APG Yearly Typologies Report

2021

Methods and Trends of

Money Laundering and
Terrorism Financing

Asia/Pacific Group on Money Laundering

July 2021
Applications for permission to reproduce all or
part of this publication should be made to:

DISCLAIMER:
APG Secretariat
Locked Bag A3000 Under Article 1 of the APG Terms of Reference 2012, the APG is a
Sydney South non-political, technical body, whose members are committed to
the effective implementation and enforcement of the
New South Wales 1232
internationally accepted standards against money laundering,
AUSTRALIA financing of terrorism and proliferation financing set by the
Financial Action Task Force. This document, any expression
Tel: +61 2 5126 9100 herein, and/or any map included herein, are without prejudice to
Email: mail@apgml.org the status of, or sovereignty over, any territory, to the delimitation
of international frontiers and boundaries and to the name of any
Web: www.apgml.org
territory, city or area.

© July 2021/All rights reserved 2

CONTENTS
CONTENTS.................................................................................................................................... 3
INTRODUCTION.......................................................................................................................... 5
1. PROLIFERATION FINANCING RISK .............................................................................. 6
1.1 Risk Assessments and Proliferation Financing ..................................................................................................... 6
1.2 Amendments to the Standards ........................................................................................................................... 7
1.3 UN Panel of Experts Reports ............................................................................................................................... 7
1.4 PF Risk Assessments in the Asia Pacific ............................................................................................................. 10
1.5 Guidance and training provided to FIs and DNFBPs .......................................................................................... 14

2. UPDATE ON COVID-19 IMPACT ON ML/TF TYPOLOGIES ..................................... 16

3. APG WORKSHOPS AND PROJECTS 2020 - 2021 ............................................................ 17
3.1 Typologies Projects ............................................................................................................................................ 17
3.2 22nd Typologies and Capacity Building Workshop ............................................................................................ 18

4. FATF, FSRBS AND OBSERVERS’ PROJECTS ................................................................ 19

4.1 FATF Typology Projects...................................................................................................................................... 19
4.2 Middle East and North Africa Financial Action Task Force ................................................................................ 24
4.3 Eurasian Group on combating money laundering and financing of terrorism .................................................. 25
4.4 Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism
........................................................................................................................................................................... 26
4.5 Egmont Group ................................................................................................................................................... 27
4.6 Inter-Governmental Action Group against Money Laundering in West Africa ................................................. 29

5. MONEY LAUNDERING AND TERRORISM FINANCING METHODS ..................... 30

5.1 Use of offshore banks, international business companies, and offshore trusts, including trust company service
providers............................................................................................................................................................ 30
5.2 Use of virtual assets (cryptocurrencies). ........................................................................................................... 32
5.3 Use of professional services (lawyers, notaries, accountants). ........................................................................ 36
5.4 Trade-based money laundering and transfer pricing. ...................................................................................... 37
5.5 Underground banking / alternative remittance services / hawala. .................................................................. 40
5.6 Use of the internet (encryption, access to IDs, international banking etc). ..................................................... 43
5.7 Use of new payment methods / systems. ........................................................................................................ 43
5.8 Laundering of proceeds from tax offences. ...................................................................................................... 45
5.9 Real estate, including roles of real estate agents. ............................................................................................ 47
5.10 Trade in gems and precious metals. ................................................................................................................. 49
5.11 Association with human trafficking and people smuggling. ............................................................................. 50
5.12 Use of nominees, trusts, family members or third parties etc. ........................................................................ 50
5.13 Gambling activities (horse racing, internet gambling, etc). .............................................................................. 52
5.14 Purchase of valuable assets (art works, antiquities, race horses, vehicles, etc)............................................... 54
5.15 Investment in capital markets, use of brokers. ................................................................................................ 54
5.16 Mingling (business investment). ....................................................................................................................... 56
5.17 Use of shell companies/corporations. .............................................................................................................. 56
5.18 Association with environmental crimes (illegal logging, extraction, wildlife trafficking, etc.). ........................ 59
5.19 Currency exchanges / cash conversion. ............................................................................................................ 61
5.20 Use of credit facilities, credit cards, cheques, promissory notes etc. ............................................................... 62
5.21 Wire transfers / Use of foreign bank accounts. ................................................................................................ 64
5.22 Use of false identification. ................................................................................................................................ 65
5.23 Association with corruption/bribery ................................................................................................................ 67
5.24 Abuse of non-profit organisations (NPOs). ....................................................................................................... 72

6. PROLIFERATION FINANCING METHODS & TRENDS ............................................ 73

6.1 Case studies of breaches, non-implementation or evasion of targeted financial sanctions related to
proliferation financing. ...................................................................................................................................... 73

7. MONEY LAUNDERING & TERRORISM FINANCING TRENDS .............................. 76

7.1 Recent research or studies on ML/TF methods and trends. ............................................................................. 76
7.2 Association of types of ML or TF with particular predicate activities (eg terrorist organisations, terrorist
training, corruption, drugs, fraud, smuggling, etc). ........................................................................................... 82
3
7.3 Emerging trends; declining trends; continuing trends. ..................................................................................... 92

8. EFFECTS OF AML/CFT COUNTER-MEASURES ........................................................ 96

8.1 The impact of legislative or regulatory developments on detecting and/or preventing particular methods (eg
tracing proceeds of crime, asset forfeiture etc). ............................................................................................... 96
8.2 Cases developed directly from suspicious or cash/threshold transaction reports. ......................................... 102

9. COVID-19 RELATED ML & TF TRENDS ..................................................................... 106

9.1 Association of types of ML or TF with particular predicate activities linked to COVID-19 (e.g. welfare fraud,
scams, counterfeit medicines, corruption, drugs, smuggling, etc). ................................................................. 106
9.2 Displacement of ML or TF methodologies to established typologies (e.g. increase in reporting of the internet
for ML/TF as use of cash decreases, impact of lockdowns and border closures on smuggling and trafficking,
etc.).................................................................................................................................................................. 120
9.3 Any research or reports conducted on the impact of pandemics, natural disasters or economic crises on
ML/TF trends and typologies. .......................................................................................................................... 120

10. ABBREVIATIONS AND ACRONYMS ........................................................................... 122

4
INTRODUCTION

1 The APG is the FATF-style regional body for the Asia/Pacific. One of the mandates of
the APG is to publish regional ML and TF typologies reports to assist governments and other
stakeholders to better understand the nature of existing and emerging ML and TF threats and
pursue effective strategies to address those threats. When a series of ML or TF arrangements
are conducted in a similar manner or using the same methods they are generally classified as a
typology. Typologies studies assist APG members to implement effective strategies to
investigate and prosecute ML and TF, as well as design and implement effective preventative
measures.

2 Each year APG members and observers provide case studies, observations on trends,
research, information on regulatory enforcement action, and examples of international
cooperation. The information collected provides a basis for further study of particular and high
priority topics.

3 The case studies featured in this report are a small part of the work by law enforcement
and intelligence agencies in the Asia/Pacific and other regions to detect and combat ML and
TF. Many cases cannot be shared publicly due to their sensitive nature or to ongoing
investigative/judicial processes.

4 This report includes a brief chapter on understanding risks associated with proliferation
financing in light of the amendments to Recommendation 1 and its Interpretive Note (INR.1)
adopted by the FATF on 23 October 2020.

5 The APG Operations Committee has oversight of the typologies research programme
and is Co-Chaired by Samoa and New Zealand (2020-2021).

APG Typologies Report 2021 5

1. PROLIFERATION FINANCING RISK

1.1 Risk Assessments and Proliferation Financing

Until recently, the FATF framework used a foundation of risk to assess responses to ML and
TF This expectation did not extend to proliferation financing (PF). On 23 October 2020, the
FATF adopted amendments to Recommendations 1 and 2 (R.1 and R.2) to require jurisdictions,
financial institutions (FIs), designated non-financial businesses and professions (DNFBPs) and
virtual asset service providers (VASPs) to identify and assess the risks of potential breaches,
non-implementation or evasion of the targeted financial sanctions (TFS) related to PF, as
contained in FATF Recommendation 7 (R.7), and to take action to mitigate these risks. In this
context, the typologies related to PF TFS have attracted renewed interest.

Obligations aimed at countering the financing of proliferation of weapons of mass destruction

(WMD) under R.7 focus on jurisdictions’’ implementation of two jurisdiction-specific regimes
created by United Nations Security Council Resolutions (UNSCRs): the Democratic People’s
Republic of Korea (DPRK)1 and Iran.2 Broadly, R.7 requires jurisdictions to freeze, without
delay, the funds or other assets of, and ensure that no funds and other assets are made available,
directly or indirectly to, or for the benefit of (a) any person or entity designated by the United
Nations Security Council (UNSC), (b) persons and entities acting on their behalf or at their
directions and/or (c) those owned or controlled by them.

PF risks as set out in R.1 include:

 The risk of a potential breach or non-implementation of TFS: this risk may materialise
when designated entities and individuals access financial services, and/or funds or other
assets, as a result, for example, of a delay in communication of designations at the national
level, lack of clear obligations on FIs and DNFBPs, failure on the part of FIs and DNFBPs
to adopt adequate policies and procedures to address their PF risks (e.g. weak customer
on boarding procedures and ongoing monitoring processes, lack of staff training,
ineffective risk management procedures, lack of a proper sanctions screening system or
irregular or inflexible screening procedures and a general lack of compliance culture);

 Risk of evasion of TFS: this risk may materialise due to concerted efforts of designated
persons and entities to circumvent TFS (e.g. by using shell or front companies, joint
ventures, dummy accounts, middlemen and other fraudulent intermediaries).

This chapter provides a brief introduction to the new obligations and an overview of typological
and risk assessment work being undertaken in our region or relevant for our region. In
particular, the APG has collaborated with the Royal United Services Institute (RUSI) to
showcase some research on PF typologies and PF TFS implementation.

1
See UNSCR 1718 (2006)
2
See UNSCR 2231 (2015)

APG Typologies Report 2021 6

1.2 Amendments to the Standards

The new elements of R.1 require governments to identify, assess, and understand the PF risks
for the jurisdiction, in addition to existing requirements under R.7 in relation to TFS
frameworks. The amendments also require jurisdictions to place obligations on FIs, and
DNFBPs and VASPs to identify and assess the risks of potential breach, non-implementation
or evasion of TFS when dealing with their customers, and taking appropriate mitigating
measures in line with the level of risks identified.3 Importantly, in the context of R.1, ‘PF risk’
refers strictly and only to the potential breach, non-implementation or evasion of the targeted
financial obligations referred to in R.7.

The FATF published its ‘Guidance on proliferation financing risk assessment and mitigation’4
on 29 June 2021 to assist the public and private sectors in implementing the new requirements
to identify, assess and mitigate PF as defined in R.1 and INR.1. 5 Notably, this 2021 Guidance
provides an updated list of key indicators relevant to identifying instances of PF.6

The changes to the FATF Recommendations will come into effect for the purposes of the 4th
round of APG mutual evaluations.7

1.3 UN Panel of Experts Reports

As noted above, the obligations in the FATF under R.7 relate to UNSCRs that focus on two
specific jurisdictions: DPRK (UNSCR 1718) and Iran (UNSCR 2231). In endorsing the Joint
Comprehensive Plan of Action, UNSCR 2231 terminates previous provisions of resolutions
relating to Iran and WMD proliferation, including UNSCRs 1737 (2006), 1747 (2007), 1803
(2008) and 1929 (2010), but retained TFS on a number of individuals and entities designated
pursuant to these resolutions and also established new specific restrictions, including a number
of other measures. However, the obligations in relation to DPRK remain broad.

The UN Security Council 1718 Sanctions Committee is tasked with oversight of the sanctions
measures designed to prevent the DPRK from accessing materials and items for their WMD
programmes. The Committee is supported by a Panel of Experts responsible for gathering
information from member states and other sources on the implementation of the 1718 sanctions
and where there have been examples of non-compliance.

3
https://www.fatf-gafi.org/publications/financingofproliferation/documents/statement-proliferation-financing-
2020.html
4
https://www.fatf-gafi.org/publications/fatfrecommendations/documents/proliferation-financing-risk-
assessment-mitigation.html
5
https://www.fatf-gafi.org/publications/fatfgeneral/documents/public-consultation-proliferation-financing-
risk.html
6
See also, FATF’s 2008 Typologies Report on Proliferation Financing (accessible at https://www.fatf-
gafi.org/publications/methodsandtrends/documents/typologiesreportonproliferationfinancing.html), and the
FATF’s 2018 Guidance on Counter Proliferation Financing - The Implementation of Financial Provisions of
United Nations Security Council Resolutions to Counter the Proliferation of Weapons of Mass Destruction
(accessible at https://www.fatf-gafi.org/publications/financingofproliferation/documents/guidance-counter-
proliferation-financing.html)
7
As part of a phased approach, FATF will begin assessing jurisdictions for implementation of these
requirements at the next (5th) round of mutual evaluations, to allow time for governments to take the necessary
domestic measures.

APG Typologies Report 2021 7

The Panel of Experts produce a report, which is generally issued as a mid-term and final report,8
detailing the trends and methodologies by which DPRK has sought to obtain the resources
required to further their nuclear, ballistic and other WMD programmes. These reports have
observed the activities DPRK employs to obtain both the materials (including dual-use goods)
and the technology (including the intellectual property of foreign experts) to support and
expand the proliferation of WMD. Importantly, these reports have a section, typically titled
‘Finance’, specifically dedicated to the manner in which DPRK is able to access international
financial systems. Funds raised from sanctions evasion activities and laundered through these
networks support the DPRK’s nuclear, ballistic and other WMD programmes.

The Panel of Experts Report gathers, examines and analyses open source material, information
from proactive and reactive submissions of UN member states, relevant UN bodies and other
interested parties regarding the implementation of the measures, and in particular, on incidents
of non-compliance to identify the methods by which DPRK accesses these materials. Where
the Panel of Experts investigation reveals the suspected involvement of an entity or person in
a member state, it will make a request to the member state for further information or action.
The Panel of Experts also receives information and data proactively from member states to
assist in its investigations.9

In recent years, the reports have identified emerging and changing trends and typologies
utilised by DPRK to facilitate its PF including some of note to the APG membership. DPRK
continues to utilise complex corporate vehicles, including joint ventures, offshore accounts,
shell companies, and overseas banking representatives to disguise its ongoing access to
international finance systems in order to raise funds and further its PF activities. Lastly, the
increasing use by DPRK of cyber activities against FIs targeting virtual assets (VAs) and
virtual asset service providers (VASPs) and exchanges including the theft and laundering of
cryptocurrencies into fiat currencies is becoming a significant PF typology.

8
https://www.un.org/securitycouncil/sanctions/1718/panel_experts/reports
9
https://www.un.org/securitycouncil/sanctions/1718/panel_experts/work_mandate
APG Typologies Report 2021 8
 RUSI: CRYPTOCURRENCY AND PF

The use of cryptocurrency to evade sanctions and raise revenue is a feature of modern day PF.
In 2019, RUSI published a landmark study on DPRK’s cryptocurrency activities in Southeast
Asia.10 This study set out the various steps in PF where cryptocurrencies can be abused:

 Acquisition: Cybercrime is unquestionably the most prevalent method of sanctioned actors

obtaining cryptocurrencies, especially by hacking cryptocurrency exchanges in East Asia.
DPRK has also been involved in ransomware campaigns, such as WannaCry, 11 and has
been particularly interested in phishing and online fraud in the last few years.12
 Movement typologies: Like traditional money laundering, large-scale cryptocurrency
launderers such as DPRK use layering as a technique.13 Attackers create thousands of
transactions in real time through one-time use cryptocurrency wallets.14 They are then able
to muddy their tracks and break the transaction path.
 Exchanges: It has become increasingly clear that DPRK relies heavily on unregulated15 or
noncompliant16 exchanges to launder funds, as well as peer-to-peer exchanges. Lack of
regulation in many jurisdictions makes this pursuit relatively easy.
 Liquidation speed: DPRK generally cashes their cryptocurrency into fiat currency or
another cryptocurrency relatively quickly,17 with liquidation speed increasing recently.
There appears to be little interest in stockpiling cryptocurrency for future use.
 Scale: According to the most recent analysis,18 DPRK hackers are estimated to have stolen
at least $1.75 billion from cryptocurrency exchanges.

10
https://rusi.org/publication/occasional-papers/closing-crypto-gap-guidance-countering-north-korean-
cryptocurrency
11
https://www.washingtonpost.com/world/national-security/us-set-to-declare-north-korea-carried-out-massive-
wannacry-cyber-attack/2017/12/18/509deb1c-e446-11e7-a65d-
1ac0fd7f097e_story.html?utm_term=.cd703dfb03a2
12
https://www.justice.gov/usao-cdca/pr/3-north-korean-military-hackers-indicted-wide-ranging-scheme-
commit-cyberattacks-and
13
https://www.swift.com/sites/default/files/files/swift_bae_report_Follow-The%20Money.pdf
14
https://www.justice.gov/opa/press-release/file/1253491/download
15
https://www.elliptic.co/blog/following-money-from-bithumb-hack
16
https://www.justice.gov/opa/pr/two-chinese-nationals-charged-laundering-over-100-million-cryptocurrency-
exchange-hack
17
https://go.chainalysis.com/2021-Crypto-Crime-Report.html
18
https://www.forbes.com/sites/thomasbrewster/2021/02/09/north-korean-hackers-accused-of-biggest-
cryptocurrency-theft-of-2020-their-heists-are-now-worth-175-billion/?sh=691163865b0b

APG Typologies Report 2021 9

The reports also flag the continued exploitation of the shipping industry through ship-to-ship
transfers, laundering of ship identification, manipulating flags and vessel identifiers, and
technological methods of deceiving automatic identification system tracks. In clarifying the
ambit of ‘financing’ as covered by UNSCRs, UNSCR 2270 affirms that the term ‘economic
resources’19 include assets of every kind, which potentially may be used to obtain funds, goods,
or services and specifies that this includes maritime vessels.

RUSI: Shipping and PF

RUSI’s Project Sandstone uses open source data-mining and data-fusion techniques to spot
DPRK sanction evasion activities, particularly in the maritime space. The project aims to
provide open-source intelligence and actionable evidence to those engaged in enforcement and
the policy community in general. Investigations in Project Sandstone include research into
DPRK’s oil procurement networks, typologies for the movement of DPRK funds through the
international finance system, and the significance of the city of Dandong in trading companies
associated with PF.20

In the APG region, the MERs of China and Singapore were able to draw on the work done by
the Panel of Experts report to understand the level of effectiveness under IO 11. For example
the Panel of Experts reports have been mentioned in MERs to the extent that they contained
examples of accounts, funds or assets held by designated entities in the assessed jurisdiction,
and (front) companies run by designated entities in that jurisdiction.21 Further, requests by the
Panel of Experts for information about alleged links with designated entities have led to
authorities taking compliance action domestically.22

1.4 PF Risk Assessments in the Asia Pacific23

Indonesia

In 2020, Indonesia initiated a PF risk assessment and a subsequent update of the existing
ML/TF risk assessment. The methodology on Indonesia’s PF risk assessment is similar to
Indonesia’s ML/TF risk assessment that identifies the risk based on vulnerability level, threat
level, and impact level through quantitative and qualitative information. This methodology is
also similar to the FATF methodology for conducting national risk assessments (NRAs). The
development of the PF risk assessment involves the following stakeholders: the Indonesian
National Police (Special Detachment 88 Anti-Terror, State Intelligence and Security Agency
of the Indonesian National Police), BIN (State Intelligence Agency), Ministry of Foreign

19
The term is clarified specifically for the purposes of paragraph 8(d) of UNSCR 1718 which, in broad terms,
places a freezing obligation on Member States in relation to funds, other financial assets and economic resources
connected to PF by DPRK.
20
https://rusi.org/project/project-sandstone
21
China MER paragraph 274: http://apgml.org/includes/handlers/get-document.ashx?d=5b27e83d-c28b-4e87-
9549-20839d4bd92c
22
Singapore MER paragraph 288: http://apgml.org/includes/handlers/get-document.ashx?d=1280e446-2110-
430c-b709-3a777b85a020
23
This section includes contributions from APG members on their work to implement the amendments in R.1
and R.2. The APG has not reviewed or assessed the work on PF risk summarised by members here.

APG Typologies Report 2021 10

Affairs, Directorate General on Customs and Excise (Ministry of Finance) and regulators of
financial services providers and DNFBPs as reporting entities (Bank Indonesia/Central Bank,
Financial Services Authority, PPATK, etc.), and representatives from FIs and DNFBPs.

Indonesia identified 3 levels of PF risk that consist of 9 quadrants which are, low level (score
3-5), medium level (score 5-7), and high level (score 7-9). The scope of Indonesia’s PF risk
assessment is limited to the effectiveness of TFS related to PF, as required by R.7. The PF risk
assessment excludes the wide scope of PF risk as mentioned in UNSCR 1540 and its successor.
Nevertheless, Indonesia considered the volume and materiality of dual use goods trading,
specifically to Iran and DPRK as designated jurisdictions based on customs and excise
information. In conducting the PF risk assessment, Indonesia also utilised cross-border cash
courier (CBCC) information, specifically related to individuals or entities associated with Iran
and DPRK.

Overall, Indonesia identified a medium level of PF risk, considering existing diplomatic and
economic relationships with Iran and DPRK, and the jurisdiction’s geographic proximity to
DPRK. Indonesia also identified a potential threat arising from the accounts of former foreign
diplomats who are no longer serving in Indonesia and have subsequently been misused by other
parties. Nevertheless, some PF risk mitigation has been conducted, such as issuing the Joint
Regulation (enacted 31 May 2017) that designated persons or entities based on UN lists (both
for Iran and DPRK, concerning PF) and freezing without delay the funds of persons and
entities listed. Implementation of the Joint Regulation was expanded to require FIs to identify
and freeze the assets of individuals or entities, including those affiliated with UN designated
persons and entities. Moreover, in order to mitigate PF risk, some of Indonesia’s FIs limit
international funds transactions related to Iran and DPRK, including wire transfers. A few FIs
will not open any business relationship with Iran and DPRK. Indonesia also established a
WMD Task Force in 2017 which consists of the following agencies: PPATK, State Intelligence
Agency, Indonesian National Police, Ministry of Foreign Affairs, and NERA (Nuclear
Supervision Authority). The main role of the WMD Task Force is to identify and monitor
activities and financial flow of individuals or entities, including those affiliated with UN
designated persons and entities, through integrating spontaneous exchange information.

