaration of high immediate profits from a business owned by a former PEP;

• High turnover of funds in individual accounts from PEP declared by the business, but not justified by the income of the business;

• Investments in real estate after leaving office without a clear source of income;

• Investments in property from PEP with declared value below the market price;

• The initial placement of administrators/legal representatives but also of partners of legal entities with no record of criminal activity, but obviously without proper preparation in economic or educational culture to own or develop such commercial activities, which are de facto owned by PEP and which are then passed on their behalf. A part of these companies, in sporadic cases, are involved in the field of public procurement./Monitor