Malaysia

Malaysia’s National Coordination Committee to Counter Money Laundering (NCC) has

recently approved and endorsed the work on a risk assessment on proliferation financing
(PFRA), undertaken at the beginning of 2019, in collaboration with export control authorities
in Malaysia. The PFRA intends to achieve the following objectives:

 Provide base-line assessment to enhance understanding of Malaysia’s risk exposure to PF;

 Identify and address key vulnerabilities in the financial and DNFBP sectors that may be
exploited to finance activities relating to proliferation of WMD or to evade UNSC
sanctions; and
 Support development of appropriate strategies and recommend measures in mitigating the
risks and vulnerabilities identified to strengthen Malaysia’s overall countering
proliferation financing (CPF) framework.

The assessment has grown in importance and in line with the recent adoption of the revised
FATF Recommendations 1 and 2. The completion of PFRA will serve as a key step to ensure
effective implementation of the recommendations from the following four different clusters:
APG Typologies Report 2021 11
 Legislative, policy and coordination framework;
 Regulatory and supervisory initiatives;
 Implementation and guidance; and
 Enforcement actions.

Upon endorsement by the NCC, the sanitised version of the report is expected to be published
to the public tentatively in the third or fourth quarter of 2021.

Philippines

On 4 March 2021, the Bangko Sentral Ng Pilipinas (BSP) completed its sectoral risk
assessment for banks and other BSP-supervised financial institutions (BSFIs) which highlights
the ML/TF/PF threats and vulnerabilities of banks and other BSFIs and the consequences of
criminal activities, as well as the overall ML/TF/PF risks associated with other priority areas
such as trade-based ML/TF/PF and the implementation of the TFS regime.

APG Typologies Report 2021 12

RUSI: THE PRIVATE SECTOR AND PF IMPLEMENTATION

In 2020, RUSI conducted a global survey on PF compliance, in partnership with the

Association of Certified Anti-Money Laundering Specialists (ACAMS). Key findings include:

 International banks (with operations in several regions of the world) appear most likely
to have a compliance function that incorporates PF (76%), in comparison to national
banks (63%) and non-banking institutions (46%). This finding tracks with RUSI’s own
experience delivering training and technical assistance around the world, as well as
several mutual evaluation reports, which confirm that banks are generally more aware of
their PF obligations, whereas DNFBPs have not considered PF as a discrete financial
crime risk.
 Respondents working in international banks are also more likely than other types of
institutions to consult red flags, typologies and other PF resources. Some resources, such
as the UN Panel of Expert reports on DPRK, are rarely consulted. The survey also found
that a higher number of respondents in international banks consult the UN Panel of
Experts reports (25%) compared to national banks (3%). Additionally, advisories issued
by the US government are mostly consulted by respondents in international banks (39%),
and less in other types of institutions (16-17%).
 There are also key regional differences in PF awareness, with Asia having the highest
proportion of respondents that say they stay up to date on the latest DPRK sanctions
evasion activities through news reporting.
 Over three-fifths agree it is challenging to incorporate lists of dual-use goods into
transaction monitoring programmes, and a majority of respondents also agreed that the
industry should prioritise strict end-user checks rather than identifying specific goods in
transactions.
 On DPRK-specific sanctions concerns, respondents were most concerned about
effectively implementing UN obligations on DPRK joint ventures, and detect and stop the
sale of fuel to DPRK.

Thailand

Thailand’s Financial Intelligence Unit (FIU), the Anti-Money Laundering Office (AMLO), is
currently updating its NRA to capture PF, and other crimes and entities not yet covered by
Anti-Money Laundering Act (AMLA). The scope of the PF risk assessment is on the potential
breach, non-implementation or evasion of the TFS obligations in R.7. The updated NRA is
expected to be finalised by the end of 2021.

Through this exercise, AMLO aims to understand Thailand's ML/TF/PF threats,

vulnerabilities, risks and consequences. The exercise is intended to serve as a guideline in
formulating policies, strategies and measures to mitigate ML/TF/ PF risks.

Thailand’s PF update to its NRA will include public and private partners, competent authorities
such as AMLO, security and intelligence agencies, regulators and self-regulatory bodies,
APG Typologies Report 2021 13
company registries, tax authorities, finance agencies, foreign affairs agencies, law enforcement
agencies (LEAs) including customs and border agencies, import and export control agencies,
and justice agencies. With respect to the private sector, reporting entities (FIs and DNFBPs),
non-profit sectors (NPOs) and other legal persons will be included. Lastly, the risk assessment
will consult with international partners such as relevant police liaison officers in Thailand.

Progress thus far includes collection and analysis of data, including agency risk assessment
data, and data from questionnaires and interviews/focus groups. AMLO will analyse data
collected to assess threats, vulnerabilities and consequences.

AMLO will disseminate the NRA to all relevant public and private partners to further
strengthen their policies, plans, measures, and procedures to ensure that ML/TF/PF risks will
be effectively mitigated, and Thailand’s financial system will be well protected from being
abused for ML/TF/PF.

Usefully, AMLO have been able to give an insight into the challenges that come with
conducting a PF risk assessment. The lack of PF understanding, especially within the private
sector, leads to a low of level of awareness with respect to PF risk and an inappropriate level
of mitigation. In response, Thailand has identified the need for outreach on PF obligations and
associated risks of sanctions evasion.

Co-mingling of legitimate business with illicit transactions in the international financial system
also poses difficulty in identifying and mitigating PF risk. Therefore, PF risk, including the
amount of PF, might be assessed based on perception rather than statistical data. This challenge
requires enhanced co-operation and coordination, and information sharing both at a national
and international level.

1.5 Guidance and training provided to FIs and DNFBPs

Case provided by Chinese Taipei

On 2 February 2021, the Financial Supervisory Commission forwarded to FIs, the

‘Implementation Handbook for UN Sanctions on North Korea’, published by Compliance and
Capacity Skills International in partnership with CRDF Global in March 2019.24

Case provided by Singapore

The Monetary Authority of Singapore (MAS) published the ‘Guidelines to MAS Notice 626
on prevention of money laundering and countering the financing of terrorism’ in April 2015.25
This guidance includes information regarding the potential indicators of PF, as well as the
requirements of banks and FIs in relation to PF and freezing funds, customer due diligence and
internal controls.

24
https://www.amlo.moj.gov.tw/media/15269/dprk-un-sanctions-implementation-handbook_english-
version.pdf?mediaDL=true
25
https://www.mas.gov.sg/-/media/MAS/Regulations-and-Financial-Stability/Regulations-Guidance-and-
Licensing/Commercial-Banks/Regulations-Guidance-and-Licensing/Guidelines/MAS-Notice-626-
Amendments-Nov-15/Guidelines-to-MAS-Notice-626--November-2015.pdf

APG Typologies Report 2021 14

MAS has also been working with FIs to assist them in the countering of PF risks. Following a
series of supervisory visits to banks, MAS published a paper in August 2018 entitled ‘Sound
Practices to Counter Proliferation Financing’ which provides a summary of the key findings
and discusses the sound practices observed during their thematic supervisory visits. This paper
can be used by banks and FIs to enhance their existing controls and practices in relation to PF.26

In addition, MAS has worked in conjunction with the Association of Banks in Singapore (ABS)
to make PF a standing agenda item at the ABS annual Financial Crime Seminar, which is one
of Singapore’s key AML/CFT industry outreach events and is attended by over 500 delegates
from Singapore and the region.

Case provided by Thailand

AMLO, in collaboration with foreign counterparts such as the United Nations Office on Drugs
and Crime (UNODC) and RUSI, organised training and workshops regarding understanding
PF risk and PF risk assessments, for competent authorities and other relevant partners such as
AMLO (FIU), security and intelligence agencies, regulators, finance agencies, foreign affairs
agencies, LEAs including customs, justice agencies, and finally reporting entities (FIs and
DNFBPs).

The scope of the training and workshops included:

 Identifying the risks posed by both state and non-state actors which seek to acquire or
facilitate the acquisition of WMD;
 Taking measures to mitigate PF risks which include detecting, investigating and disrupting
PF; and
 Raising awareness of ways to ensure the national implementation of UNSCR against PF
and related FATF standards.

26
https://www.mas.gov.sg/regulation/guidance/sound-practices-to-counter-proliferation-financing

APG Typologies Report 2021 15

2. UPDATE ON COVID-19 IMPACT ON ML/TF TYPOLOGIES

Chapter 1 of the 2020 APG Yearly Typologies Report focused on COVID-19’s impact on
ML/TF typologies given not only its relevance to the APG membership but also globally. The
chapter provided an overview of how the global pandemic prompted criminal groups to adjust
their ML/TF typologies in response to border closures, social distancing requirements, greater
reliance on digital communications/payment channels and the increased criminal opportunities
arising from the misappropriation of government financial support payments.

As the pandemic continues into 2021, APG members were asked to provide an update on ML
and TF typologies associated with predicate activities linked to COVID-19 (e.g. welfare fraud,
scams, counterfeit medicines, corruption, drugs, smuggling, etc).27

A number of case studies were provided by members that indicate how the pandemic continues
to change the ML/TF landscape, including an increase in online scams and fraud in relation to
the sale of personal protective equipment (PPE) and pharmaceutical products. Fraud has also
been identified through the use of fake charities to receive pandemic-related donations as well
as individuals pretending to be affiliated with governments in order to solicit donations.
Members continue to report fraud claims for COVID-19 related government subsidies.

Given the pandemic-related border closures there has also been a reported increase in the
detection of smuggling related to illicit drugs, alcohol and tobacco. An increase in the number
of suspicious transaction reports related to online gambling is believed to be a result of COVID-
19 quarantine measures.

27
See section 9

APG Typologies Report 2021 16

3. APG WORKSHOPS AND PROJECTS 2020 - 2021

This section of the report provides a brief overview of typologies-related work undertaken by
the APG between July 2020 and June 2021.

3.1 Typologies Projects

Digital Know Your Customer (KYC) Workshop

At the APG’s 22nd Annual Meeting in 2019, members approved a two-phase project on the
implementation of digital KYC in the Asia/Pacific region. The objective of the approved
project is to support the implementation of digital KYC and ID including outreach and capacity
building on applying the FATF Guidance on Digital Identity (ID) published in March 2020.

 Phase one of the project was to be a regional workshop on digital KYC to be held
collaboratively by the Alliance for Financial Stability with Information Technology (AFS-
IT), a non-profit organization based in Hong Kong, China and the APG Secretariat. The
initial plan for phase one was to conduct the workshop in Seoul in late March 2020,
however, due to the impacts of COVID-19 the workshop was postponed and was held
virtually on 2-5 February 2021, within the 22nd APG typologies workshop.
 Phase two of the project is currently underway and will include the development of a
scoping paper of proposed further activities informed by the outcomes of the workshop to
be developed in partnership between AFS-IT and APG. Any future work on this issue
would depend on resources available in the secretariat and member needs.

Financing and Facilitation of Foreign Fighters in Southeast Asia

The APG secretariat worked with the Global Center on Cooperative Security over the course
of 2020-2021 to finalise the typology report on Financing and Facilitation of Foreign Terrorist
Fighters and Returnees in Southeast Asia. This report is expected to be adopted in July 2021 at
the APG Annual Meeting, which will finalise the secretariat’s work on this project.

The draft report was shared with APG members for their feedback and review in advance of
the 22nd APG typologies workshop, where Financial Profiles of Foreign Terrorist Fighters (in
collaboration with Global Center on Cooperative Security) formed a workshop stream.

The APG hosted a Private Sector Roundtable to gather insights and feedback from the private
sector on Financial Profiles of Foreign Terrorist Fighters.

FATF Project on TF Risks Related to Illicit Arms Trafficking

The APG participated in the FATF project on Illicit Arms Trafficking and Terrorist Financing.

Human trafficking and people smuggling project (Phase two)

Due to COVID-19 travel-related restrictions, the final workshop of the Human Trafficking and
People Smuggling Project (Phase two), due to be completed in June 2020, did not proceed and
the programme will be considered finalised.

APG Typologies Report 2021 17

3.2 22nd Typologies and Capacity Building Workshop

Each year the APG typologies workshop brings together AML/CFT practitioners from
government agencies, including investigation and prosecution agencies, FIUs, regulators, and
the private sector to consider priority ML and TF risks and vulnerabilities.

The 22nd APG typologies workshop was held in a virtual format on 2-5 February 2021 due to
restrictions on travel during the COVID-19 pandemic. The four day workshop involved
approximately 325 delegates from 36 APG members, 10 APG observers, and 29 private sector
or non-government organisations.

The workshop included a plenary session (first and last day) and two streams, running in
parallel, on: (i) Digital KYC (in collaboration with AFS-IT and (ii) Financial Profiles of
Foreign Terrorist Fighters (in collaboration with Global Center on Cooperative Security).
Expert presentations, panel discussions and other contributions were made in both streams by APG
members, observers and other from the global network.

APG Typologies Report 2021 18

4. FATF, FSRBS AND OBSERVERS’ PROJECTS

This section of the report provides a brief overview of typology reports published by FATF
and other FATF-style regional bodies (FSRBs) between July 2020 and June 2021.

4.1 FATF Typology Projects

Virtual Assets Red Flag Indicators of ML and TF (September 2020)

This FATF report complements the FATF ‘Guidance for a Risk-Based Approach to Virtual
Assets and Virtual Asset Service Providers (2019)’28. It contains ML/TF red flag indicators
associated with VAs to assist reporting entities, including FIs DNFBPs, and VASPs. The red
flag indicators included are based on more than one hundred case studies contributed by
jurisdictions from 2017-2020.

Key indicators in this report focus on:

 Technological features that increase anonymity - such as the use of peer-to-peer exchanges
websites, mixing or tumbling services or anonymity-enhanced cryptocurrencies;
 Geographical risks - criminals can exploit jurisdictions with weak, or absent, national
measures for VAs;
 Transaction patterns - that are irregular, unusual or uncommon which can suggest criminal
activity;
 Transaction size – if the amount and frequency has no logical business explanation;
 Sender or recipient profiles - unusual behaviour can suggest criminal activity; and
 Source of funds or wealth - which can relate to criminal activity.

The report is available on the FATF website at:

https://www.fatf-gafi.org/media/fatf/documents/recommendations/Virtual-Assets-Red-Flag-
Indicators.pdf

Trade-Based Money Laundering: Trends and Developments (December 2020)

The publication of this report29 marked the completion of a joint project between FATF and
the Egmont Group on trade based ML. Using numerous case studies from around the FATF
global network, the report examines criminal methods of exploiting trade transactions to move
money, rather than goods.

The report contains recommendations to address the trade-based ML risks targeted at both the
public and private sectors, including the use of NRAs and other risk-focused material to raise
awareness entities involved in international trade. The report also recommends improving
information sharing of financial and trade data, and cooperation between public and private
sectors, including public-private partnerships.

28
https://www.fatf-gafi.org/media/fatf/documents/recommendations/RBA-VA-VASPs.pdf
29
https://www.fatf-gafi.org/media/fatf/content/Trade-Based-Money-Laundering-Trends-and-Developments.pdf

APG Typologies Report 2021 19

The report is available on the FATF website at:
https://www.fatf-gafi.org/media/fatf/content/Trade-Based-Money-Laundering-Trends-and-
Developments.pdf

Trade-Based Money Laundering: Risk Indicators (March 2021)

The FATF and Egmont Group published these risk indicators in March 2021 to help public and
private entities identify suspicious activity associate with trade based ML.

The report includes risk indicators on:

 The structure of the business;

 Trade activity;
 Trade documents and commodities; and
 Account and transaction activity.

The report is available on the FATF website at:

https://www.fatf-gafi.org/media/fatf/content/images/Trade-Based-Money-Laundering-Risk-
Indicators.pdf

Update: COVID-19-Related Money Laundering and Terrorist Financing Risks (December

2020)

This paper updates work published by the FATF in May 2020, highlighting COVID-19-related
ML and TF risks and policy responses. Using input from the FATF global network, and from
private and public sector webinars in July and September 2020, the paper details how criminals
continue to exploit the crisis. A selection of case studies illustrates how the risks have evolved
as the pandemic has progressed, and how authorities have dealt with them. These include the
counterfeiting of medical goods, cybercrime, investment fraud, charity fraud and abuse of
economic stimulus measures.

The paper confirms the FATF concerns expressed in May 2020, including:

 Changing financial behaviours - especially significant increases in online purchases due to

widespread lockdowns and temporary closures of most physical bank branches, with
services transitioning online; and
 Increased financial volatility and economic contraction - largely caused by the losses of
millions of jobs, closures of thousands of companies and a looming global economic crisis.

The paper recommends authorities and the private sector take a risk-based approach (RBA)
responding to these evolving risks, as required by the FATF Standards, by mitigating the ML
and TF risks without disrupting essential and legitimate financial services and without driving
financial activities towards unregulated service providers.

The report is available on the FATF website at:

https://www.fatf-gafi.org/media/fatf/documents/Update-COVID-19-Related-Money-
Laundering-and-Terrorist-Financing-Risks.pdf

Guidance on TF Investigations and Prosecutions (2021)

APG Typologies Report 2021 20

This confidential guidance provides best practices to national authorities to improve the
effectiveness of their legal actions against TF. It covers detection, investigative strategies for
common types of TF activity, proving intent and knowledge, and confiscation of assets as a
tool to disrupt TF. The final version of this confidential report has been disseminated to
operational authorities. Authorities should get in contact with their FATF national contacts
should they want a copy of the report.

TF Risks Related to Illicit Arms Trafficking (2021)

This confidential report on the links between illicit arms trafficking and TF aims to raise
awareness across the FATF global network, particularly in the context of NRAs, and help
jurisdictions develop effective operational responses.

The final version of this confidential report has been disseminated to operational authorities.
Authorities should get in contact with their FATF national contacts should they want a copy of
the report.

ISIL and Al-Qaeda and affiliates financing updates (October 2020) – Non-public

This non-public update to the FATF comprehensive report on the Financing of the Islamic State
in Iraq and the Levant (ISIL)30 published in February 2015, is based on information provided
by the FATF global network and covers Al-Qaeda, and ISIL and Al-Qaeda affiliates.
Authorities should get in contact with their FATF national contacts should they want a copy of
the latest ISIL update.

Joint Experts’ Meeting (November 2020)

In November 2020, the FATF held the annual Joint Experts’ Meeting (JEM) in a virtual format
for the first time. Approximately 400 participants representing 95 jurisdictions from across the
FATF global network, FSRBs and international organisations attended the meeting.

The meeting started with a high-level session to discuss evolving ML/TF risks faced by
members across the FATF global network and had a concluding session to discuss the need for
stronger co-operation when pursuing ML cases in a multilateral context. Four other sessions
were held to advance ongoing and upcoming priority projects under the FATF German
Presidency. These sessions covered: (1) ML and environmental crime; (2) the financing of
ethnically or racially motivated terrorism; (3) illicit arms trafficking and TF; and (4) digital
transformation of AML/CFT for operational agencies. The discussions at the JEM also covered
high level issues including, emerging money laundering and terrorist financing risks, and co-
operation in multi-jurisdictional money laundering cases. The meeting provided invaluable
inputs into FATF’s ongoing work.

Additional details on the outcomes are available on the FATF website at:
https://www.fatf-gafi.org/publications/methodsandtrends/documents/jem-2020.html

Money Laundering from Environmental Crime (July 2021)

30
https://www.fatf-gafi.org/media/fatf/documents/reports/Financing-of-the-terrorist-organisation-ISIL.pdf

APG Typologies Report 2021 21

This report aims to strengthen awareness of the scale and nature of criminal gains and
laundering techniques for environmental crimes. The report brings together expertise from
across the FATF’s Global Network to identify good practices that governments and the private
sector can take to disrupt the profitability of environmental crimes. The findings for this report
are based on case studies and good practices provided by over 40 jurisdictions, alongside
expertise from civil society and the private sector.

Key findings of the report include:

 Estimates of the scale of financial flows from environmental crimes vary considerably, but
evidence suggests that proceeds account for hundreds of billions of dollars annually
impacting all regions. With the exception of waste trafficking, environmental crimes
generally occur in resource-rich developing and middle-income jurisdictions, with
proceeds coming from larger, developed economies.
 Criminals often rely on cash intensive sectors (frequently linked to the export sector) and
trade-based fraud to launder proceeds from environmental crimes.
 The significant role of trade-based fraud and misuse of shell and front companies to launder
gains from illegal logging, illegal mining, and waste trafficking.
 Criminals frequently comingle legal and illegal goods early in the resource supply chains
to conceal their illicit source.
 Actors, enabled by corruption, rely on corporate structures, third party transfers and
offshore jurisdictions to obfuscate the beneficial owners.
 Jurisdictions face a range of challenges in identifying and disrupting environmental crimes.
These include gaps in effective understanding and awareness of financial flows connected
to environmental crimes; internal and inter-agency co-ordination gaps; low levels of
international co-operation on the financial flows; insufficient awareness of risk-indicators
to develop red-flags; and inadequate private sector capacity to implement successful
preventive measures.
 Jurisdictions highlighted a number of good practices including coordinated risk
assessments involving environmental and AML agencies, clear and coherent legal
frameworks (including criminalisation of ML for environmental crimes that occurred
abroad), guides for domestic co-operation, joint taskforces and information exchange to
follow and repatriate the money for environmental crimes from overseas, and consultation
with the private sector to develop red-flags.

The report identifies the following key priorities for Members of the FATF Global Network:

 All Members of the FATF Global Network should consider whether criminals may be
misusing their financial and non-financial sector to conceal and launder gains from
environmental crimes. This includes jurisdictions without domestic natural resources.
 Members must also strengthen their operational capacity to detect and pursue financial
investigations into environmental crimes. This includes working with foreign counterparts
to share information, facilitate prosecutions and the effective recovery of assets that are
moved and held abroad.
 Jurisdictions should fully implement the FATF standards as an effective tool to combat
money laundering from environmental crime. This includes ensuring AML outreach to
relevant intermediaries covered by the FATF Standards, such as dealers in precious metals
and stones and trust and company service providers.
 Jurisdictions should consider establishing and strengthening public-private sector dialogue
to share risk information, and organisation of industry-led initiatives to strengthen due
APG Typologies Report 2021 22
 diligence of supply chains and their financial flows. These initiatives can play a significant
role in raising awareness about suspicious financial activity and addressing comingling by
finding means to demonstrate the legitimate source of goods.

The report is available on the FATF website at:

https://www.fatf-gafi.org/publications/environmentalcrime/documents/money-laundering-
from-environmental-crime.html?hf=10&b=0&s=desc(fatf_releasedate)

Ethnically or Racially Motivated Terrorism Financing (June 2021)

The report brings together expertise from jurisdictions and institutions which have had
experience in tackling ethnically or racially motivated terrorism (EoRMT) with an aim to
increase the understanding of TF risks related to extreme right wing (ERW) actors more
broadly among competent authorities, non-governmental bodies, the private sector, and the
broader public. The findings in the report are based on inputs from around 30 jurisdictions
across the FATF Global Network, as well as expertise from the private sector and international
bodies partnered with the FATF. The report provides an outline of key ways in which ERW
actors raise, move and use funds, as well as practical examples of this.

Key findings of the report include:

 While extreme right wing terrorist attacks are mainly perpetrated by self-funded lone
actors, extreme right wing (ERW) groups employ an array of fundraising techniques. These
include donations (through both crowdfunding and private contributions), membership
fees, commercial activities (including organisation of concerts, sales of merchandise and
real estate ventures), and criminal activities. Notably, most of the funding for ERW groups
appears to come from licit sources.
 ERW groups appear to be less concerned with concealing their transactions than in other
forms of TF. Many jurisdictions also reported that ERW actors are becoming increasingly
operationally sophisticated in how they move their funds.
 Funds appear to be used for varying activities, ranging from financing of attacks, to
purchasing equipment, training, creating and dispersing propaganda, recruitment,
networking, legal fees, and even purchasing and maintaining real estate assets.
 The report highlights several challenges in tackling the financing of ERW-motivated
groups and attacks including different legal regimes in place for combatting ERW terrorism
in different jurisdictions; few national designations of groups; growing transnational links
between groups (and, in some instances, individuals who have perpetrated terrorist attacks);
the fact that most ERW attacks are carried out by self-funded lone actors; and, the limited
public-private partnerships in place for exchanging financial information.

Recommendations contained within the report include:

 Jurisdictions are encouraged to continue to develop their understanding of EoRMTF,

especially through including this threat in their NRAs, working with relevant public and
private partners on threat detection, and exchanging best practices with relevant
international partners to tackle the increasingly transnational characteristics of EoRMTF.
 Jurisdictions should maintain their focus on the evolving threat posed by EoRMTF,
particularly in the context of the COVID-19 crisis which has provided a recruitment
opportunity for violent extremist groups.

APG Typologies Report 2021 23

The report is available on the FATF website at:
https://www.fatf-gafi.org/publications/methodsandtrends/documents/ethnically-racially-
motivated-terrorism-financing.html

4.2 Middle East and North Africa Financial Action Task Force

A Study on: Coronavirus Pandemic (COVID-19) and its impact on AML/CFT systems in the
Middle East and North Africa Region (August 2020)

This report documents responses to a questionnaire disseminated by MENAFATF to its

members requesting information and case studies on the effects of the pandemic on AML/CFT
systems in the region and the most important methods and trends used in committing related
crimes.

The report explores the measures taken by jurisdictions in the region with regard to their
AML/CFT systems in response to developments as a result of the pandemic. Several
jurisdictions indicated that there had been a significant decrease in the number of suspicious
transaction reports (STR) as a result of economic decline and quarantine conditions. The report
explores the most prominent challenges facing AML/CFT systems in the region including
technological difficulties with regard to remote working, reduced cooperation between
domestic authorities as well as reduced international cooperation, the redirection of resources
towards combating the pandemic and effects on onsite inspections by supervisory bodies.

The report also documents best practices taken by jurisdictions in the region to mitigate the
effects of the pandemic including using technology to conduct virtual onsite inspections and to
fulfil KYC requirements.

The report also outlines key typologies identified in the region during the pandemic including
cybercrime, corruption, cross-border smuggling of cash and fraud including with regard to
donations and counterfeiting of medical goods.

The report recommended that competent authorities take several key actions, including:

 Not only attempt to restore the level of compliance to what it was before the COVID-19
pandemic, but also strengthen AML/CFT systems continuously and sustainably even in
times of crisis;
 Develop a unified risks map associated with ML and TF related to the pandemic and work
to find measures to mitigate it and similar crises.
 Review the adequacy of AML/CFT regulations and their ability to meet critical and crisis
conditions.
 Activate international cooperation channels and respond accurately to requests for
information in a timely manner.

The report is available on the MENAFATF website at:

http://www.menafatf.org/information-center/menafatf-publications/coronavirus-pandemic-
covid-19-and-its-impact-amlcft-systems

APG Typologies Report 2021 24

4.3 Eurasian Group on combating money laundering and financing of terrorism
Typologies of the use of preventive measures of financial institutions for crime detection and
risk assessment (2021)

The report summarises the approaches and best practices of jurisdictions related to the use of
STRs and includes information on preventive measures applied by FIs for identifying offences
and assessing risks. The report includes case studies from Eurasian Group (EAG) members on
best practices related to the use of STRs and preventive measures. The report also outlines the
specificities of supervision and implementation by reporting entities of preventive measures
amid the COVID-19 pandemic.

Key findings of the report include:

 The main preventive measures, that have proved their effectiveness in mitigating ML/TF
risks in practice, are refusal to carry out transactions for customers and refusal to enter into
bank accounts (deposit) agreements with customers, also known as denial of services;
 In some EAG members, the STR form includes information on beneficial owners of
customers and IP and MAC addresses of devices used by customers for accessing online
banking services. Such information enables the FIUs to identify additional links and make
thematic collections of the incoming STRs;
 There have been changes in financial behaviour during the COVID-19 pandemic due to
the rapid growth of online services and development of e-commerce;
 There has been an increase in cybercrime, online fraud and the misuse of public funds
during the pandemic;
 There has also been an increase in fraud related to personal protective equipment,
medicines and in the area of charities;
 There has been an increase in cross-border online gambling;
 Some jurisdictions experienced increases in the number of STRs during the pandemic
attributed to a surge in digital transactions and an increase in cybercrime, while others
experienced decreases in the number of STRs attributed to a decline in economic activity;
and
 In a number of the EAG member states in the first half of 2020, scheduled inspections in
a number of sectors of FIs were cancelled and on-site inspections were replaced with
remote ones.

Recommendations contained within the report for EAG members include:

 Analyse the practices of financial institutions in applying the right to refuse to conduct
transactions and the right to refuse to enter into an account (deposit) agreement as risk
mitigation measures and, if necessary, take measures to optimise them;
 Consider including in the format of the electronic message about a suspicious transaction
information about the customer's beneficial owner, as well as the IP and Mac addresses of
the devices used by customers in remote banking, as well as a special marking to highlight
important STRs that require an urgent response;

APG Typologies Report 2021 25

 Competent authorities of the EAG members are invited to review, in collaboration with
the private sector, current pandemic trends and risks and, if necessary, to update relevant
recommendations and guidance documents on identifying high-risk transactions; and
 Competent authorities of the EAG members are invited to consider expanding the formats
of using IT tools for remote interaction with reporting entities for implementation of non-
contact supervision and for prompt collection of information about risks and vulnerabilities
among a wide range of respondents.

The report is available on the EAG website at:

https://eurasiangroup.org/files/uploads/files/Preventive_measures_final_report_eng.pdf

4.4 Committee of Experts on the Evaluation of Anti-Money Laundering

Measures and the Financing of Terrorism

Money laundering and terrorism financing trends in MONEYVAL jurisdictions during the
COVID-19 crisis (September 2020)

This report used responses to a questionnaire sent out to all MONEYVAL jurisdictions to
ascertain emerging ML cases, practical challenges, typologies and trends surfacing during the
pandemic.

Key findings of the report include:

 The overall level of criminality remained stable or slightly decreased and suspicious
transactions reporting remained steady;
 Jurisdictions reported a surge in certain crimes, especially transnational crimes, such as
fraud (through electronic means) and cybercrime, creating new sources of proceeds for
ML purposes;
 No reported increase in crimes related to drug trafficking, TF, abuse of NPOs and insider
trading. Several jurisdictions reported growth in medicrime, cybercrime and corruption;
 Opportunities for abuse of government emergency economic relief measures (such as
financial aid and tax incentives) to support businesses and the population were identified.
 Vulnerability for fraud and corruption has been created by the temporary suspension of
complex controls in public procurement procedures for medical equipment and supplies in
some jurisdictions.
 Cooperation between FIUs has not been affected and has proven to be particularly relevant
on exchanging information on cross-border cases related to fraudulent offerings of medical
and sanitary equipment, counterfeited products, non-delivery scams and illegal over-
pricing.

Three main types of fraud related to COVID-19 were identified: medical equipment fraud,
economic relief measures fraud, and fraud/embezzlement related to public procurement
contracts.

Recommendations contained within the report include:

 Law enforcement should place sufficient focus on investigating frauds and cybercrimes
committed during the pandemic crisis.

APG Typologies Report 2021 26

 Border police and customs authorities should pay special attention to the cross-border
movement of cash which might be related to “late demand” to move illicit funds. Cross
border cash movements are used by criminals to finance their operations and it is said that
now criminal organisations face a “late demand” for cross border transportation of cash
given the temporary closing of national borders due to the pandemic.
 Authorities should closely monitor the situation of public procurement, to detect possible
cases of abuse and corruption, especially where controls have been relaxed.

The report is available on the MONEYVAL website at:

https://rm.coe.int/moneyval-2020-18rev-covid19/16809f66c3

4.5 Egmont Group

Public Bulletin on Money Laundering of Serious Tax Crimes (July 2020)

This bulletin aims to present key lessons, best practices, and representative case examples to
help enhance the fight against ML of serious tax crimes both at the national and international
levels. The bulletin relies on a questionnaire and survey on case examples distributed to the
Egmont Group’s FIUs.

Key lessons from the bulletin include that effective national capabilities of authorities to
receive, access, analyse and share relevant tax-related information, including on related ML,
are key to the ability of jurisdictions to effectively tackle serious tax-related crimes. In addition,
national legal frameworks that grant high levels of tax secrecy complicate reciprocity in the
exchange of information. Furthermore, low level/no taxation policies do not only increase the
attractiveness of the concerned jurisdiction for investors, but also for criminals, which can
create vulnerability in other jurisdictions as a lack of beneficial ownership transparency hinders
transnational investigations.

The bulletin recommends best practices in the fight against ML of serious tax crimes including
to facilitate effective cooperation between FIUs and tax authorities at the national level and
international cooperation between FIUs. The bulletin provides a series of case examples to
illustrate best practices including effective cooperation between FIUs.

The bulletin is available on the Egmont Group website at:

https://egmontgroup.org/en/filedepot_download/1661/117

COVID-19 Best Practices for Financial Intelligence Units (March 2021)

This report is informed by a series of virtual roundtables conducted by the Egmont Centre of
FIU Excellence and Leadership (ECOFEL) in order to strengthen the capabilities of FIUs
during the COVID-19 crisis, together with a stocktaking exercise of open source material
published by Egmont Group members, observers and other international organisations. The
report documents a variety of typologies that have emerged as a result of the COVID-19
pandemic.

The report finds that suspicious activity report numbers have not decreased significantly during
the pandemic, with FIUs only noting a reduction where there has been economic decline or
reporting entities have limited capacity.
APG Typologies Report 2021 27
Importantly, the report also notes that most FIUs have identified some new emerging risks as
a result of the pandemic, particularly relating to fraud (concerning medical equipment and
PPE), corruption linked to the relaxation of public procurement rules and cybercrime including
phishing. FIUs have noted increases in fraud, phishing, other online scams and increases in the
misuse of public funds. Other emerging risks include child pornography and child exploitation,
counterfeit currency and the emergence of wildlife crime. FIUs are also aware of new emerging
risks, such as those relating to the development of COVID-19 vaccines.

The report provides examples of action taken by FIUs against COVID-19 related crime and
lists recommendations for FIUs to respond to the changing COVID-19 risk landscape.

The report is available on the Egmont Group website at:

https://egmontgroup.org/en/filedepot_download/1661/123

ECOFEL - Financial Investigations into Wildlife Crime (January 2021)

This report aims to provide FIUs with an enhanced understanding of wildlife crime and
presents the trends and patterns associated with wildlife crime financial flows. The report also
explores the links between wildlife crime and other forms of criminal activity such as drug
offences, corruption, TF and the illegal weapons trade. It notes that historically, there have
been very few financial investigations into wildlife crime globally and the resulting lack of
financial scrutiny and low penalties make wildlife crime a highly profitable, low-risk enterprise
for perpetrators.

The report emphasises the benefits of investigations into the financial flows of the illegal
wildlife trade and explains how FIUs can get involved in supporting financial investigations
into wildlife crime. The report lists recommended practices to increase the effectiveness of FIU
efforts including properly assessing the risks of wildlife crime in the jurisdiction’s NRA,
filtering and analysing STRs based on strategic assessments of wildlife crime within the
jurisdiction and enhancing inter-agency cooperation and information exchange. International
organisations and non-government organisations (NGOs) active in the fight against wildlife
crime are also suggested as good partners for FIUs.

The report is available on the Egmont Group website at:

https://egmontgroup.org/en/filedpot_download/1661/122

Public Bulletin on Combatting Online Child Sexual Abuse and Exploitation through Financial
Intelligence (July 2020)

This bulletin focuses on the strategic intelligence picture associated with payments identified
as relating to online streaming of child sexual abuse and exploitation (CSAE). The bulletin
notes that the criminal business models specifically established for online streaming bring a
financial dimension to the activity that is not always prevalent in the other forms of CSAE. The
bulletin then explains the financial dimension of online streaming of CSAE including the
payment patterns for online-streamed material and the associated business models. It also
emphasises how the analysis of reports submitted by private sector entities, including
suspicious activity reports and STRs, enables FIUs to provide LEAs with actionable
intelligence relating to the movement of funds and the identification of both offenders and
facilitators.

APG Typologies Report 2021 28

The bulletin is available on the Egmont Group website at:
https://egmontgroup.org/en/filedepot_download/1661/119

4.6 Inter-Governmental Action Group against Money Laundering in West

Africa

Illegal Wildlife Trade and Financial Investigations in West Africa (April 2021)

This paper was published by RUSI with the support of the Inter-Governmental Action Group
against Money Laundering in West Africa (GIABA). The paper relies on 89 interviews with
key stakeholders in West and Central Africa, as well as a survey of 12 out of 17 GIABA
member FIUs to assess the extent to which the financial dimensions of the Illegal Wildlife
Trade (IWT) are investigated in the region.

The paper analyses IWT trends in West Africa, with a focus on high-grossing trafficking in
elephant ivory, pangolin scales and rosewood. It also identifies key challenges that currently
prevent the use of financial investigations in IWT cases.

The paper’s key findings include:

 86% of respondents considered IWT a ‘serious issue’, but only 58% made reference to
environmental crime or IWT in their national ML/TF risk assessments;
 Only one FIU considered itself to be regularly involved in the investigation of IWT cases;
 Only 25% (three) of the FIUs reported ever having conducted IWT financial
investigations, no jurisdiction had completed more than one and none led to a prosecution
for ML or another financial crime;
 FIUs have very minimal knowledge about the methods used to generate, transfer and
launder the proceeds of IWT in West Africa;
 Most GIABA member states criminalise environmental crime as a predicate offence to
ML, but most FIUs identified a ‘lack of awareness of IWT as a predicate offence’ as the
most important reason why financial investigations do not currently occur in wildlife
cases;
 Most FIUs identified the need for greater training, knowledge and financial resources to
pursue IWT cases as a capacity-building priority; and
 The paper affirms that global enforcement action remains disproportionately focused on
low-level, easily replaced poachers, leaving the controllers and ultimate beneficiaries of
IWT virtually untouched.

Key recommendations of the paper include:

 The establishment of a financial crime working group in the West Africa network to
combat wildlife crime that will be responsible for coordinating the implementation of the
West Africa Strategy on Combating Wildlife Crime at the regional level.
 The inclusion of FIUs and anti-corruption agencies in all national level domestic taskforces
created to address wildlife crime.
 Policymakers charged with developing national counter-wildlife crime strategies and
action plans should include the requirement to initiate parallel financial investigations in
all suitable IWT cases.

APG Typologies Report 2021 29

 Proposals for improving domestic and international cooperation and information sharing.

The report is available on the GIABA website at:

https://www.giaba.org/media/f/1131_IWT_west_africa_Report_2021.pdf

5. CURRENT MONEY LAUNDERING AND TERRORISM

FINANCING METHODS AND TRENDS

5.1 Use of offshore banks, international business companies, and offshore

trusts, including trust company service providers.

Fiji

Offshore Profit Shifting and Tax Evasion

Person B, a dual citizen of Fiji and jurisdiction X was reported for claiming a false VAT refund
from the local taxation authority on the pretext of a legitimate business expense. Checks by the
Fiji FIU revealed that Person B started a sole proprietor business in Fiji with a trading activity
of real estate and is a director of two other companies in Fiji, which were both related to the
construction industry. However, it was established that there was no corresponding trading
activity in relation to the VAT claim since one of his companies had no significant trading
activities while the other company was incurring losses for the same period. The Fiji FIU
established that more than $110,000 (USD 53,981) was claimed and refunded as VAT from
the taxation authority by Person B. Person B also sent large remittances to Fiji from jurisdiction
X to himself, his companies and Person C who was his associate amounting to more than
$750,000 (USD 368,893) within five years. The remitted funds were used to acquire three
properties in Fiji with a total value of more than $1.8m (USD 885,359) which were partly
financed by a loan. A case dissemination report was provided to the taxation authority in Fiji
and the relevant FIU in jurisdiction X.

New Zealand

Abuse of New Zealand Trust or Company Service Provider and related structures for ML of
offshore corruption proceeds

At the instruction of an offshore-based individual, a New Zealand (NZ) Trust or Company

Service Provider (TCSP) established two foreign trust structures using NZ limited liability
companies as the trustees and as the partners (limited and general) of multiple NZ limited
partnerships which were also incorporated into the structures and used to open NZ bank
accounts. The TCSP was the director for all of the entities and had authority to operate the bank
accounts. The offshore-based individual and his wife were beneficial owners of the above
structures, however, they had no identifiable links to any of the above structures in NZ publicly
available databases.

The offshore-based individual was subsequently indicted for conspiracy to commit wire fraud
as part of a violation of anti-kickback laws in jurisdiction A, using a company based in
jurisdiction B. Authorities alleged the offshore-based individual was part of a wider conspiracy
relating to a sham marketing agreement used to disguise kickback and bribe payments relating
to provision of medical supplies. It was suspected the proceeds of this scheme were laundered
via an international web of trust and company structures – including the NZ foreign trust
APG Typologies Report 2021 30
structures in whose name overseas assets were purchased and whose NZ bank accounts were
known to have facilitated the movement of more than USD 1.5 million.

Proceeds from offshore political corruption and bribery laundered through NZ

A political official and head of a state-owned energy company in overseas jurisdiction A was
indicted in jurisdiction B on charges of bribery, corruption and conspiracy to commit money
laundering, in relation to bribes he received from company officials in the jurisdiction B to
corruptly secure energy contracts and payment priority on outstanding invoices. The official
had been living in jurisdiction C for the past seven years along with his wife.

The official admitted to authorities that between 2011 and 2014, he conspired with officials in
jurisdictions A and B to solicit and direct bribes to a range of associates, and to launder the
bribes through a series of financial transactions, including to bank accounts in jurisdictions D
and E owned or controlled by the official or associates.

A NZD 17.4 million (USD12,564,408) transfer was made into a NZ account from a bank
account held in jurisdiction E registered in the name of the wife of the indicted official. The
funds were received into the NZ account of an NZ accountancy firm specialising in the creation
and administration of offshore structures on behalf of international ‘high net worth’ clients.
The accountancy firm’s employees featured prominently in Panama Papers reporting where
they were listed as officers and/or nominees of numerous NZ and overseas companies which
formed part of the Mossack Fonseca network of entities.

The fund transfers were conducted under order of the wife of the indicted official. As part of
ECDD, the bank requested further information from the accountancy firm, which stated that
due in part to political issues, the bank moved to close all accounts for jurisdiction A nationals
operating in jurisdiction E and the portfolio was liquidated to enable funds to be transferred to
NZ for investment purposes. The accountancy firm stated it was expecting the wife to visit NZ
in the near future and it had set up the ‘required structures’ on her behalf in the meantime.

Singapore

The Commercial Affairs Department of the Singapore Police Force (CAD) investigated
allegations against a licenced professional intermediary for concealing beneficial ownership
using trust structures.

A Singapore-incorporated trust company (“Trust Company X”), allegedly conspired with asset
managers based in jurisdiction S to set up complex trust structures in Singapore with the aim
of concealing the beneficial ownership of financial assets belonging to a Jurisdiction A
national, Person Z. This investigation arose from a MLA request from Jurisdiction A which
commenced civil forfeiture proceedings against Person Z. Person Z faced a tax evasion charge
under Jurisdiction A laws for failing to declare assets in undisclosed and untaxed offshore bank
accounts held outside of Jurisdiction A.

Trust Company X facilitated the set up and administration of two trust structures, and was
registered as the trustee of the assets under them. The beneficial owner of the trust structures
was Person Z. The trust structures comprised companies (Companies A and B) incorporated in

APG Typologies Report 2021 31

jurisdiction B, and these companies in turn maintained corporate bank accounts in Singapore.
From 2012 to 2017, Person Z routed his undeclared financial assets from a foundation in
jurisdiction P to the corporate bank accounts in Singapore of the said companies incorporated
in jurisdiction B.

Working closely with Jurisdiction A authorities during investigations, Singapore seized the
funds in bank accounts amounting to approximately SGD 3.5 million (USD 2.6 million).
Pursuant to a settlement agreement between Jurisdiction A authorities and the accused person
Z, the proceeds of the Jurisdiction A tax evasion offences were recovered and eventually
restituted to Jurisdiction A’s government. Investigations are currently ongoing for money
laundering offences against Trust Company X.

5.2 Use of virtual assets (cryptocurrencies)31.

Australia

In June 2020, the Australian Federal Police (AFP) commenced an investigation into an
unknown person using the details of victims of identity theft to register for multiple accounts
with Digital Currency Exchanges (DCEs) and subsequently using these accounts to launder
proceeds of crime. Working in conjunction with the DCEs the AFP identified in excess of AUD
$40,000 (USD 31,100) being deposited into cryptocurrency ATMs and transferred via nine

31
A virtual asset, as defined by FATF, is a digital representation of value that can be digitally traded, or
transferred, and can be used for payment or investment purposes. Virtual assets do not include digital
representations of fiat currencies, securities and other financial assets that are already covered elsewhere in the
FATF Recommendations (https://www.fatf-gafi.org/glossary/u-z/)
APG Typologies Report 2021 32
separate accounts registered with the DCE. Further investigations identified the unknown
person responsible who was subsequently arrested and charged with the following offences:

 Receiving a designated service using a false customer name, contrary to the Anti Money
Laundering and Counter Terrorism Financing Act 2006 (Cth) s140(1); and
 Possession of identification information, contrary to Criminal Code (Cth) s372.2(1).

New Zealand
Bitcoin trader facilitates fraud
A peer-to-peer bitcoin trader operating on localbitcoins.com facilitated the conversion of
fraudulently obtained fiat currency into bitcoin on behalf of international fraudsters operating
offshore. The overseas fraudsters would contact NZ-based victims and engage in deceptive
practices (primarily romance and ‘advance fee’ scams) to convince the victims to provide them
with money. The scammers instructed their victims to meet with their local ‘associate’ (the
bitcoin trader) to conduct a cash handover, providing the victims with a time and place to meet
the associate. Meanwhile, the scammers also contacted the bitcoin trader advising they wished
to purchase bitcoin with NZD, instructing the trader to meet with their ‘associate’ (who was
actually the scam victim) at a specific time and place to conduct the handover. The scammers
provided the trader with their bitcoin wallet address to which he was to credit bitcoin to the
value of the cash handed to him by the victim. The bitcoin trader did not undertake any forms
of CDD when facilitating these trades, accepting the cash from the victim, and crediting the
value in bitcoin to the fraudster on a ‘no questions asked’ basis.

Pakistan
Drug Trafficking and unauthorised dealings in Virtual Assets
An STR was reported by XYZ Bank on the account of Mr. AM upon suspicion of his
involvement in unauthorised dealings in virtual assets. Activity on a Virtual Asset trading
platform revealed that Mr. AM was involved in the sale/purchase of Bitcoins, which is not legal
in Pakistan as per the Central Bank’s instructions.

The bank investigated the account of Mr. AM because transactional activity was reportedly
unusual due to high turnovers in the account and transactions with unrelated counterparties.
During the analysis of transactional activity, it became clear that the individual was involved
in the trading of virtual assets.

Further, Mr. AM was conducting high value transactions with various unrelated counterparties,
most of whom were suspected of being involved in Hawala or other criminal activity. As per
the Pakistan FIU’s databases, one of Mr. AM’s counterparties, Mr. BA, a proprietor of M/s AA
was found during an investigation by the Anti-Narcotic Force to have acquired proceeds from
the sale of drugs. The account of Mr. BA was credited with a substantial volume of funds from
the account of Mr. AM with no clear purpose.

The financial intelligence was shared with law enforcement agencies and the central bank as it
was suspected that Mr. AM is involved in virtual asset transactions and possibly facilitating
others to route the proceeds of crimes using virtual assets.

Ponzi scheme & Crypto currency

APG Typologies Report 2021 33

An STR was raised by XYZ bank on an entity, namely ABC, as complaints were received by
the bank through the Prime Minister’s Delivery Units (PMDU) and the complaint portal of the
Company Registry (SECP) that the entity ABC Trading was involved in the unlawful activities
of soliciting unauthorised deposits from a public offering promising unrealistically hefty
returns on investments. As per the website of ABC trading, it was dealing in the sale/purchase
and investment in cryptocurrencies and also offered wallet facilities and ATM facilities for
cryptocurrencies in different jurisdictions.

ABC Trading was not found to be registered with the Securities & Exchange Commission of
Pakistan (SECP). It was identified through complaints that the entity was working in the
jurisdiction presumably through multiple different incorporated companies while their affairs
are run by three individuals including Mr. SR, his wife Mrs. ZK and his son Mr. AW.

Furthermore, multiple STRs were also reported by different banks on Mr. SR and his family
members based on their involvement in Ponzi schemes and cryptocurrencies on a large scale.

Mr. SR had opened 70 bank accounts during the period 2011 to 2020 where the funds were
mainly credited through online cash coming from different cities of the jurisdiction and debits
to the accounts were made through clearing transactions. 59 out of 70 accounts were opened
during the period 2018 to 2020. A huge turnover was observed in the accounts. Most of the
funds were credited through online cash and debited through centralised inward clearing, pay
orders and cash.

The same business address was provided in the account opening forms for diversified
businesses run by these individuals under different business names. Upon a search in Inland
Revenue’s database of taxpayers, it was discovered that a nominal amount of tax was paid by
the businesses. The financial intelligence was shared with relevant law enforcement agencies
and the Central Bank in order to investigate the matter.

Philippines
Receipt of deposit/fund transfer with no underlying legal transaction involving bitcoin
The subject opened a passbook with ATM access account in a bank in the Southern Tagalog
Region, Philippines, in January 2020. Based on the completed customer information sheet, the
subject earned a monthly income of PHP 70,000 (USD 1,461) as the business owner of a
general store. However, the bank’s monitoring system triggered an alert due to an inward
remittance from a single sender amounting to PHP 55,400 (USD 1,156) in March 2020. The
bank attempted to contact the subject to request supporting documents for the alerted
transaction. The subject was contacted on 13 May 2020, and he disclosed that the transaction
was payment from a customer who ordered 5,000 facemasks. However, the bank ascertained
that the inward remittance was from a verified Bitcoin company. The subject was advised to
visit the branch to provide supporting documents, but the client failed to do so due to the
imposition of enhanced community quarantine (ECQ). The branch asked the subject to e-mail
a copy of the voucher and delivery receipt or any proof of the transaction. The subject submitted
a delivery receipt and a voucher but upon checking, the documents were deemed unacceptable.
The bank also requested that the subject provide a copy of the delivery/courier receipt and
screen shots of conversations regarding the transaction since the subject claimed that the
transaction was the result of an online sale. The bank called the subject almost every day
between 13 and 27 May 2020 to seek further documents, but to no avail. The subject is now

APG Typologies Report 2021 34

rejecting the bank’s calls, and funds from the subject’s account have gone below the
maintaining balance.

Online shopping bitcoin scam

A buyer bought a treadmill from an online marketplace and the online seller instructed the
buyer to deposit the payment in a certain bank account. On 1 June 2020, the buyer made five
fund transfers, totalling PHP 22,000 (USD 459), but the ordered item was never delivered. The
beneficiary bank account owner (Mr. BBAC) denied any relation to the online scammer/seller,
emphasising that he has never sold gadgets/equipment. Mr. BBAC mentioned that at the start
of the COVID-19 crisis, he started engaging in Bitcoin trading in a legitimate online peer-to-
peer finance platform, where individuals are registered under a username or alias. On 31 May
2020, Mr. BBAC traded Bitcoins with three users. Upon receipt of the screenshots of successful
payment transfers to his bank account, Mr. BBAC released the Bitcoins to the traders not
knowing that the transferred funds were from the buyer. Mr. BBAC submitted all the
supporting documents, including screenshots from the trades. Details of the ultimate
beneficiary/suspect remain unknown.

Singapore
Person L was sentenced on 28 January 2021 to four weeks’ imprisonment for providing digital
payment token services without a licence. This is Singapore’s first conviction under the
Payment Services Act (PS Act) which came into force in January 2020. The PS Act
criminalises individuals who carry on a business of providing payment services without a
requisite license under the said Act.
Sometime in late February 2020, Person L came across a job advertisement listed on a social
media platform by an online persona named “Person N”. The job required Person L to receive
monies in his own bank account, and use them to purchase Bitcoins for a commission set at
10% of the transaction amount.
Person L accepted the job, receiving 13 inward transfers into her bank accounts and
withdrawing close to SGD 2,800 (approximately USD 2110) to make multiple purchases of
Bitcoin at a Bitcoin machine. At Person N’s direction, Person L transferred the Bitcoins to
APG Typologies Report 2021 35
specified Bitcoin wallets, and deleted the WhatsApp conversation history between them from
her phone after every Bitcoin purchase she made.
Although the monies were traced to be criminal proceeds from online scams, investigations did
not reveal that Person L knowingly laundered criminal proceeds. Nonetheless, Person L was
culpable for an offence through her actions in providing the digital payment token services
without a licence.

5.3 Use of professional services (lawyers, notaries, accountants).

Malaysia
Involvement of Law Firm in Siphoning Company Funds
The suspect was appointed by a government agency to oversee the purchase of a landbank for
the planting of rubber trees. Deposits for the purchase of the landbank were paid into a law
firm’s client account which was subsequently transferred to a company before it was swindled
by the suspect and his associates, with the collaboration of the lawyer. The purchase of the
landbanks never materialised and was aborted by the government agency. The law firm allowed
the use of its client accounts to receive the proceeds of illegal activities before the subsequent
transfers to the company and ultimately the withdrawal of funds via cash cheques.

Philippines
Use of designated non-financial businesses and professions in setting up entities alleged to
have received funds from illicit activities
In 2018, a foreign government requested assistance from the Philippines in relation to an
ongoing investigation of its nationals for alleged drug trafficking and ML. The foreign
nationals transferred large funds to several jurisdictions, involving the fictitious import of
goods from the Philippines. The aforementioned subjects allegedly transferred PHP 1.53
billion (USD 30.6 million) worth of proceeds from drug trafficking to 21 Philippine-based
entities and two individuals. Four domestically incorporated service providers were recipients
of about PHP 189.3 million (USD 3.79 million) worth of proceeds. Financial records, however,
showed PHP 386.42 million (USD 7.73 million) credited to the accounts of the said four service
providers.

APG Typologies Report 2021 36

The 21 entities of the subject request were registered as service providers, trading companies,
software solutions, consultancy firms, among others. A certain lawyer and law firm facilitated
the incorporation of these companies including the four service providers.
Based on the typology, it was made clear that the lawyer and the law firm providing services
are within the scope of the DNFBP Guidelines, e.g. acting as a formation agent, providing a
correspondence address, and acting on behalf of juridical persons or arrangements, as defined
in the DNFBP Guidelines. They are covered persons under the Anti-Money Laundering Act of
2001 (AMLA), as amended, and as such should be registered with the AMLC.
The existence of typologies and the increasing number of STRs may demonstrate a higher
threat rating because these two expose the possible emergence of threats, involving legal
persons in the jurisdiction.

5.4 Trade-based money laundering.

Australia
Use of high-end electronics in TBML
In 2017, the Australian Border Force (ABF) commenced examination of a TBML referral from
another jurisdiction relating to the exploitation of trade in small portable electronics. Detailed
examination through a range of analytical techniques, supplemented by financial and criminal
intelligence, enabled ABF specialists to prepare a detailed criminal network assessment of
associated entities. Piecing together an extensive network of ML facilitators, the ABF found
more than AUD 500 million [EUR 319.8 million/ USD 388,806,522] had passed through
Australian bank accounts since 2014.
Proceeds were generated by the sale of drugs in North America. The criminal proceeds were
transmitted to bank accounts in South East Asia, before they were subsequently layered through
a multitude of Australian bank accounts in Australian FIs. The proceeds were remitted to
offshore bank accounts, or used to purchase small, high-end electronic devices for export to
companies in South East Asia and the Middle East. The undervaluation of exported devices
exaggerated the illicit value being transferred offshore.
In this case, the ABF was able to use a combination of automated and manual trade data
discrepancy analysis techniques to better identify and assess suspected instances of TBML.
Declarations of goods on export from jurisdiction A should match the corresponding import to
jurisdiction B (because the consignment, in theory, is the same thing). When they did not match
in this case, ABF officers had reason to believe that the discrepancies were an indicator of trade
mis-invoicing, and therefore, potential TBML. Further investigation and collaboration with
partner agencies have enabled the linking of the OCG with the transactions.

Daigou operations facilitating TBML:

Investigations have revealed a four-step methodology used in daigou operations to facilitate
TBML. Daigou operations refer to persons in one jurisdiction making, often large scale,
purchases for consumers in another jurisdiction.
Step One – Funds are generated from the sale of the illicit commodities (including Bitcoin
Diamonds (BCDs)) in Australia.
Step Two– Illicitly generated funds are then ‘pooled’ by a money laundering organisation
(MLO) and provided to multiple daigou coordinators. Encrypted communication platforms are
used by MLOs to provide instructions to daigou coordinators.

APG Typologies Report 2021 37

Step Three - Daigou coordinators take responsibility for distributing the funds to daigou
shoppers in Australia to fund purchases of consumer items. Daigou coordinators also partner
with related entities to fund business operations using pooled money.
Step Four – Consumer items are packaged and shipped overseas to an affiliated daigou
coordinator, which then sells the items and realises profits in the receiving jurisdiction.

Export indicators of TBML exploiting daigou networks:

 Key indicators of illicit or non-compliant behaviour exhibited include:
 Purchases by daigou shoppers are funded by pools of cash provided by coordinators;
 Pooled funds are held outside of the formal banking system;
 Shoppers receive payment for their activities in cash;
 An absence of legal documents evidencing the nature of the commercial relationship
between coordinators and shoppers;
 Off-setting arrangements between Australian-based daigou coordinators and their
offshore counterparts are documented in code and/or not declared to government
officials.

Bangladesh
Two garments companies ‘X Garments Ltd’ and ‘Y knitting Ltd’ exported goods worth USD
5.09 million to business entity ‘Z Ltd’ against 33 export bills through four banks namely ‘M’
‘N’ ‘O’ and ‘P’. 33 export bills (EXP) were issued by four banks against a sales contract on an
advance remittance basis. However, export proceeds amounting to USD 4.68 million out of
USD 5.09 million had not been repatriated from business entity ‘Z Ltd’.
Bank ‘M’ issued a Back to Back Letter of Credit (BTB LC) against a fake contract submitted
by Company ‘X Garments Ltd’. Bank ‘M’ issued two EXP and Bank ‘P’ issued 19 EXP against
contract and discounted the bills. Bank ‘N’ issued six EXP and Bank ‘O’ also issued six EXP
against contract on an advanced remittance basis.
The goods (FOB Value USD 429,000) exported through the letters of credit (LCs) issued by
Bank M, N and P were found to be sold in a public auction at ‘L’ Port of the importer
jurisdiction. The importer company ‘Z Ltd’ released goods of six EXP of Bank ‘O’ with copied
documents although the original shipping documents were found to be held in the custody of
Bank ‘O’.
Both company ‘X’ and ‘Y’ are directly connected with business entity ‘Z’ as the Managing
Director of company ‘X’ is also the owner of business entity ‘Z’ which is located in a
jurisdiction in the Middle East. Thus, it was revealed that Mr. ‘S’ had exported goods from his
Bangladeshi company to his own company located in a foreign jurisdiction and ultimately did
not expatriate the export proceeds and thus laundered money from Bangladesh through trade.
Based on the analysis, an Intelligence Report with supporting documents was disseminated to
Customs intelligence and Investigation Directorate, National Board of Revenue and Criminal
Investigation Department (CID), Bangladesh Police for further investigation and necessary
legal actions under the provisions of the Money Laundering Prevention Act (MLPA), 2012.

Embezzlement of Bank funds

Mr. X, the proprietor of export-import and supplier company ‘ABC Trading’ established
businesses abroad violating the provisions of the Foreign Exchange Regulation Act, 1947. An
APG Typologies Report 2021 38
open search revealed that ‘ABC Trading’ has 20 other sister companies out of which four
companies (1. AB Ltd, 2. BC Ltd, 3. CD Ltd, and 4. DC Ltd) were conducting business abroad.
A suspicious transaction report and media report triggered an investigation into the exports of
‘ABC Trading’ and an export order was identified that was valued at about USD 50 million
against 110 letters of credit (LCs), issued by four foreign banks, that had been sent to a
Bangladeshi Bank called PQR Bank ‘(LC Acceptance Bank). The LCs were issued by four
banks’ in favour of three importer companies, L Ltd, M Ltd and N Ltd for importing tiles from
the Bangladeshi company, ‘ABC Trading’. Although a team including the branch manager of
the LC accepting Bank, PQR Bank, visited the factory of ABC Trading, they did not provide
any visit report. Such a gap raised a suspicion as to whether the exporting company had any
production facility at all to export tiles.
On the other hand, analysing the credit reports of the tiles importing companies it was revealed
that the nature of the business of those three importing companies were leather and wool
products. The importation of different kinds of products in a substantial volume compared to
their respective paid up capital seemed suspicious. Furthermore it was found that the owner of
the three importing companies is a Bangladeshi Citizen Mr. Y.
Unconvinced about the export, further analysis was carried out by the FIU which revealed that
all the four LC issuing banks were Shell Banks. Mr. X & Mr. Y in collaboration with PQR
Bank’s senior executives successfully smuggled about BDT 25 (USD 295,115) million by
fraud, forgery and overvalued Export Bills. Later, the bank allowed the exporters to take
another BDT 18 million (USD 212,486) in the name of purchasing a documentary bill. In doing
so only 80 export bills out of 220 had been repatriated to Bangladesh in order to camouflage
illicit business. BFIU analysis concluded that the exporter and importer, in collaboration with
senior bank officials under the disguise of international trade had siphoned off money abroad.
Following the findings, an intelligence report was sent to the respective Law Enforcement
Agency under the Money Laundering Prevention Act, 2012 for further investigation and legal
action.

Fiji
Evasion and elusion
Company F was reported in a STR for making advance payments from Fiji to overseas
suppliers and failing to produce customs import entries on a timely basis to its bank. Fiji FIU
analysis showed movement of funds from the company loan bank account to the daily
administration bank account of Company F. Profiling revealed that Company F had stopped
importing in 2016 and began trading as another entity, Company B, since 2015. It was further
established that Company B was classified as a hotelier and that Service Turnover Tax (STT)
and Environment & Climate Adaptation Levy (ECAL) were also applicable to Company B.
The Fiji FIU established that Company B did not lodge its Service Turnover Tax (STT) and
Environment and Climate Adaptation Levy (ECAL) since 2015-2019. A case dissemination
report was sent to the local taxation authority for further investigation.

Singapore
Person A, the sole director of Company M, has been prosecuted for falsifying invoices and
money laundering offences.
Pursuant to intelligence received from Singapore’s Financial Intelligence Unit, the Suspicious
Transactions Reporting Office (STRO), the Commercial Affairs Department (CAD) of the
APG Typologies Report 2021 39
Singapore Police Force (SPF) commenced investigations into the matter. Sometime in early
2019, Person A became acquainted with an online persona, Person B, via social media, with
the latter claiming to be an investor who was keen on investing into Person A’s company.
Subsequently in July 2019, Person B sought the assistance of Person A to receive and transfer
funds to overseas beneficiaries for which Person A would receive a commission for the
deposited amount. Person A agreed and allowed the use of Company M’s bank account for this
purpose.
Company M’s bank account was eventually found to have received proceeds, amounting to
approximately SGD 225,000 (approximately USD 169,546), arising from an alleged business
email compromise fraud victim based in jurisdiction N. Pursuant to notifications received by
the bank in relation to a funds recall request on this sum of money, Person A submitted a false
invoice to the bank to justify the legitimacy of the transaction, stating that Company M had
provided the stated services to a client when it did not. He further extended a copy of the false
invoice to Person B to solidify the deception should further checks be made.
Singapore informed the authorities of jurisdiction N that their citizen had been a victim of
fraud, which led to eventual exchanges of information. The successful cooperation between
jurisdiction N and Singapore authorities was valuable towards the prosecution of money
laundering offences, arising from a foreign predicate offence.

5.5 Underground banking / alternative remittance services / hawala.

China
Case on Underground banking
D, W and other suspects developed a website and a smart-phone based application to sell game
cards and provide top-up services for both Chinese and foreign clients. They provided illegal
cross-border currency exchange, payment and settlement services on third-party platforms for
commission.
The public security agency and the AML department of the People’s Bank of China established
a joint task force to carry out an investigation. In 2020, the public security agency launched a
crackdown on the criminal network and arrested more than 50 suspects.

Chinese Taipei

APG Typologies Report 2021 40

Mr. J was the owner in charge of S group company (S Group) and its subsidiary companies.
Between January 2016 and August 2020, with the intention of making a profit by furnishing a
place to gamble or assembling people in order for them to gamble, Mr. J convened with various
members to establish W online gambling group company (W Group) and set up its branch
companies to support the group’s basic functions such as hardware maintenance, client
services, database management, and financial management. In 2016, W Group began to attract
the interest of site owners from other online gambling websites who wished to use the platform
designed by W Group and its backstage management services. W Group allotted the profit with
those site owners based on a monthly revenue. It was estimated that from the period up to the
end of 2019, over 500 site owners had joined, while W Group received approximately NTD
59.5 billion (USD 2,121,308,344) profit during 2016 to 2020.
It was discovered that most of the gamblers were from Jurisdiction X. Those gamblers had
transferred funds into the dummy accounts provided by W Group. W Group then moved the
funds back to Chinese Taipei using an underground banking system. When Mr. J and his
accomplices received the above gambling gains in the form of NTD, they then hid the proceeds
in a safe deposit box placed in the subsidiary company filed under S Group and used some to
pay personnel and equipment costs of S Group. Moreover, in order to launder the illegal gains
through investment, Mr. J and his accomplices established an investment company D, then
purchased the stocks of public companies under the names of D, Mr. J, and his accomplices.
Furthermore, assisted by the group member, Mr. J purchased the plots of lands to facilitate
further investment projects in Jurisdictions P, Q and R, as well as acquiring a public company
T in jurisdiction S.
The Prosecutors’ Office prosecuted Mr. J, along with his accomplices for violations of the
Criminal Code and Money Laundering Control Acts in October 2020.

Hong Kong, China

Case 1
Frequent HKD and USD transactions amounting to HKD 1.6B (USD 206,023,727) and
temporary repository of funds were observed in the bank account of an alleged technology
company in Hong Kong, China. The pattern of transactions gave rise to a suspicion of activities
of an unlicensed money services operator. A police investigation revealed that the company
was indeed a shell company and action has been taken to strike it off from the Companies
Registry. A police investigation is ongoing.

Case 2
Over HKD 300,000 (USD 38,628), mainly sourced from cash top-up at convenience stores or
by peer-to-peer fund transfers via e-wallets, was deposited into stored value facility (‘SVF’)
accounts of a domestic helper in Hong Kong, China and her employer. The funds were then
credited to another SVF account under the name of the domestic helper. Investigation revealed
that the domestic helper registered three SVF accounts using the identity card of her employer
without consent for remitting monies to her home jurisdiction. The domestic helper was
arrested and she admitted that she wired monies for her friends and charged them remittance
fees. The domestic helper was charged with ‘Fraud’ and ‘Operating Money Service Without
Licence’.

New Zealand

APG Typologies Report 2021 41

Alternative remittance network laundering proceeds of illicit drug offending within NZ
A network of Auckland-based foreign-exchange and money transfer businesses are suspected
to have knowingly facilitated the movement of millions of dollars’ worth of criminal proceeds
derived from illicit drugs, fraud, and other acquisitive crimes. The network used cash collectors
to conduct cash pickups from clients wishing to remit funds internationally and deposit the
funds into bank accounts of young, third-party mainly foreign nationals in NZ on student visas,
where the funds would be consolidated and used to complete remittances from offshore parties
seeking to move funds into NZ as NZD (an informal value transfer system). A significant
proportion of the cash collected by the network’s collectors is believed to have derived from
serious illicit drug offending, along with fraud and other acquisitive offences. Neither the
principals nor the collectors undertook sufficient (if any at all) CDD on their customers.

Pakistan
Tax Evasion/Illegal Money Value Transfers
A reporting entity raised STRs on four different individuals for remitting a substantial amount
of funds from jurisdiction D to multiple persons in Pakistan. The remitters were Pakistani
nationals residing in jurisdiction D, and were engaged in different occupations/businesses.
Funds were remitted through an exchange company of jurisdiction D with the purpose of
“Home Remittances”. Such a substantial number of remittances sent with the sole purpose of
home remittances created suspicion.

These four individuals remitted a considerable amount of funds through 1300 transactions to
more than 500 individuals in Pakistan. Upon a detailed analysis, more than 28 common
beneficiaries were found who were receiving funds from more than one remitter. Nine out of
28 beneficiaries belonged to four different business groups where they held key management
positions and received remittances from more than one remitter. These nine beneficiaries paid
a very low amount of personal and business income taxes during the last three financial years.
During the analysis, it was also identified that a business entity namely XYZ Trading run by
one of the beneficiaries was already under investigation by a law enforcement agency for Trade
Based Money Laundering charges. The financial intelligence was shared with the relevant
LEAs as the suspects were apparently involved in using the channels of IMVTS and home
remittance for tax evasion.

International Cooperation Request:

An international cooperation request for information on all the four remitters was sent to
jurisdiction D. The FIU of jurisdiction D responded in a timely manner with valuable financial
information on the subject remitters which was shared by FMU with the relevant law
enforcement agencies for analysis in their ongoing investigation.

APG Typologies Report 2021 42

Singapore
Person W has been prosecuted under the Payment Services Act for carrying out unlicenced
remittance businesses for allegedly receiving illicit proceeds which he tried to remit overseas.
Person W is a Singaporean who is employed at a money-changing company to introduce
customers to the company. However, Person W also provided money-changing and remittance
services in his own capacity despite not being licensed to do so.
Person W assisted his customers to change or remit monies via net settlements with his overseas
contacts. He would collect cash from his customers, and contact his overseas contacts to
transfer the equivalent amount in foreign currency from casino accounts, to destination
accounts designated by his customers. In one instance, Person W assisted his customer, Person
T, to remit monies from Singapore to another jurisdiction, by collecting cash from third parties
under Person T’s instructions. It was eventually revealed that these monies which Person W
collected were fraudulently obtained, having arisen from government official impersonation
scams that targeted three individuals.

5.6 Use of the internet (encryption, access to IDs, international banking etc).
Hong Kong, China
A resident from Jurisdiction X found her online banking account being hacked, resulting in a
loss of approximately HKD 16 million (USD 2,060,186) via 23 unauthorised transfers to other
bank accounts worldwide, where over HKD 5 million (USD 643,808) was remitted into three
bank accounts in Hong Kong, China. The funds were further dissipated to bank accounts held
by five shell companies in Hong Kong, China under the directorship of five local persons from
Jurisdiction Y. One HK individual was arrested and HKD 3.5 million (USD 450,660) was
frozen in the bank accounts. An investigation is ongoing.

5.7 Use of new payment methods / systems.

APG Typologies Report 2021 43
Hong Kong, China
Case 1
A bookmaking syndicate, with a view to receiving and laundering proceeds of illegal gambling,
set up a number of stored value facility (‘SVF’) accounts in Hong Kong, China under names
of their brokers and subordinates. Gamblers transferred monies to brokers for exchanging game
points for gambling on the online website and redeemed the points for fiat currency through
the brokers via SVF transactions. The syndicate further transferred the crime proceeds to the
subordinates’ SVF accounts and cashed out at money exchange operators. An investigation
revealed that there were over 10,000 transactions amounting to HKD 4 million (USD 515,681)
made within two years’ time. 17 SVF account holders were arrested for the offence of
Conspiracy to gambling and Money Laundering. An investigation is ongoing.
Case 2
Through analysis of a series of cases of online investment fraud and online extortion wherein
victims were deceived to transfer monies to virtual bank accounts in Hong Kong, China, it was
revealed that these accounts were opened by subordinates employed by a bookmaking
syndicate. The syndicate was further found to have laundered crime proceeds totalling HKD
90 million (USD 11,588,125) with the assistance of the person-in-charge of a money service
operator. 38 persons were arrested. An investigation is ongoing.

Singapore
This is a syndicate case where Police investigated money laundering offences and offences
under the Computer Misuse Act, among others. In 2020, Person H, the mastermind, was
sentenced to 27 months’ imprisonment for money laundering offences and offences under the
Computer Misuse Act. Persons S and M were sentenced to 24 months’ supervised probation
and fined SGD 5,000 (approximately USD 3767) respectively. Between January to February
2019, Persons H, S and M created accounts on mobile applications services “E” and “D” to
facilitate a payment service fraud. Service E is a stored value card which could be used for
payment of merchandise, and offers a cash refund service as one of its features. Service D
offers virtual prepaid card services. After linking the two App accounts, the perpetrators took
advantage of an automatic reload function of Service E with Service D when the former reached
minimal balances. Under this arrangement, Service E allowed users to transact on the 'topped-
up' balance while only settling the debt with Service D at a later stage. Users of the Service E
App were also able to 'refund' the remaining balance in their accounts to a specified bank
account. Thus, by deliberately maintaining an insufficient balance in their Service D accounts,
the perpetrators were able to incur mounting debts with Service D, which they had no intention
of paying off, whilst receiving ‘refunds’ into their personal bank accounts from which they
withdrew cash from ATMs. By virtue of using Service E in the manner described, Person H
had committed offences under the Computer Misuse Act. Under this scheme, Person H
managed to obtain ‘refunds’ into his bank account amounting to a total of approximately SGD
36,000 (approximately USD 27,127), either directly using his own bank account or with the
assistance of other parties involved in the scheme, such as Person S and Person M. Person H
subsequently spent the illicit funds on himself.

APG Typologies Report 2021 44

5.8 Laundering of proceeds from tax offences.
Australia
In July 2020, AFP Operation BORDELON went to resolution, which resulted in the arrest of
a number of Australian-nationals for their alleged involvement in a large-scale tax fraud
conspiracy involving misappropriating ‘Pay As You Go Withholding’ (PAYGW) tax from the
Commonwealth, through a structure of entities within the labour hire industry. The proceeds
of this crime were subsequently laundered through separate entities both within Australia and
overseas.
The alleged fraud involved the following three tier structure:
Tier One comprised two well-established labour hire companies, directed by trusted
professional facilitators. These companies contracted services out to multinational construction
entities (clients) to provide labour hire and payroll services. The clients, through an invoice
financing arrangement, paid the Tier One companies for labour hire services. Upon receipt of
these payments, the Tier One companies then transferred the gross wages, plus superannuation,
into the payroll service companies (Tier Two).
Tier Two comprised one or more payroll entities, which were appointed with professional straw
directors by the syndicate. These companies processed the payroll, transferring the net wages
and superannuation to the nominated employee accounts. Financial analysis identified the
syndicate’s professional facilitators received part of the PAYGW tax as payment from this Tier
in return for their services. The remaining PAYGW tax was then withheld from the ATO and
transferred directly to the Tier Three companies.
Tier Three comprised multiple companies, operated and controlled by the syndicate. False
invoices were allegedly used to disguise the true nature of the financial transfers to these
entities (for example, to characterise them as payments for consultancy work, or loans). The
proceeds of crime were then transferred on to the personal and corporate accounts of members
of the wider criminal syndicate, for their financial benefit.
APG Typologies Report 2021 45
Fiji
Tax Evasion and Accumulation of Unexplained Wealth
The Fiji FIU received a STR on Person A for the misuse of their personal account for business
related transactions, conducting large deposits and a possible case of tax evasion. Checks by
the Fiji FIU revealed that Person A was a director of a company and had a sole proprietor
business. The nature of business for the company and the sole proprietorship was the provision
of freight services and both business entities had alleged to have incurred accumulative losses
for the past four years. However, the Fiji FIU established that Person A received large sums of
“salary” amounting to more than $450,000 (USD 221,904) within the four years from the
company despite declaring losses for both business entities. Further analysis also revealed that
Person A opened a term deposit of $130,000 (USD 64,105) subsequent to declaring the losses.
A case dissemination report was provided to the local taxation authority.

Hong Kong, China

Two residents of Jurisdiction X were arrested in Jurisdiction X for smuggling cash out of the
jurisdiction and luxurious goods from Hong Kong, China to Jurisdiction X without declaration.
Fake invoices purporting that the value-added tax was settled in Jurisdictions X and Y were
also found to have been presented for the purpose of tax evasion. An investigation by Hong
Kong Police revealed that the suspected proceeds derived from the tax evasion were remitted
to bank accounts in Hong Kong, China and HKD 11 million (USD 1,416,315) was withheld.
An investigation is ongoing.

Indonesia
As stated in the Academic Paper on the Effectiveness Index of AML/CFT by the Indonesian
FIU, the Financial Transaction Reports and Analysis Centre (PPATK) in 2020, the case of
money laundering with predicate offences in the field of taxation was carried out by Mr. RAS
by issuing tax invoices that were not based on actual transactions and the misuse or
unauthorised use of a Taxpayer Identification Number or Taxable Entrepreneur Registration
Number. The state losses arising from this crime amounted to IDR 577 billion (USD
39,903,910). The typology carried out by Mr. RAS in carrying out money laundering proceeds
of crime is as follows:
a. Placing; placing the proceeds of tax crime by ordering agents or sellers and users of
fictitious invoices to deposit funds into Mr. RAS’ account and / or on behalf of the suspect's
company for at least IDR 25,761,908,836 (USD 1,781,455).
b. Transferring; transferring the proceeds of tax crime by transferring money on behalf of
the suspect either at the same bank or to another bank and transferring money from the
suspect's company either at the same bank or at a different bank, and transferring money
from the suspect / company belonging to the suspect's third party account. There were
minimum incoming transfers of IDR 51,881,427,007 (USD 3,586,524) and USD
1,465,648, and minimum outgoing transfers of IDR 14,002,394,683 (USD 968,290) and
USD 75,855.
c. Spending; to spend the proceeds of the tax crime by purchasing assets in the form of
property and offices of at least IDR 15,200,000,000 (USD 1,050,728).

APG Typologies Report 2021 46

New Zealand
Laundering of tax evasion proceeds
A restauranteur concealed more than NZD 6.5 million (USD 4,660,912) in primarily cash sales
conducted through the chain of 13 restaurants he owned, during a six-year period. As part of
this plot, his companies filed 115 GST returns which contained false or misleading sales figures
and a GST tax shortfall of more than NZD 700,000 (USD 501,953).
The proceeds of the offending was laundered via discrete activities which were undertaken
with the express intention of concealing the source of funds. This included handing bags of
cash to his accountant which was then sent around the world and laundered through foreign
exchange transactions and forex trading.
Given the offending spanned many years, the absence of reliable records and the offender’s
persistent failure to ensure tax returns were filed by his restaurants, the precise scale and nature
of the offending is unknown. The offender pled guilty to 34 tax evasion charges and nine
charges of money laundering and was sentenced to three and a half years imprisonment and
fined NZD 50,000 (USD 35,853).

Singapore
The Inland Revenue Authority of Singapore (IRAS), Commercial Affairs Department (CAD)
of the Singapore Police Force and the Corrupt Practices Investigation Bureau of Singapore
(CPIB) initiated a joint investigation against Person A. In June 2020, a foreign national, Person
A, was convicted on tax evasion, corruption and money laundering offences, and sentenced to
18 months’ imprisonment and a tax penalty of SGD 60,000 (approximately USD 45,212).
Person A made at least six fraudulent tourist refund claims under the Electronic Tourist Refund
Scheme (“eTRS”) in 2013, with the assistance of Person B who was a Singapore Customs
officer responsible for approving the said claims. Investigation showed that Person A gave
bribes to Person B for endorsing the fraudulent claims. Person A subsequently departed
Singapore over several occasions with the GST refunds totalling cash of SGD 27,895
(approximately USD 21,020), which constituted the removing of criminal proceeds from
Singapore.
Person A left Singapore prior to the commencement of investigations, but he was swiftly
apprehended upon his re-entry to Singapore in October 2019. Person B was also convicted and
sentenced for tax evasion and corruption offences and is no longer employed with Singapore
Customs.

5.9 Real estate, including roles of real estate agents.

Chinese Taipei
In December 2018, Ms. C and her accomplices forged the contract which enabled the
borrowing of Mr. W's name for real estate registration, and also engraved Mr. W’s seal without
his consent. The contract recorded that Ms. C purchased a plot of land A from Mr. X, and
registered it under Mr. W’s name.
According to this contract, Ms. C is allowed to ask Mr. W to return the land to her at any time.
With the purpose of defrauding the other financiers, Ms. C then designed a fraud scheme, by
which she first accused Mr. W of not returning land A to her after she formally made a legal
request; then Ms. C made a civil writ mediation petition and brought it to court. In January
2019, Ms. C’s accomplice faked his identity as Mr. W and appointed a lawyer to make an
APG Typologies Report 2021 47
agreement with Ms. C. Ms. C then acquired the legal ownership of land A. Ms. C subsequently
hired the agent Ms. L to introduce to her people who could provide financial aids after reaching
an agreement with Ms. C that Ms. C provided the land A and used it as collateral to the
financiers under a maximum-amount mortgage.
In order to conceal and transfer the illegal gains, Ms. C opened her personal accounts at Bank
E and Bank F as well as her banking account opened at Bank G. After receiving the remittances
from those aforementioned financiers, Ms. C went to those banks to make cash withdrawals in
small amounts many times. In addition, she asked the above banks to issue cashier’s cheques
and subsequently borrowed other people’s bank accounts to cash those cheques.
After investigation, the case was referred to the Prosecutors’ Office in August 2019 for
violations of the Criminal Code and Money Laundering Control Act.

Fiji
Money Laundering through Real Estate Transactions Persons
A, B, Y and Z, who are foreign nationals, were reported to the Fiji FIU in a STR for a possible
case of money laundering involving a real estate transaction of over FJD 2.8 million (USD
1,380,713). In December 2019, Person A attempted to purchase a high-end luxury property for
FJD 12.5 million (USD 6,163,944). Person A and another unknown individual met with the
real estate agency regarding the property deal. In January 2020, Person A arranged funding
through Person Y in jurisdiction Q, who remitted over FJD 2.8 million directly into the real
estate agency’s trust account as the deposit payment. Person A stated that Person B, who was
his business partner in jurisdiction E, would be listed as the owner of the property in the sale
and purchase (S&P) agreement. When the offer by Person A of FJD 10 million (USD
4,931,206) was not accepted by the vendors of the property, he instructed the real estate agency
to refund the deposit amount to another individual, Person Z in jurisdiction Q. Fiji FIU analysis
revealed that Person A was the only party communicating with the real estate agency through
email and instant messaging applications, which did not include Persons B, Y and Z. It
appeared that Person A was the main party in control of the real estate transaction. Interestingly,
Persons A, B and Y had never travelled to Fiji and it was noted that Persons Y and Z had the
same dates of birth. Further checks with national and international law enforcement agencies
revealed that Person A was allegedly working with an organised crime syndicate involved in
illicit importations of drugs in jurisdiction Y, and that Person B and Person Z are jurisdiction
Q nationals issued with jurisdiction E citizenship through jurisdiction E Government
Development Support Program. Additionally, it was established that Person B was a red notice
fugitive in jurisdiction Q, who was using fake identification documents in Fiji. Person B was
deported to jurisdiction Q in January 2020.

APG Typologies Report 2021 48

Hong Kong, China
Members of a syndicate purchased eight luxury real estate properties in Hong Kong, China and
applied for mortgage loans with the banks. An investigation revealed that the proof of income
in the mortgage loan applications was fictitious and artificially made up by the syndicate. Nine
syndicate members were arrested with HKD 10 million (USD 1,287,484) in proceeds of crime
temporarily frozen. An investigation is ongoing.

5.10 Trade in gems and precious metals.

Australia
In October 2020, the United States Office of Foreign Assets Control (OFAC) listed an
Australia-based al-Qa’ida-associated facilitator person A for having materially assisted,
sponsored, or provided financial, material, or technological support for, or goods or services to
or in support of, Al-Qa’ida.
Person A has had financial dealings in a number of jurisdictions and is involved in dealing
gemstones, which provide him with the ability to move funds internationally for the benefit of
al-Qa’ida. Person A conducts business around the world.
Hong Kong, China
A person and two accomplices purchased 3,000 taels32 of gold bars with HKD 60 million (USD
7,724,993) cash at a goldsmith shop in Hong Kong, China. The trio were arrested and an
investigation revealed that they were paid to collect the cash from a money service operator for
the purchase and deliver the gold to others. Further investigation revealed that the monies were
remitted from Jurisdiction X and the gold would be delivered to a syndicate in Hong Kong,
China. Three syndicate members were then arrested with a total of 600 pieces of 5-tael gold
bars, cash and jewelleries amounting to HKD 78 million (USD 10,042,222) seized. An
investigation is ongoing.

Singapore

32
A Chinese unit of measurement. One tael is defined as 1+1⁄3 ounce and is approximated as 37.7994 g

APG Typologies Report 2021 49

In March 2020, three precious stones and precious metals dealers (“PSMDs”) – Companies P
and G and Person T – were charged in court with offences under the Corruption, Drug
Trafficking and Other Serious Crimes (Confiscation of Benefits) Act, Chapter 65A
(“CDSA”).This was in relation to a series of frauds perpetrated in 2019 by a criminal syndicate
against a public agency, which resulted in total losses of SGD 40 million (approximately USD
30 million). In particular, two of the syndicate members were found to have used the criminal
proceeds to purchase SGD 600,000 (approximately USD 452,123) worth of jewellery and gold
bars from these three PSMDs using cash. These two syndicate members have been charged
with money laundering offences, among others. In Singapore, PSMDs who enter into cash
transactions exceeding SGD 20,000 (approximately USD 15,070) are obligated to submit a
cash transaction report (“CTR”) to a Suspicious Transaction Reporting Officer within 15
business days. The three PSMDs in this case had failed to do so for the said purchases.
Furthermore, Person T also failed to perform the requisite customer due diligence which was a
punishable offence under the CDSA. Between August and October 2020, Company P and G
and Person T were sentenced to fines ranging from SGD 9,000 (approximately USD 6,781) to
SGD 40,000 (approximately USD 30,141).

5.11 Association with human trafficking and people smuggling.

Hong Kong, China
Hong Kong Police neutralised a human smuggling syndicate, which arranged sea passage and
entry of illegal immigrants from Jurisdiction X to other jurisdictions through Hong Kong,
China, and resulted in the arrest of the ringleader and three active syndicate members. An
investigation revealed that suspected crime proceeds of about HKD 3.4 million (USD 437,766)
were laundered via the ringleader’s two personal bank accounts in Hong Kong, China. The
ringleader was convicted of ‘Money Laundering’ and sentenced to 3 years’ imprisonment. A
total of HKD 270,000 (USD 34,764) was also confiscated.

5.12 Use of nominees, trusts, family members or third parties etc.

Hong Kong, China
Case 1
An investigation into the personal bank accounts of an arrested drug trafficker in Hong Kong,
China and his close relatives revealed that the drug trafficker had been controlling his own and
mother’s bank accounts to launder over HKD 7 million (USD 901,293) in crime proceeds. The
drug trafficker was charged with Money Laundering and a court proceeding is ongoing.
Case 2
A joint operation was launched between Hong Kong, Jurisdictions X and Y to combat against
cross-jurisdictional drug trafficking activities where the syndicate ringleader had been
arranging fishing vessels to transport dangerous drugs from Jurisdiction X to other jurisdictions
and colluding with his associate in Jurisdiction Y to procure vessels and recruit crews for the
transportation. An investigation revealed that the ringleader and his two family members had
used 21 bank accounts in Hong Kong, China to launder HKD 113 million (USD 14,548,025)
APG Typologies Report 2021 50
in drug proceeds. One of the family members was convicted of 11 counts of Money Laundering
and sentenced to 3 years of imprisonment. The remaining HKD 42 million (USD 5,407,255)
in her bank accounts was confiscated.

Indonesia
Mr. NL is the President Director of the XYZ Financial Credit Institution (FCI) which aims to
raise public funds without a business license from the regulator and then lend funds to the
public with an interest rate of 10%. During the 5 years of operation, the FCI managed to raise
funds amounting to IDR 413 billion (USD 28,533,176) from 16,155 customers. However, on
the other hand, FCI XYZ did not actually obtain a business license from the management of
Bank Indonesia.
For each fund that has been collected, an amount of around IDR 7 billion (USD 483,791) to
IDR 10 billion (USD 691,120) in the FCI XYZ account, will be transferred by NL to a personal
account which is then transferred back to many accounts, including accounts belonging to NL,
NL's wife, NL's children and employees. In addition, NL also used the money to purchase
assets in the form of land, buildings, project payments, cars and three insurance policies worth
IDR 500 million (USD 34,555) each. For this act, NL has been sentenced to four years and a
fine of IDR 1 billion (USD 69,084).

Macao, China
Suspects B and C, who are a couple, allegedly embezzled over USD 800,000 from jurisdiction
N. In order to disguise and conceal the illicit origin of the funds, suspects B and C remitted
their deposits in jurisdiction N to Macao, China and informed suspects D and E, who are
suspect C’s parents, to collect the money. Suspects D and E repeatedly received the remitted
funds at banks, applied for fixed deposits, bought insurance policies, purchased stocks and
shares, and engaged in real estate property transactions in Macao, China to transfer and conceal
illegal proceeds, by converting illegal proceeds into other forms of assets.
Suspects B and C were convicted of embezzlement and sentenced by the court of jurisdiction
N afterwards. In 2020, suspects B, C, D and E were charged for money laundering by the Public
Prosecutions Office. When jurisdiction N was investigating the embezzlement case against
suspects B and C, a request for mutual legal assistance in criminal matters was issued to Macao,
China for assistance in investigation and getting evidence.

Pakistan
Money Laundering/Tax Evasion

STRs were reported against multiple members of a family and their employees by two different
reporting entities during 2019 and 2020 on the grounds that they were maintaining various
bank accounts and giving the mandate of operating those accounts to two family members, Mr.
A and Mr. B, who were related as father and son.

Upon analysis of multiple STRs raised by reporting entities on members of a family and their
employees, it was found that they were all engaged in the timber business in a famous market
of one of the biggest cities of the jurisdiction. Moreover, it was also revealed that alongside
running sole proprietorship businesses, they were also holding the positions of directorship in
a number of private limited companies and were maintaining individual, sole proprietorship

APG Typologies Report 2021 51

and company accounts. The same business addresses and contact numbers were provided in
account opening forms of all the bank accounts. After an analysis of the statements of those
accounts, it was observed that a substantial amount of funds were routed through various
accounts being maintained by the family members and their employees at different banks. After
receipt in the accounts, the funds were then immediately transferred to the accounts of other
members of the family where Mr. A and Mr. B exercised effective control. Funds were also
credited through transfers by the counter parties located in far flung areas of the jurisdiction
who appeared to be involved in Hawala/Hundi. In addition to the accounts, of which there were
72 as reported in the STRs, 37 more accounts were identified in CTRs reported on the same
family members wherein the mandate of operating these accounts was again held by both the
individuals, Mr. A and Mr. B. Furthermore, a practice of opening new accounts and closing the
old ones by the accountholders was observed. Based on the analysis, the financial intelligence
was shared with an LEA to further investigate the matter for money laundering and tax evasion.

Philippines
Nationals from Jurisdiction X used and enticed Filipinos to register sole proprietorship
businesses and open bank accounts for the said businesses. The Filipinos were only the owners
on paper, while the Jurisdiction X nationals had full control of the business and the accounts.
Person Z (Jurisdiction X national) deposited millions of pesos into the accounts of Persons D
(Jurisdiction X national) and F (Filipino). The recipients of funds declared Company H, a
Philippine-registered business, as the source of funds.
The Anti-Money Laundering Council (AMLC), in coordination with the said law enforcement
agency, was able to trace the accounts and froze the funds with an estimated value of PHP 78
million (USD 1,624,174).

5.13 Gambling activities (horse racing, internet gambling, etc).

Chinese Taipei
CIB received information concerning a fraudulent syndicate T, which specialised in setting up
dummy accounts in Jurisdiction X and provided these accounts to others for illegal uses. After
an investigation, it was discovered that the principal suspect of the syndicate T, person A
recruited unspecified persons to open financial accounts in banks operated in Jurisdiction X,
and used those accounts to launder money through illegal online gaming operators.
It was determined that all of the recruited accounts were collected and used by a same group
working in the same building, which was deemed a laundering centre. It was estimated that the
daily money laundering flow was about 10 million in Jurisdiction X currency (USD 1,544,823).
On 8 June 2020, CIB searched the building and multiple locations and subsequently seized 19
computers, 87 telephones, 57 SIM cards, 23 application contracts, 323 USB keys from banks
located in Jurisdiction X, 140 Union Pay cards and other money laundering exhibits, and
arrested person A and another eight members who worked in the above laundering centre.
After a thorough investigation, CIB further found that the members working in the laundering
centre were all employees of Y Company. On June 18, 2020, CIB searched the head office of
Y Company and discovered another three online gambling platforms operated by Y Company.
CIB immediately seized 10 computers, 16 mobile phones, and 7 Union Pay accounts and
arrested the head of the company, person B, and his accomplices.

APG Typologies Report 2021 52

Hong Kong, China
Case 1
Hong Kong, China and Jurisdiction X jointly neutralised a cross boundary bookmaking
syndicate with 23 persons arrested for ‘Bookmaking’ and ‘Money Laundering’ in Hong Kong,
China and 33 persons arrested in Jurisdiction X during synchronised raids. An investigation
revealed that more than HKD 216 million (USD 27,806,578) derived from bookmaking
activities was laundered through 18 accounts in the names of four core syndicate members.
Three of them were convicted of ‘Money Laundering’ and ‘Bookmaking’ and sentenced to 24
to 57 months of imprisonment and HKD 2 million (USD 257,467) was confiscated. A court
proceeding is ongoing against the last mastermind who is facing a count of ‘Money
Laundering’ and HKD 20 million (USD 2,574,701) worth of assets in both Hong Kong, China
and Jurisdiction Y have been frozen.
Case 2
A financial investigation suggested that Mr. A had used his personal bank account and that of
his family members and associates in Hong Kong, China to launder crime proceeds of about
HKD 100 million (USD 12,873,244) in five years’ time. The residence of Mr. A was raided
with bookmaking paraphernalia such as betting slips and audio betting records seized. After
investigation, Mr. A, his family members and associates were charged with and convicted of
‘Engaging in Bookmaking’ and ‘Money Laundering’. Confiscation Orders were granted
against three of the convicted persons, who were ordered to pay some HKD 4 million (USD
514,928) to the Government.

Mongolia
An STR was submitted by a bank with the suspicion that ‘the amount, number and frequency
of transactions on customer B's account did not correspond to the customer's employment and
business. He may have been involved in organising illegal online gambling activities’.
FIU-Mongolia conducted an analysis on this STR collecting more information from reporting
entities and found out that person B was using his two accounts to collect betting money and
distribute winning money to players. During the period of analysis, person B received the total
amount of MNT 1 billion (approximately USD 350,000) in about 500 transactions through
ATM and domestic bank transfers to his first account. Moreover, he received MNT 5.7 billion
(approximately USD 2 million) into the same account from five different individuals in 3,025
transactions with descriptions containing the same word. It is assumed that these five
individuals were associates of person B. After receiving the funds, he transferred a large sum
of money from his first account to his second account. Then he transferred and distributed
money in small amounts to 6,000 different individuals from his second account through 70,000
transactions with descriptions containing random letters and numbers. In addition, the majority
of the aforementioned transactions were made from 1 am to 5 am at intervals of 1-2 minutes.
As a result of the analysis, FIU-Mongolia disseminated this case to a law enforcement agency
for further investigation.
During the investigation, it was established that these suspects organized illegal online
gambling, laundered the proceeds gained from such gambling and bought movable and
immovable properties worth MNT 4-5 billion (USD 1,404,201 to USD 1,755,251). The
investigation of this case is ongoing.

APG Typologies Report 2021 53

5.14 Purchase of valuable assets (art works, antiquities, race horses, vehicles,
etc).
New Zealand
Proceeds of multi-billion-dollar international fraud scheme used to purchase artwork,
property and vehicles in name of NZ foreign trust
A network of overseas-based offenders misappropriated billions of dollars from a (non-NZ)
government-owned investment company and laundered these funds via a complex network of
trust and company structures. One of the principals of the network (individual A) established
two NZ foreign trusts, naming himself and his close family members as beneficiaries, with a
NZ limited liability company established by a NZ TCSP to act as the trustee of the trusts. The
trusts owned assets in several overseas jurisdictions, including several pieces of artwork by an
internationally renowned artist, a luxury yacht, and luxury properties. The ownership structure
involved the creation of special purpose (non-NZ) companies which owned the assets; the
shares of these companies were owned by holding companies in another (non-NZ) jurisdiction,
whose shares in turn were owned by the NZ foreign trusts, the beneficiaries of which were
individual A and his family members.

5.15 Investment in capital markets, use of brokers.

Chinese Taipei
Mr. S was the owner in charge of T company, while Ms. Z was T company’s accountant as
well as cashier. During the period from 2016 to 2019, with the intention of embezzling the
company’s property for her own personal use, Ms. Z took Mr. S’ passbook and his seal of the
account opened at A bank, which Mr. S provided only for T company’s use, to withdraw a total
of NTD 7,615,420 (USD 272,306).
In order to conceal these illegal gains, during the period between 2018 and 2019, Ms. Z made
three separate withdrawals, extracting a combined sum totalling NTD 1,080,000 (USD 38,621)
from Mr. S’ aforementioned account, subsequently transferring this money into her son’s
settlement account to buy the stocks of C company.
After the investigation by MJIB, the case was referred to the Prosecutors’ Office in October
2020 for violations of the Criminal Code and Money Laundering Control Act.

Hong Kong, China

Two cannabis plant cultivation centres were raided, resulting in the arrest of four persons
including the mastermind Mr. X and his family member Ms. Y in Hong Kong, China. The 11
bank and securities accounts of Mr. X recorded total deposits of more than HKD 7 million
(USD 901,142) in 3,500 transactions, over half of which was deposited by cash from unknown
sources while the remaining portion was transferred from various counterparties. Ms. Y was
found to have controlled more than 15 bank and securities accounts and the total deposits
amounted to HKD 15 million (USD 1,931,008) in 7,500 transactions, which were inconsistent
with her financial background. Mr. X and another two persons were convicted and sentenced
to five years and 10 months’ imprisonment and over HKD 5 million (USD 643,657) was
confiscated. Ms. Y was charged with ‘Money Laundering’ and over HKD 7 million (USD
901,142) worth of assets were restrained. A court proceeding is ongoing.

APG Typologies Report 2021 54

Indonesia
Market Manipulation
Mr. AA is a Commissioner at Company A which is engaged in Investment Management as a
result of the separation of the Investment Manager Company division of SMI Company.
Company A itself has a license as an Investment Manager from the regulator.
Mr. AA uses parties as nominees to conduct stock transactions through 13 different securities
companies. Based on the identification of the Customer Securities Account of the nominee
parties, the account opening was carried out at the same bank, namely Bank XX and within the
same period or close.
The job profiles of nominee parties that are used vary widely, including private employees and
self-employed workers who have different income and age profiles and even have an income
of less than IDR 2 million (USD 138) per month.
Then, Mr. AA transfers to the accounts of nominees, which are then used to purchase one type
of the same share, namely XY shares. During 2016, Mr. AA's account had a total transaction
volume of IDR 7 trillion (USD 484,940,661).
Based on the analysis of financial transactions, there is a flow of funds in the form of "U Turn
Transactions" from the nominee party's account to Mr. AA's account. A comparative analysis
was conducted on the transactions of Mr. AA through the nominees. When the XY stock value
reached the highest value, the total transaction volume of the nominees reached more than 40
percent of the transaction volume of XY shares in the market. This shows the significance of
the sale and purchase transaction of XY shares by Mr. AA through the nominees. In addition,
the funds sent from Mr. AA to the nominees were only used to transact in XY shares. There is
an alleged affiliation between Mr. AA with XY Group because Mr. AA worked at XY Group
and there is a flow of funds in Mr. AA's account from several XY Group subsidiaries.

RDN: Securities account

PT: Company

APG Typologies Report 2021 55

5.16 Mingling (business investment).
Indonesia
Fraud and Illegal Bank
B Cooperative was a cooperative operating in the transportation and other businesses in
Indonesia. Its management consisted of Mr. AND as the chief, Mr. CEK as the Secretary along
with Mr. JUL and Mr. YUL as the administrators. Meanwhile, Company A which was also led
by Mr. AND was faced with a financial obligation that prevented Mr. AND from listing it as a
public company. It was stated that Company A was constrained by Bapepam’s (Indonesia’s
Securities and Exchange Commission) regulations so that the Company cannot go public if it
has obligations to more than 50 parties.
There was a partnership agreement between Company A and its investors (called partners).
However, Mr. AND made an agreement with Mr. CEK and the partnership was transferred to
Cooperative B without the partners’ knowledge. The partnership also transferred Company A’s
debts to B Cooperative, clearing the way for listing of Company A on the stock exchange.
However, B Cooperative was not licensed to accept deposits from public fundraising.
Partner funds of Company A that have been collected from 2007 to 2014 amounted to IDR
4,779,976,704,333 (USD 333,823,791) and around IDR 3,264,688,621,100 (USD
227,924,779) could not be retrieved by partners.
The investment money from the community/partners was placed by the defendants in accounts
in the name of the B Cooperative and was then withdrawn in cash by cheque and giro transfer
form. The funds were placed back through banking instruments by means of cheques, giro
transfer form and RTGS into the personal accounts of the defendants and companies owned by
the defendants, which amounted to around IDR 319,456,000,000 (USD 22,309,663). The funds
were used to pay employee salaries, pay vehicle tax and purchase land and building assets and
lend to Company A amounting to IDR 200,000,000,000 (USD 13,967,582).

5.17 Use of shell companies/corporations.

Hong Kong, China
A drug trafficker was arrested in Jurisdiction X and an investigation revealed that the drug
trafficker had laundered HKD 540 million (USD 69,524,478) through four corporate accounts
of two shell companies in Hong Kong, China, out of which HKD 138 million (USD
17,767,240) was remitted through remittance agents in Jurisdiction X. The directors of the two
companies were convicted of ‘Conspiracy to Money Laundering’ and sentenced to 38 months’
imprisonment.

New Zealand
NZ registered shell company used as part of international ML network
A NZ limited liability company (Company A) was incorporated and used to open bank
accounts in an overseas Jurisdiction (Jurisdiction A). Funds were sent to Company A’s
accounts in jurisdiction A from company B’s accounts in another overseas jurisdiction
(Jurisdiction B). Overseas inquiries established that Company A was likely being used as part
of a wider network of companies to move illicit funds from Jurisdiction B to Jurisdiction A.
Company A was listed as a ‘manufacturer or wholesaler’ but in reality it had no substantive
business operations either in NZ or the overseas jurisdictions. The payments made in Company
APG Typologies Report 2021 56
A’s name were accompanied by false invoices referencing textile products, with fake logos,
stamps and signatures that had been superimposed over electronic documents. Further inquiries
by offshore agencies established no goods were actually being shipped – they were ‘phantom
shipments’. Company A had been incorporated by a NZ TCSP whose website advertises
‘offshore asset protection and tax minimisation… with professional directorship services
provided on request.’ It had no substantive NZ footprint, no NZ bank accounts, and the
directors and shareholders were nominees appointed by the NZ TCSP.

Philippines
Use of business entities to facilitate drug trafficking
In August 2020, the AMLC published a typology on the use of Filipino nationals and their
businesses by foreign nationals in illegal drug activities.
The identified modus operandi involves Filipino nationals (“the front”), who register sole
proprietorship retail businesses with the Department of Trade and Industry (DTI) on behalf of
certain foreign nationals, who are the actual and ultimate beneficial owners (UBOs) of the said
businesses. The said businesses likewise operate without the capitalisation required by law for
foreign owners. These companies are under the complete control and operation of these foreign
nationals.

After registration with the DTI, the front goes to the bank (mostly commercial and universal
banks) with the newly acquired DTI registration permit to open an account in the name of the
newly registered business.

APG Typologies Report 2021 57

The said bank account will then be managed and controlled by the foreign nationals—the
UBOs—for the purpose of receiving funds from illegal proceeds. Moreover, the majority of
the registered sole proprietary businesses, as identified in this modus operandi, are discovered
to be “shell companies” or inexistent companies.

Singapore
Case one
Person G was sentenced to 10 months’ imprisonment in January 2020 for money laundering
offences. The co-accused, Person V was sentenced to five months’ imprisonment for using a
false document to dishonestly induce a local bank into approving his corporate bank account
application. Person G worked for an overseas corporate service provider and one of his
responsibilities included recruiting individuals to become nominee company directors and set
up corporate bank accounts in the company’s name. These nominee directors would then cede
control of the company and its bank accounts for a fee. Person G was aware that his employer
was in the business of selling shell companies and their corporate bank accounts, often for
criminals to launder money. In this particular case, Person G recruited Person V, and the two
persons visited Singapore in December 2018 to incorporate Company M and open corporate
bank accounts. Pursuant to this, Person G handed Person V a false document that portrayed the
latter as a successful businessman to assure the bank that the company was operated by
someone with sound financial standing. The Internet banking access token, together with
Internet login credentials, were then couriered to the overseas corporate service provider after
the bank account was opened.
In April 2019, CAD received a report that Company M had received USD 50,000 in criminal
proceeds in its bank account. CAD swiftly established the identities of the persons involved
and arrested Person G and Person V when they entered Singapore. CAD recovered around
USD 7,600 of criminal proceeds during investigations.

APG Typologies Report 2021 58

Case two
In August 2020, Person B was convicted in court for an offence under Section 157(1) of the
Companies Act, for his failure to exercise reasonable due diligence as a director. He was
sentenced to a fine of SGD 5,000 (USD 3,758) and disqualified from being a director for one
year. Two other charges under the Companies Act were taken into consideration for sentencing.
Between 2012 and 2015, the Commercial Affairs Department (CAD) of the Singapore Police
Force undertook money laundering investigations against six local companies for allegedly
receiving fraudulent funds amounting to approximately USD 2.25 million from jurisdictions
across three different continents. The predicate offences committed included boiler room
investment ruses and business email compromise frauds. Investigations revealed that all six
companies had no legitimate business operations in Singapore, and were in fact shell
companies. All of them were found to be incorporated with the assistance of the same corporate
service provider, Person B, who also appointed himself as a nominee director for each company
to fulfil the legal requirement of a local resident director under Section 145(1) of the Companies
Act. However, Person B made little effort to inform himself of the affairs of the companies,
including having little oversight over the corporate bank accounts maintained by these
companies. CAD managed to seize approximately SGD 45,000 (approximately USD 33,909)
which was returned to the victim, despite the fact that most of the alleged criminal proceeds
had been quickly dissipated prior to investigations.

5.18 Association with environmental crimes (illegal logging, extraction,

wildlife trafficking, etc.).
Australia
Joint Parallel Financial Investigation in Australia to Dismantle Reptile Smuggling Network
In 2016, the Australian Border Force (ABF) intercepted several outgoing international mail
parcels containing native wildlife. Together with several intercepted inbound packages
containing exotic wildlife they were linked to an Australian person of interest (POI). To further
investigate, the Department of the Environment and Energy (DoEE) undertook a joint
investigation with the AFP, and coordinated significantly with the ABF, the FIU (AUSTRAC),
the Department of Agriculture and Water Resources, and various state and territory wildlife
authorities.

APG Typologies Report 2021 59

The AFP confirmed that the POI coordinated an IWT criminal network to export Australian
native reptiles. Many of the POI’s exports were destined for associates in Jurisdiction X. The
investigation involved sharing intelligence with Jurisdiction X Police authorities on the
activities of POIs with Jurisdiction X nationality. A search was conducted on the POI’s
residence resulting in their arrest. During the search two Burmese pythons were discovered on
the property, along with approximately USD 30,000 in cash.
Financial intelligence helped identify the broader criminal networks. Bank transaction
information obtained from the FIU linked the primary POI directly to a number of Jurisdiction
X wildlife traffickers, supporting the criminal investigation. Likewise, FIU analysis showed
that the same Jurisdiction X entities had been sending funds to another Australian reptile trader.
The payment methods used were: cash; bank transfers; payments through a large Money or
Value Transfer Service (MVTS) provider; “in-kind” transactions (exchange of wildlife of equal
value); and transactions to associates and family members of wildlife traffickers. The volume
of financial flows is difficult to quantify; however, estimates indicate that the primary POI
stood to gain over half a million Australian dollars (USD 389,014) from an intercepted import
of fish, stingrays, reptiles and turtles from Jurisdiction Y.
The POI was convicted of six charges including: attempting to export regulated native
specimens (Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act)
303DD); importing of regulated live specimens (EPBC Act 303EK); possession of illegally
imported specimens (EPBC Act 303GN); and money laundering (Criminal Code Act 1995).
The individual was sentenced to four years’ imprisonment, with a non-parole period of two and
a half years. During the investigation, authorities confiscated approximately USD 30,000 in
cash as proceeds of crime, along with USD 340,000 (estimated value of the wildlife).

China
Case on illegal wildlife trafficking
In 2020, the China Customs seized 1.1 million Japanese eel fry smuggled and exported by
means of a fabricated declaration. As the Japanese eel fry cannot be artificially bred, it is a wild
animal protected by China’s wildlife conservation laws and regulations. By cooperating with
the China Anti-Money Laundering Monitoring and Analysis Center (CAMLMAC), the China
Customs quickly identified the fund chain linking sellers, customs clearance service providers
and overseas receivers, and identified the gang members and their trading modes. The law
enforcement agency cracked down on the eel fry smugglers and arrested 16 suspects. The value
of funds involved in the case reached 150 million yuan (USD 23,213,713), among which more
than 30 million yuan (USD 4,642,859) was frozen.

Hong Kong, China

An investigation into a crime syndicate in Jurisdiction X which has been engaging in cross
boundary bookmaking and illegal wildlife trading activities revealed that the mastermind had
been using bank accounts of his company and accomplices in Hong Kong, China to launder
over HKD 550 million (USD 70,814,566) and dissipated the crime proceeds for purchasing
bonds, securities and real estate. The two accomplices in Hong Kong, China were arrested with
over HKD 260 million (USD 33,475,035) frozen. An investigation is ongoing.

Indonesia
APG Typologies Report 2021 60
Based on the results of the Forest Products Circulation operation by a joint team carried out by
the Ministry of Environment and Forestry, the Indonesian Navy, Bareskrim (Criminal
Investigation Department) of Indonesian National Police Headquarters, Customs and Excise,
the Port Head has checked and secured 199 containers containing processed wood that are
suspected of being illegally logged.
The case relates to the transportation of wood from forest products without a certificate of
legality of forest products. Based on the results of document checking and inspection, only 12
transport documents were found in the form of Certificates of Legality of Processed Timber
Forest Products totalling 57 containers owned by Company A. 27 Containers owned by
Company B were confiscated because they were transported using a document in the form of
a Timber Transportation Note by the Company which did not match its designation. The Illegal
Timber Products are transported using a ship owned by Company C at the Port of Teluk
Lamong Terminal Co. Surabaya, East Java. The same thing was also done by Company D
which intentionally misused the timber forest product transport document issued by the
authorised official. The estimated value of the crime is in the hundreds of billions of rupiah.
It is known that based on the flow of funds, Company A has received incoming funds from
abroad amounting to IDR 5 billion (USD 349,766) as well as several cash financial transactions
in the billions of Rupiah. In addition, cash financial transactions received by DG as Director of
Company A amounted to more than IDR 13 billion (USD 908,558). Furthermore, the majority
of cash flows to DT, as the Director of Company A, were in the form of cash withdrawal
transactions reaching IDR 2 billion (USD 139,965). Meanwhile, TS (the director of Company
D) placed funds in insurance policies for individuals, children and wives in the amount of more
than IDR 3 billion (USD 209,948).

5.19 Currency exchanges / cash conversion.

Macao, China
A phone scam victim deposited cash into a designated Macao, China bank account multiple
times, as instructed by the perpetrator who was impersonating a police officer, with the incurred
loss being around MOP 200,000 (USD 25,000) in total. In order to receive part of the scam
proceeds, suspect A provided a bank account in Macao, China as required by the crime
syndicate. However, this bank account was held by suspect K, whose business was to provide
mobile application top-up and money transfer services. Upon receiving the funds in MOP,
suspect K exchanged the said illicit proceeds from MOP to another foreign currency, with forex
service charges deducted first, and then transferred the money in foreign currency into suspect
A’s mobile application or overseas bank account. Suspect A then remitted the money to another
overseas bank account designated by the crime syndicate. In the aforementioned case, despite
knowing that the transferred funds were derived from criminal activities, suspect A still
disguised the illicit origin of the funds and concealed his/her involvement in the scam by using
a third party bank account held by suspect K. In 2020, suspect A was charged with fraud and
money laundering by the Public Prosecutions Office and suspect K was charged for receiving
stolen goods.

Pakistan
Laundering of proceeds through illegal currency exchange and hawala/hundi business

APG Typologies Report 2021 61

STRs were raised against an individual, Mr. XX, on the suspicion that high value structured
currency exchange transactions were conducted by him which were not consistent with his
declared profile as a wage earner.
After an analysis it was identified that in addition to the STRs, the suspect was identified in a
large number of CTRs (cash transactions above the threshold of PKR 2 million- USD 13,078)
involving substantial amounts of funds with different reporting entities including banks and
exchange companies during the period 2016 to 2020.
70% of the CTRs were reported by different exchange companies during the period 2018 to
2020 whereas the remaining 30% were reported by different banks on the reported individual,
Mr. XX.
An analysis of the bank accounts of Mr. XX showed very minimal activity indicating that Mr.
XX was conducting transactions in other accounts. In order to determine the ultimate beneficial
owner of the transactions, the analysis was further extended to those accounts where Mr. XX
had conducted transactions. It was found that Mr. XX had been frequently conducting
transactions as an operator of the account of an individual named Mr. YY during 2020.
The Computerised National Identity Card (CNIC) number of Mr. YY was searched in FMU’s
database wherein it was found that financial intelligence on Mr. YY was already shared with
an LEA and was under investigation with the Law Enforcement Agency on account of his
possible involvement in illegal currency exchange and Hawala/Hundi business.
Based on the above information, it was suspected that Mr. XX was benami of Mr. YY and was
working as a conductor of transactions in Mr. YY’s accounts. The financial intelligence was
forwarded to an LEA to further expand the ongoing investigation against Mr. YY.

Singapore
Person L was an employee of a bank, whose duties involved facilitating the hedging of forex
exposure for customers. In this regard, he was allowed to enter foreign exchange (“forex”)
trades only after he received instructions from customers and had checked with the bank’s
treasury desk for prevailing quotes.
Between 2011 and 2013, Person L executed a scheme to conduct unauthorised forex trades in
his clients’ accounts, using the accounts maintained by two sole proprietorships controlled by
him as counterparties to these trades. Person L then made additional unauthorised trades in
other clients’ accounts to close the forex positions of earlier customers. Through this scheme,
Person L accumulated benefits amounting to approximately SGD 1.2 million (approximately
USD 0.9 million). Person L used these criminal proceeds to repay his outstanding credit lines,
and loans and exchanged the rest into foreign currencies for his own investments.
In 2019, Person L was sentenced to imprisonment of eight years and four months for offences
relating to the unauthorised modification of computer material, instigating others to commit
cheating by personation, and the laundering of proceeds of criminal conduct.

5.20 Use of credit facilities, credit cards, cheques, promissory notes etc.
Indonesia
Case one:

APG Typologies Report 2021 62

The defendant Mr. HT made modifications to credit cards issued by Bank X on behalf of Mr.
KS and Mr. RH by transferring data from the original credit card chip to a smart chip using X2
software so that the credit card can be used without going through the Bank X host system and
can be used on the Bank X EDC machine. Using a credit card on the EDC machine will issue
proof of the transaction so that the merchant thought that the transaction is legitimate and
registered with the host Bank X.
Furthermore, the defendant Mr. HT met the defendant Mr. BS and Mr. MFN to explain the use
of the modified credit card before use. The way it works is that after selecting the item to be
purchased, the buyer will be asked to enter a PIN so the defendant can enter a 6-digit PIN
randomly and the transaction will be successful. For the first time the defendant Mr. HT invited
the defendant Mr. BS and Mr. MFN conducted a trial using the card to purchase gold weighing
approximately 8 grams for IDR 3,200,000 (USD 224). After the defendant Mr. BS and Mr.
MFN knew how to use the modified card, they were ordered by the defendant Mr. HT to buy
goods such as gold, cell phones and electronic goods as priority items. The use of cards is
carried out in various shops from various regions on the islands of Sumatra and Java.
All proceeds from the purchase of goods were handed over to the defendant Mr. HT to be
converted into money / sold with the aim of disguising the proceeds of crime. The total loss
suffered by Bank X due to the use of credit cards is IDR 2,553,840,268 (USD 179,292). The
defendant Mr. HT distributed IDR 32,000,000 (USD 2,251) to Mr. BS and IDR 31,000,000
(USD 2,177) to Mr. MFN. The defendant Mr. HT used the money to pay debts, the cost of
living for his wife and children, to pay for rotating savings and credit association (Arisan in
Bahasa Indonesia), rent an apartment, and money amounting to IDR 175,298,871 (USD
12,329) was deposited into Mr. HT's colleague's account. While the defendant Mr. BS used the
money for a clothing manufacturing business and the defendant Mr. MFN used the money for
business capital.

Case two:
Person A as Head of Corporate Banking at Bank Z takes advantage of his position to facilitate
the credit application process of Company A for IDR 150 billion (USD 10,494,664). It is
known that the Beneficial Owner of Company A, namely Mr. HS, manipulated seven other
banks. Person A uses his authority to change the proposal for submitting a credit application
for Company A which was previously rejected by the Corporate Credit Risk Division. One of
the collateral or credit guarantees used by Company A as the underlying form of Company A
to Company B turned out to be fictitious in that Company C never had a debt to Company A.
In connection with this, the defendant received IDR 1.5 billion (USD 105,030) transferred from
Company A to person A for the purpose of "office operations". Person A then transferred the
funds to five accounts, one in his name and four accounts in the names of other parties. It is
also used to pay for hospital medical expenses, car purchases, credit card bills for overseas
trips, purchases of foreign currency in USD and SGD and house rentals.

New Zealand
Fraud/ML scheme using stolen cheques
A criminal network used stolen cheques to defraud NZ victims of more than $1.4 million (USD
1,003,447). The network used stolen chequebooks as payment for orders placed online. Once
the online order was placed the offenders asked for a bank account number to make a ‘bank
deposit’ as payment for the online orders. The offenders then deposited the fraudulent cheques
into the victims’ accounts via ATM deposit. When the victims looked at their account it looked
APG Typologies Report 2021 63
like they had been paid and they therefore began to make arrangements to have the goods
shipped. Several days later the deposit is identified as fraudulent, however, by this time some
goods had already been dispatched to the offenders. The network deposited stolen cheques to
a wide range of retailers across NZ, sourcing items such as gold bullion, jewellery, cameras,
computer goods, thermal imaging gear, off-road motor bikes and blank firearms.

Pakistan
Fraud/ Ponzi scheme

STRs were reported against Mr. AB and Mr. MA. Both individuals were involved in illegal
auto leasing businesses. They were using a social media platform to offer the public a number
of investment schemes at an unrealistically high rate of profit. FMU initiated the case for
analysis of STRs against both of the individuals.

FMU analysed the accounts of both individuals. It was revealed during the analysis that all the
reported 10 accounts of Mr. AB and his company were opened during the period of the last
three years. None of the automobile business related transactions were noted in his bank
accounts despite the fact that he had declared himself as an auto leasing dealer in the account
opening documents of the bank. Likewise, an analysis of the bank accounts of Mr. MA revealed
that the accounts were opened during the period of the last year and a half.

Both the individuals lured the public by offering financing at a rate lower than the market rate.
They offered a financing facility for automobile and housing at the rates of four and six percent,
respectively. Moreover, the individuals also clarified on their website that the financing facility
was not available to the media and members of law enforcement agencies.

Moreover, one of the companies run by the aforementioned individuals, was already issued
with sanctions by the Securities & Exchange Commission of Pakistan (SECP) for its
involvement in unlawfully running businesses related to the leasing of vehicles, houses,
electronics etc. However, the reported individuals ultimately managed to continue running the
businesses.

The above financial intelligence was shared with a Law Enforcement Agency whereupon
action was taken against the individuals. The offices of Mr. AB were raided and sealed while
arrests were also made. Further investigations are underway.

5.21 Wire transfers / Use of foreign bank accounts.

Chinese Taipei
Mr. H is a scammer with several criminal conviction records. Ms. L is the owner of a foreign
company (Jurisdiction A) named YK. In 2019, with the intention of executing a fraud scheme
on Ms. L, Mr. H impersonated a member of G Bank Group in Chinese Taipei and a lawyer
practicing in Jurisdiction B, and claimed that he could assist Ms. L to obtain VVIP membership
of G Bank Group, to deal with her family’s contract lawsuit, and to invest together in real
estate. Ms. L was deceived out of more than 4 million USD by the scheme, and transferred the
funds from her personal savings into Mr. H’s designated dummy accounts, including a
company account registered in Jurisdiction B.

APG Typologies Report 2021 64

The Prosecutors’ Office prosecuted Mr. H and his associates for violations of Criminal Code
and Money Laundering Control Acts in August, 2020.

Hong Kong, China

The bank-to-bank messaging system of a bank in Jurisdiction X was attacked and 11
unauthorised transactions totalling HKD 108 million (USD 13,905,561) were made to various
banks around the globe. A total of HKD 52 million (USD 6,695,234) was credited to bank
accounts in Hong Kong, China and some of the funds were further dissipated through wire
transfers on the same day. Upon receiving the report, the Hong Kong Police Force swiftly
withheld HKD 27 million (USD 3,476,411) in the beneficiary accounts. A total of 11 account
holders were arrested. Three of them were convicted and sentenced to imprisonment for 26 to
30 months. Two defendants have absconded and are yet to be located.

Singapore
In 2018, the Commercial Affairs Department (CAD) of Singapore Police Force received
information from authorities in Jurisdiction X that several bank accounts in Singapore were
used by Person R from Jurisdiction N to launder proceeds of crime.
Person R was the Chief Executive Officer of a company based in Jurisdiction N, which
allegedly produced and sold encrypted hand-held devices designed to provide a secure means
to communicate openly about criminal activity without fear of detection by law enforcement.
Pursuant to investigations conducted by Jurisdiction X authorities, Person R eventually pleaded
guilty to offences involving conspiracy to commit racketeering acts and to distribute cocaine.
As part of his guilty plea, Person R agreed for a sum of his assets to be forfeited, including
money that was held in bank accounts in Singapore.
Acting expediently on information provided by foreign authorities, CAD commenced a
domestic money laundering investigation and in the process seized over SGD 5 million (USD
3,759,238) of proceeds held in the bank accounts of Company C, a Singapore-registered
company for which Person R was a director and sole shareholder. Upon the conclusion of
investigations, CAD worked with the Attorney-General’s Chambers to invoke our judicial
process to lift the seizure and successfully repatriated the seized assets of USD 3,971,468.40
to Jurisdiction X authorities in 2020.
Additionally, the corporate service provider which had assisted in incorporating Company C
may have committed offences under the Companies Act, including the failure to exercise
reasonable due diligence as a director of Company C. Court proceedings are in progress.

5.22 Use of false identification.

Brunei Darussalam
On 9 March 2020, a victim filed a police report stating that BND 67,800 (USD 50,943) had
been transferred out of her joint account with her husband and suspected a third party (their
daughter) to be involved in the theft. The Royal Brunei Police Force (RBPF) initiated the
predicate offence investigation and arrested Person A and Person B.
Investigations revealed that Person A, the daughter of the victim, with the help of her cousin
Person B used deceitful means to transfer the funds from the victims’ account to Person A’s

APG Typologies Report 2021 65

account. They gained access to the victim’s account and, using the bank’s online banking
application, proceeded to conduct the transfers.
As part of RBPF’s investigations, the police seized a large number of items which they had
believed were bought using the proceeds of her theft. This included monies amounting to BND
8,200 (USD 6,160) and IDR 16 million (USD 1,118). Both Person A and Person B used the
money for their own personal expenses as well as luxury trips to overseas.
On submission of the investigation papers from the RBPF, the Attorney General’s Chambers
(AGC) advised to carry out the further investigations on Person A to obtain the relevant
evidence that could support money laundering charges such as the value of the seized items,
where they were purchased, when they were purchased and whether they were purchased with
the stolen money.
The RBPF was able to obtain sufficient evidence and on 30 April 2020, Person A was
prosecuted and convicted for theft and money laundering offences. She was sentenced to 32
months’ imprisonment, however, this was increased to 40 months after a successful appeal
made by the public prosecutors. Person B was sentenced to eight months’ imprisonment.

Hong Kong, China

In a property fraud case in Hong Kong, China, Mr. X used a forged identity card and appointed
a property agent and legal representatives to sell a property on behalf of the property owner.
Mr. Y changed his name officially to that of the house owner and opened a bank account. A
buyer paid about HKD 3M (USD 386,272) as deposits to Mr. Y who later withdrew all the
money in cash and changed back to his original name. The case surfaced when the genuine
property owner received a letter from a law firm informing of the change of ownership. Mr. Y
was convicted of ‘Using a False Document’, ‘Money Laundering’ and sentenced to
imprisonment for 48 months while Mr. X was convicted of ‘Fraud’ and ‘Conspiracy to
Defraud’ and was sentenced to imprisonment for 42 months.

Indonesia
There were 52 debtors related to indications of fraud committed by CRR as Branch Manager
(BM) with Branch Officers (Credit Officers) at Bank X. CRR committed fraud by borrowing
debtor identity data to apply for a loan, including fictitious businesses as one of the
requirements possessed by the debtor, falsification of the debtor's identity documents,
engineering the sale and purchase of collateral assets for loan applications from banks and
mark-up on the results of business income and the value of the debtor's collateral, so that the
loan can be approved. Then, CRR gave an amount of money to the party whose identity was
borrowed from IDR 2.5 million (USD 175) to IDR 5 million (USD 351) as a fee for using that
party's identity to apply for a credit loan to Bank X.
CRR received money from banking crimes amounting to IDR 931,300,000 (USD 65,511). The
money laundering was carried out through the purchase of assets in the form of land using
someone else's identity.
For this act, CRR was sentenced to imprisonment for eight years and a fine of IDR 200 million
(USD 14,075).

New Zealand
Organised Crime Group engaged in bank loan fraud

APG Typologies Report 2021 66

A group of NZ citizens defrauded several NZ banks by taking out bank loans, changing their
names by deed-poll to avoid authorities and then defaulting on the loan repayments. The
activity was aided by use of a NZ construction company which provided payslips and fake
wage payments in support of the loan applications. Financial intelligence identified a number
of individuals receiving payments from the NZ company labelled ‘wages’. The individuals
used these statements as part of a wider suite of documents (wage statements, payslips,
employment agreements) from the company, to obtain loans from several NZ banks. It is
estimated the group obtained several-hundred thousand dollars’ worth of loans from multiple
banks. Once they had obtained the loans, the offenders legally changed their names, enabling
them to better-avoid follow up inquiries by the bank and law enforcement. Fraudulently
obtained funds were largely withdrawn as cash or funnelled through a network of third-party
accounts.

5.23 Association with corruption/bribery

Bangladesh
Laundering of Illegally Earned Money to Several Jurisdictions by a Government Official

Mr. ‘A’ is a government official and his wife Mrs. ‘R’ is the proprietor of a business entity
named ‘Company A, a contracting firm supplying surgical equipment to government hospitals
and institutions. More than BDT 5202.2 million (USD 61,286,951) was transacted in the bank
accounts of Mr. ‘A’, his wife Mrs. ‘R’, and their concerned entities. About BDT 4300 million
(USD 50,657,108) was transacted in the bank accounts of Company A of which BDT 1020
million (USD 12,016,424) was deposited in this account for the purpose of bidding for a
government tender (as per declaration in the deposit slips).
Money was transferred from the bank accounts of Company A to the account of another entity
named Company B whose proprietor’s name was published in the Panama Papers.
Furthermore, a substantial amount of money was transferred to several accounts from this
account very frequently. Analysis revealed that Mr. ‘A’ was the ultimate controller and
beneficiary of his wife’s company, Company A. Open source information revealed that he used
to prepare fake papers of supplying goods and controlled government tenders in favour of his
wife’s company and even managed to obtain a tender without minimum capital/security money.
In addition, Bangladesh Financial Intelligence Unit (BFIU) obtained information of accounts
being maintained by Mr. A and his wife in four foreign jurisdictions, namely jurisdiction Wx,
Xy, Yz and Zx. There was information of numerous cash transaction reports, large transaction
reports and electronic fund transfer reports amounting to a total of USD 13.45 million against
the accounts of Mr. ‘A’ and his wife in those jurisdictions. Furthermore, in one of those
jurisdictions, suspicious transactions made between December 2014 and June 2020, were
reported. Additionally, a business entity in a foreign jurisdiction in the name of Mr. ‘A’ was
detected even though a Bangladeshi cannot invest in a foreign jurisdiction without approval
from the appropriate authority.
After the analysis, it appeared that Mr. ‘A’ with the assistance of his wife amassed a
considerable amount of illegitimate wealth and had tried to conceal his illegally earned money
by establishing a contracting company in his wife’s name and ultimately funnelled the amount
to foreign jurisdictions through illegal channels. Based on the findings BFIU prepared an
intelligence report and disseminated the same to the Anti Corruption Commission for further
investigation and necessary legal actions as per the Money Laundering Prevention Act (MLPA)
2012.
APG Typologies Report 2021 67
Fiji
Corruption, bribery, kickback and unexplained wealth
Person R, employed by a local statutory body, was brought to the attention of Fiji FIU for a
possible case of bribery, corruption and unexplained wealth. Analysis revealed that Person R
received deposits totalling approximately $28,804 (USD 14,107) into his bank account
between July 2018 and September 2020 from various individuals in Jurisdiction V and Fiji. It
was also noted that Person R, his unemployed spouse (Person Y), and their children frequently
travelled to jurisdiction V. In August 2019, Person R acquired a taxi permit, however, there
was no corresponding transaction showing that Person R had paid for the taxi permit. Person
R and Y collectively own four high value vehicles that were purchased without any financing.
Further analysis revealed that Person R acquired a freehold property in the central division and
has made significant improvements to the property in the last few years. Further analysis
revealed that patterns in Person R’s transactions and accumulation of wealth were not
consistent with the annual income declared. It was also established that person R and his family
frequently travelled abroad, however, funding for tickets and travel expenses could not be
traced to credit card or bank account transactions. A case dissemination report was provided to
the Fiji Independent Commission Against Corruption (FICAC) to examine the case for possible
unexplained wealth as a result of corruption and bribery.

Indonesia
Case one:
Mr. ZAI is a Regent of the South Lampung region for the period 2016-2021. From 2016 to
2018, Mr. ZAI through Mr. AGU (Head of Sub Division of Finance at PUPR (Ministry of
Construction and Housing) Office from 2015 to January 2017) and Mr. ANJ (Head of the
PUPR South Lampung Office from December 2017 to July 2018) received money (termed
‘commitment fees’) for the allocation of infrastructure work.

APG Typologies Report 2021 68

Mr. ZAI with Mr. AGU, Mr. ANJ, Mr. HER and Mr. SYA received cash in stages from 2016
to 2018 amounting to a total of IDR 72,742,792,145 (USD 5,116,854) from entities who were
awarded projects by the PUPR Office.
Under the commitment fee arrangement, Mr. HER formed a team coordinated by Mr. SYA.
Mr. HER then provided a list of jobs to Mr. SYA and ordered Mr. SYA to collect commitment
fee money from entities that were to be awarded the jobs (infrastructure work) according to
project plotting. The commitment fee was then submitted to Mr. AGU. The task of the team
coordinated by Mr. SYA was to prepare bid documents for the companies that paid the
commitment fee and upload them into the Electronic Procurement Service (LPSE) system. The
commitment fee could amount to approximately 21% of the project value.
Case two:
Mr. SLM, Mr. BS and Mr. AN are civil servants in a government agency. Mr. SLM is the Head
in charge of expenditure with regard to the Supply Fund (SF) and Additional Supply Fund
(ASF). However, it was discovered that the SF and ASF were not entirely used to finance
operational, non-operational, supplies, services, and maintenance expenditures in accordance
with the agency's activity plan that has been determined, but were also used for the personal
interests of Mr. SLM, Mr. BS, Mr. AN, and other parties. Funds that were used contrary to
normal expenditure guidelines amounted to IDR 5,018,121,329 (USD 347,816). The funds
used for the personal interests of Mr. SLM, Mr. BS and other parties amounted to IDR
4,685,971,329 (USD 327,794), while the remaining IDR 332,150,000 (USD 23,022) was
controlled by Mr. AN. The funds that had been received by these parties were then divided
between several of the defendants' associates.
Case three:
a. On two instances, Mr. NZ placed or transferred the proceeds from corruption in procurement
activity using the accounts of companies part of the PMI Group and accounts in the names of
others amounting to IDR 70.018 billion (USD 4,903,635) and SGD 1,034 (USD 774 - around
IDR 9.3 million); ownership is transferred in the form of shares of a company under the control
of the PMI Group, namely ETU co. and PNH co. is worth IDR 50,425 billion (USD 3,529,984).
b. Furthermore Mr. NZ transferred ownership of land and buildings worth IDR 18.447 billion
(USD 1,291,476); to spend or pay for the purchase of land and buildings IDR 111,117 billion
(USD 7,779,327); to spend or pay for the purchase of motorised vehicles amounting to IDR
1.007 billion (USD 70,500); spent or paid for an insurance policy of IDR 2.092 billion (USD
146,525).
c. Mr. NZ spends or pays for the purchase of shares which are then resold using companies that
are members of the PMI Group or the names of other people on the Indonesia Stock Exchange,
namely shares of GRD co., shares of Bank MDR, shares of Bank ABC, shares of GG co., shares
of KS co., shares of JAW co., shares of BCE co. (using the name of Mr. NZ's wife), shares of
PRW co., shares of CA co., shares of DMK co., shares of ETU co. and shares of PPM co..
Besides that, Mr. NZ bought bonds worth a total of IDR 374,747 billion (USD 26,211,738).
Thus Mr. NZ’s total assets in the capital market is IDR 627.86 billion (USD 43,915,767).
d. To hide or disguise the origin of the proceeds of the crime, the proceeds from the sale of
shares of GRD co. was transferred by Mr. NZ through the PMI Group Finance Director, which
was done by transferring money from the Jurisdiction X Dollar Giro account at SCT Bank33 on
behalf of PPM co. amounting to around 6 million Jurisdiction X dollars (USD 4,494,743) to
Mr. LKS's account as if it were for payment for the purchase of a Tug Boat in Jurisdiction X.
Furthermore, this occurred through Mr. GL’s instructions as the President Director of a

33
A type of securities account intended for foreign companies that open securities accounts in Indonesia.
APG Typologies Report 2021 69
recruitment agency named PT. TCL in Jurisdiction X to cross the shares of PT. GRD in the
negotiation market of four companies, namely PT. PRW, PT. CA, PT. MK and PT. ETU to PT.
TCL for the amount of IDR 163 billion (USD 11,414,212).
e. In addition, there are also transactions where the sale of shares of BCE co. was transferred
by Mr. NZ’s wife to the account of a company called WII, Pte Ltd. in Jurisdiction X for an
amount of IDR 26 billion (USD 1,820,517).

New Zealand
Proceeds of offshore corruption scheme laundered via NZ property market
NZFIU received three Suspicious Activity Reports (SARs) regarding a NZ-registered company
(Company A). The SARs related to the sale of a property in Auckland for NZD 23 million
(USD 16,663,730) owned by Company A, to an undisclosed owner. The SARs identified that
the beneficial owner of Company A was an overseas jurisdiction government official (Person
A), who was subject to investigation by another jurisdiction’s anti-corruption agency due to
alleged corruption involving the other jurisdiction’s natural resources, and had been subject to
‘numerous’ corruption allegations since the 1980s. As part of the SARs the reporting entity
supplied beneficial ownership information for Company A which showed Person A to be the
settlor of a trust (based in an EU jurisdiction) which owned 60% of Company A, which in turn
was the sole owner of the NZ property valued at NZD 23 million (USD 16,663,730). This
information also showed Person A to be the protector of a second (offshore-based) trust which
owned a 20% share of Company A – effectively giving him an 80% ownership share of the
company.
Proceeds of abuse of official position in offshore jurisdiction laundered through NZ bank
accounts
NZFIU received a SAR regarding a New Zealand citizen living in overseas jurisdiction A who
had come to the attention of the reporting entity via open source information alleging he had
abused his position as a public official in Jurisdiction A for personal gain. The allegations
included clocking up expenses and time off for which he was not entitled, and using his
influence to obtain preferential treatment for key staff members. The suspect had previously
been interviewed by jurisdiction A’s anti-corruption agency and inquiries were ongoing.
SAR reporting on the suspect showed he received more than NZD 200,000 (USD 144,823)
credited to his NZ accounts from his bank accounts in Jurisdiction A. These funds were then
forwarded to third party accounts within NZ and also used to fund personal expenses
Proceeds of overseas bribery scheme laundered via NZ foreign trust structure
NZFIU received a spontaneous dissemination from an overseas partner regarding a foreign
national (Subject X) who was subject to an international investigation regarding a ‘notebook
of bribes’ where a group of overseas businessmen located in Jurisdiction A were accused of
paying bribes to keep public works contracts administered by a government body in jurisdiction
A. The partner FIU indicated that Subject X was the settlor and beneficiary of a trust (Trust Z)
which was transferred to a New Zealand company (Company Z) in 2016, which held assets
totalling USD 8.6 million in an offshore bank account.
Inquiries conducted by NZFIU identified Trust Z was indeed transferred to NZ in 2016, being
set up as a NZ foreign trust with Company Z as the trustee. Company Z was associated with a
group of companies which provide trust and company services in New Zealand and
internationally, which had previously come to the attention of NZFIU for suspected

APG Typologies Report 2021 70

involvement in complex international money laundering schemes. The shareholder of
Company Z was another overseas based company.
NZFIU inquiries revealed Trust Z did not hold banking facilities in New Zealand, but multiple
payments referencing the name of Trust Z were credited into the NZ account of Company Z,
which NZFIU assessed were likely payments for administration of the structures by the NZ
TCSP and a portion of which was likely earmarked for forwarding to overseas bank accounts
owned / controlled by Subject X.

Pakistan
Corruption & Bribery

The transactional activity in the account of Mrs. AA was suspicious as high value funds were
transacted from the account which apparently were not consistent with her profile as a
housewife. Furthermore, the source of funds and the true beneficiary of the funds was also
unclear.

During the analysis, it was found that Mrs. AA was maintaining multiple PKR and foreign
currency accounts at different banks where a high volume of transactional activity was noted.
Furthermore, Mrs. AA received substantial funds in her local currency account from her
father’s account purportedly as a gift. The amount of the gift was then transferred to her own
account maintained with another Bank, but the mandate to operate this account was held by
her husband, Mr. AK. Afterwards, these funds were withdrawn through cash and clearing of
cheques. As per KYC documents, Mr. AK was a high-level government official.

Through Computerised National Identity Card (CNIC) searches in FMU’s database, it was
found that Mr. AK and Mrs. AA conducted currency exchange transactions and remitted a
considerable amount of funds abroad.

Suspecting Mr. AK as the ultimate beneficiary of the funds, the financial Intelligence was
shared with an LEA on suspicion of corruption and bribery.

Singapore
In 2019, the Corrupt Practices Investigation Bureau of Singapore (CPIB) conducted
investigations against a former senior management executive of a sports association for
cheating offences, relating to the wrongful award of contracts due to concealment of interest
with related vendors. Investigations revealed that between 2016 to 2018, the total proceeds of
cheating amounted to SGD 647,180 (approximately USD 487,766). The said former Deputy
Director and three other co-accused persons were prosecuted for cheating offences under the
Penal Code, Chapter 224 on 9 December 2020. CPIB commenced parallel financial
investigations to trace the illicit proceeds. Investigations revealed that the funds were
channelled to two companies which the former deputy director had an interest in, by means of
contracts awarded to the two companies. A substantial portion of the criminal proceeds were
subsequently withdrawn from the companies’ accounts and deposited into the former deputy
director’s wife’s personal bank account. The illicit proceeds were co-mingled with her personal
funds. In July 2017, she withdrew about SGD 573,000 (approximately USD 431,778) to
finance the down-payment of a private property. In view of the findings, CPIB lodged a caveat
against the property. CPIB also seized about SGD 156,000 (approximately USD 117,552) of

APG Typologies Report 2021 71

cash in possession of the former deputy director and his wife. Investigations are currently
ongoing.

5.24 Abuse of non-profit organisations (NPOs).

Singapore

Three individuals, Persons A, B and C were convicted in February and March 2020 under the
Terrorism (Suppression of Financing) Act for collecting and/or providing funds to benefit a
terror group in jurisdiction J with ties to ISIL, Entity X, and were sentenced to imprisonment
terms ranging from 18 months to 45 months.
These three individuals worked as foreign domestic workers (“FDWs”) in Singapore. Between
September 2018 and July 2019, they had collected and/or remitted monies amounting to SGD
1486 (approximately USD 1118) to two purported religious charities in the belief that these
funds would be used to support militant causes of Entity X and the families of its members who
had been detained or killed. All the monies were raised through self-funding, and sent to
persons in jurisdiction I through the same licensed remittance agent. Accordingly, the trio had
reasonable grounds to believe that the funds collected and remitted would be used to facilitate
terrorist acts overseas, resulting in the terrorism financing charges against them.

APG Typologies Report 2021 72

6. PROLIFERATION FINANCING METHODS & TRENDS

6.1 Case studies of breaches, non-implementation or evasion of targeted

financial sanctions related to proliferation financing.

Chinese Taipei
Law enforcement (MJIB) searched the residence and company of Mr W after an investigation
in October 2018, known as the ‘Vessel S case’, which involved an illicit ship to ship transfer
with DPRK. The MJIB analysed the evidence from the Vessel S case and found that Mr W
established an offshore company to purchase petroleum from a Jurisdiction X company, known
as Company S, which was then stored in an oil tank located at the Taichung Port. In May 2018,
Mr W proceeded to charter a vessel, known as Vessel G, to carry 1,350 metric tonnes of
petroleum from the Taichung Port to the high sea where it conducted a ship to ship transfer
with Vessel S. Vessel S then moved to a different location and conducted a ship to ship transfer
with DPRK Vessel P, which was designated by the UN Sanctions List and Chinese Taipei. Mr
W also used Vessel G to conduct a further petroleum ship to ship transfer with DPRK Vessel
A. Mr W then sold Vessel G to DPRK which violated Chinese Taipei law as well as the UNSCR
1718. Investigations by MJIB found that Mr W provided financial resources to designated
targets on the UN Sanctions List, which violated Article 9, Paragraph 1 and Subparagraph 1 of
the Counter-Terrorism Financing Act 2018 (CFTA). This case was referred to the District
Prosecutors Office in November 2020 for prosecution.

Malaysia
Between 2012 and 2017, two Malaysian private limited companies were identified to be fronts
for a DPRK-linked company dealing with radio communications equipment for military and
paramilitary organisations. Upon review of the companies’ bank accounts in local financial
institutions, it appeared that the front companies had received a total of 50 international
transfers amounting to RM 7.5 million (USD 1,819,806) from various foreign entities, which
included later designated entities under the UNSC, entities under Panel of Experts
investigations and other companies which appear suspicious or inconsistent with the business
activity of the sending party. Upon receipt, the funds were then immediately transferred to
several other entities, which have since been alleged by the Panel of Experts to be serving as
front companies for UNSC-sanctioned persons.
It was observed that these companies frequently moved money between their accounts to avoid
detection, before transferring to foreign front companies and subsequent transfers to the final
recipient in Pyongyang.

New Zealand
A New Zealand charitable society which was established to promote relations between New
Zealand and DPRK was implicated in a possible breach of UN sanctions in relation to a NZD
2,000 (USD 1,440) donation it made to the Red Cross Society of DPRK. Due to the UN
sanctions in place, the New Zealand society was unable to send funds directly to DPRK, so it
instead sent the funds to a contact in Jurisdiction X who then passed the funds on in cash to the

APG Typologies Report 2021 73

DPRK Embassy. Authorities identified concerns that the activity may have been in breach of
the UN sanctions against DPRK.

Philippines
Case one:
In May 2020, the AMLC was approached by the Panel of Experts, through a letter from the
Department of Home Affairs, for assistance in relation to the Panel’s investigation involving
Vessel A and Subject X, who is a Filipino national.
On 24 April 2019, Entity B was registered in the Jurisdiction X and Subject X became Entity
B’s director, shareholder and beneficial owner. In June 2019, Vessel A was sold and its name
was changed to Vessel B and ownership of the vessel was changed to Entity C. In August 2019,
Vessel B travelled from Jurisdiction Y to DPRK and returned to Jurisdiction Y in November
2019 carrying coal originating from DPRK.
Investigations into Subject X found that the date of birth and address provided by the Panel of
Experts matched the information provided by Subject X in her KYC documents. It was also
discovered that Subject X had made 103 large transactions between the period of July 2005
and February 2020 in amounts ranging from PHP 400,000 (USD 8,000) to PHP 4,000,000
(USD 80,000). There were also 10 confidential reports covering the same period on a joint
bank account of Subject X and her husband, Subject Y, which stated that the transactions made
in the joint account appear to have no underlying legal or trade obligation, purpose or economic
justification. It was also noted that there was a high volume of cash deposits and cheque
clearing transactions during the same period as the purchase of Vessel A and the registration
of Entity B. Subject X was asked to provide information regarding the source of the funds,
however she gave inconsistent and conflicting responses such as the money was from
businesses and/or an allowance from her husband. Further investigations found that no
businesses were registered with the Department of Trade and Industry and Subject X was
unable to provide information about the businesses or how they were able to generate the funds
in the account.
Investigations into Subject Y, Subject X’s spouse, found that Subject Y owned a garments
business, Entity D, in Manila. Subject Y had also made 49 large transactions from the period
July 2009 to December 2015 in amounts ranging from PHP 400,000 (USD 8,000) to PHP
4,000,000 (USD 80,000) and the bulk of the transactions are in joint bank accounts with Subject
X. Investigations are ongoing.
Case two:
An investigation conducted by the Panel of Experts concerned a case of a suspected sanctions
violation involving a Jurisdiction Z-flagged vessel, Vessel C, and the delivery of refined
petroleum products to DPRK in April 2020. The International Maritime Organisation’s website
lists an overseas company, Company YYY, as Vessel C’s registered owner, ship manager and
operator since November 2019. Information obtained from the Panel of Experts and publically
available sources showed that the director of Company YYY was Mr G, a Filipino national.
Investigations into Mr G found that he had made 130 transactions from November 2005 to
April 2019. Mr. G also made cash deposits totalling PHP 254.36 million (USD 5.32 million),
which did not appear to be in proportion to his business earnings. Moreover, he also had an
APG Typologies Report 2021 74
aggregate debit of PHP 223.77 million (USD 4,578,228) which approximates the aggregate
cash deposit.
The delivery of refined petroleum products to DPRK occurred in 2020, however, there was no
transaction report on behalf of Mr G during this time. It may be that the transaction did not
pass the financial system or smaller transactions were made below the reporting threshold. It
was also discovered by the Securities and Exchange Commission (SEC) that Company YYY
was not a registered corporation and did not appear on the SEC database, however, the SEC
did find that Mr G was associated with several other corporations. The Department of Trade
and Industry certified that there was no existing business registration under the name of Mr G.
An investigation is still ongoing.

Singapore
In September 2020, Person C was convicted of assisting Company S, C and D which were
registered under Person C’s control, to supply designated luxury items worth in excess of
SGD 500,000 (USD 676,769) to DPRK on 40 separate occasions between December 2010 and
November 2016. Investigations revealed that Person C had registered various companies since
the 1980s in order to conduct trade with the DPRK for profit. Company S, C and D had supplied
goods to four different entities in DPRK, one of which had grown into a distributor and
wholesaler supplying various goods to other shops in DPRK.
In 2010, regulations were enacted under the United Nations Act prohibiting the supply of
designated luxury goods to DPRK, however Person C did not cease their trading activities with
DPRK despite being aware of the risks of trading with DPRK and actively took measures to
avoid detection by the authorities. Person C would supply the luxury goods to DPRK by
transporting them by air and sea shipments through a neighbouring jurisdiction or by hand via
airport check in. Payments by DPRK for the luxury goods were made to Company S, C and
D’s bank accounts through front companies which were incorporated overseas. Investigations
also revealed that Person C ran a low-key operation to avoid detection, by not displaying the
names of the companies on the floor guides or outside the unit of their registered address, which
was the same for all three companies.
Person C was sentenced to three weeks’ imprisonment and company S, C and D were also fined
a total of SGD 130,000 (USD 97,966). These sentences are pending appeal before the High
Court, including an appeal by the prosecutor for a harsher sentence.

APG Typologies Report 2021 75

7. MONEY LAUNDERING & TERRORISM FINANCING TRENDS
This section of the report provides a brief overview of trends in ML and TF including open
source information on research conducted by APG members and observers.

7.1 Recent research or studies on ML/TF methods and trends.

Australia
ML/TF Risk Assessment: Junket Tour Operations in Australia
AUSTRAC published its risk assessment of junket tour operations in December 202034. This
assessment was developed as part of a targeted programme of work, focusing on Australia’s
largest financial services sectors – namely, the banking, remittance and gambling sectors.
AUSTRAC assessed the overall ML and TF risk associated with junket tour operations in
Australia to be high.

Fintel Alliance Trade-Based Money Laundering Working Group

In early 2020, Australia’s public private partnership, Fintel Alliance, established a dedicated
TBML working group aimed at building resilience, sharing knowledge, and developing
coherent strategies to combat and disrupt TBML in Australia. The working group, which meets
on a monthly basis, comprises subject matter experts from government, law enforcement, and
financial industry partners. One of the objectives of the working group is to identify and
document how financial facilities and products are exploited for TBML purposes. The working
group also aims to consider and review the adequacy of the controls to mitigate TBML. The
working group will cultivate domestic and international partnerships, and develop typologies
and indicators to establish best practices that enable an enhanced and collaborative response to
combating TBML. In the short period of time since its establishment, the working group has
launched a number of initiatives, including:
 The development of a TBML indicators paper comprising feedback from public and
private partners.
 The establishment of an information-sharing framework for public and private
collaboration under the guidance of the Australian Border Force, for the purposes of
identifying and reporting suspicious activities in selected high-risk industry sectors.
The creation and delivery of a dedicated training programme on trade financing by a
financial institution.

Brunei Darussalam
Brunei Darussalam sees a continuing trend of activity that alludes to possible money lending
without a license, an offence under Section 8 of the Moneylenders Act Cap.62 and ML, an
offence under Section 3 of the Criminal Asset Recovery Order, 2012.
On 7 December 2020, the FIU issued a typology to all FIs and DNFBPs, described as follows:
Modus Operandi:

34
https://www.austrac.gov.au/sites/default/files/2020-12/JTO_2020_FINAL.pdf

APG Typologies Report 2021 76

 a. Person X (moneylender) searches and identifies potential customers using social media,
particularly Facebook. Person X may prey on other persons who have a need to purchase
assets through obtaining a loan but are not able to, due to exceeding their Total Debt Service
Ratio (TDSR) limit,
b. Person Y (customer) seeks Person X’s help to settle their debt in order to obtain a larger
financing or loan amount for any unspecific personal purposes.
c. Person X provides Person Y with the money needed to settle their debt with the
condition that Person Y obtain a new loan of an amount sufficient to repay Person X with
commission fee (read: interest payment).
d. Person X may give the money to Person Y in the form of cash or electronic funds
transfer.
e. Person X may use another third party to perform the electronic funds transfer on their
behalf.
f. Person Y uses the funds to settle their loan in full.
g. Soon after that, Person Y applies for a new loan of an amount larger than previously
settled. The difference in amount includes the ‘commission’ to be paid to Person X.
Red Flag Indicators to look out for:
a. A customer that applied for a loan, but was rejected due to exceeding their TDSR limit.
This includes any attempts (i.e. consultations with any bank/finance company staff).
b. A customer whose previous attempt to obtain a loan was rejected, but is suddenly able
to complete an early settlement of their existing loan(s).
c. A customer that applies for a new loan soon after an early settlement of a previous loan.
d. Early settlement of a loan for an amount that may not be possible with that customer’s
level of income.
e. Early settlement of a loan using funds from unknown sources or sources that the
customer is not able to justify or where the justification provided does not make sense.
f. A customer receiving large amounts in their personal accounts from persons seemingly
unrelated.
g. A customer receiving large amounts in their personal accounts and then immediately
using it to settle their loan(s).

Indonesia
The Preliminary Report Document of Indonesia's Risk Assessment on Money Laundering in
2020, includes the following findings:
 Predicate crimes with high ML risk include corruption and narcotics. Furthermore,
predicates with medium risk are banking, environmental, forestry, fraud and taxation
crimes.

APG Typologies Report 2021 77

  The industrial sector reporting entities at high risk of involvement in ML are motor
vehicle companies and property companies/property agents.
 Legal entities have a high ML risk, while business entities that have high ML risk are
limited liability companies (PT) and government agencies such as ministries.
 Individual job profiles that have a high ML risk are legislative and government officials
and employees of state-owned or regional government-owned enterprises (including
retirees).
 A risk assessment was conducted based on typologies that have a high level of risk,
including the use of false identities, transfer to property assets and the use of nominees
or loan names, smurfing, structuring, use of professional services, use of new payment
methods/systems, use of corporations (legal persons) and utilisation of sectors which
are not well regulated.

The Preliminary Report on Indonesia's Risk Assessment on TF and PF of WMD in 2020,

includes the following:
a. Terrorism Financing Methods
 At the fundraising stage: personal sponsors (terrorist financiers/fundraisers), the
collection of donations through mass organisations and legitimate business
ventures.
 During the fund transfer stage: through a financial service provider, carrying cash
across borders, and using a new payment methods.
 During the use of funds: manufacturing of weapons and explosives, travel of foreign
terrorist fighters, and the use of weapons and explosives.

b. High-risk profile of TF perpetrators

The profiles of high risk perpetrators of TF are: entrepreneurs/small and medium business
owners, private employees, and traders.

The 2020 Research Report from the Indonesian Financial Transaction Reports and Analysis
Centre (PPATK), compiling ML court decisions from 2019, identifies:
 50 ML court decisions and 50 convictions.
 Five convictions linked to reports by DNFBPs (goods and services providers (GSPs)),
accounting for 10% of the convictions.
 The convictions were related to 8 GSPs reports in relation to the purchase of property.

Macao, China
Common ML methods detected from STRs received are as follows:
• Irregular large cash withdrawals;
• Significant cash deposits with non-verifiable source of funds;
• Use of ATM, phone banking, cash deposit machines;

APG Typologies Report 2021 78

 • Currency exchange/cash conversion;
• Chips conversion without/with minimal gambling activities;
• Foreign exchange transactions with unidentified source of funds;
• Suspected to be engaged in illegal financial activities;
• Use of cheques/account transfer etc. to transfer funds;
• Suspicious wire transfers.

Malaysia
The Malaysian FIU issued a report on Red Flags and Typologies for Tax Evasion in 2020. This
report was issued with restricted circulation to reporting institutions (RIs), with the aim to:
 Provide insights and create awareness on tax evasion including its trends, techniques,
methods and channels;
 Enhance and facilitate RIs’ knowledge and understanding on tax evasion typologies;
 Assist RIs in identification of tax evasion offences from red flags/indicators exhibited
by their customers and financial transactions involved;
 Enable early detection by RIs in order to disrupt activities related to tax evasion; and
 Further improve the quality of STRs.

Philippines
From the 2021 Money Service Business ML/TF Sector Risk Assessment
The money service business (MSB) sector has been a target of criminals to move and, at times,
facilitate proceeds of criminal activities. In the Philippines’ Second NRA, the MSB sector was
rated high in relation to the threat to ML/TF, particularly citing the involvement of 17
remittance companies and foreign exchange dealers in drug trafficking and illegal sex trade.
One of the biggest bank heist cases in 2016 also affected the sector. In the case, three remittance
companies and foreign exchange dealers facilitated the transfer of PHP 3.8 billion (USD
75,721,308) from fictitious bank accounts to casinos, junket operators, and unidentified
individuals.
Measures include amendments in the BSP manual of regulations and the extensive registration
process, which resulted in a significant restructure and consolidation of the sector. While the
MSB sector’s level of understanding of ML/TF risks and AML/CTF obligations is developing,
the newly structured MSB sector is seen to provide a strong framework for AML/CTF
compliance.
To monitor and identify emerging risks associated with the sector, the AMLC, with the
assistance of a foreign FIU and support of the BSP, undertook a risk assessment, using data
from transaction reports, responses from the BSP, and survey results from relevant industries
and other Philippine government agencies. This risk assessment shall serve as guidance for
supervising agencies, FIs, and LEAs as regards policy issuances and risk-based strategies.
APG Typologies Report 2021 79
In the analysis of transactions and investigations of cases, certain services or products catered
by MSBs are being used by criminals for their illegal activities. Remittance services and cash
transactions, including money changing facilities, were the primary means of moving illegal
proceeds.
From the STRs filed by MSBs from 2017 to 2020, child exploitation, child pornography,
trafficking in persons, swindling/fraud, Securities Regulations Code violations rank among the
most number of suspicious transactions reported.
In relation to ML Cases, in 2020 alone, the AMLC caused the filing of petitions for freeze order
on seven cases predicated on illegal drugs (4 cases), violations of the Electronic Commerce Act
of 2000 (1 case), violations of Customs Modernization and Tariff Act (1 case), and violations
of the Securities Regulation Code (1 case). Sixteen (16) MSBs were identified in the said 10
cases. Twelve (12) of the 16 MSBs were impleaded as parties in the said cases. Three (3) MSBs
were also involved in at least two cases. The value of proceeds from the ML cases amounted
to PHP 258.69 million (USD 5.2 million).
Terrorism Financing
Anecdotal intelligence and reports have previously identified MSBs for terrorism and TF. From
2017 to 2020, MSBs reported 2,007 STRs with an estimated STR value of PHP 20 million
(USD 400 thousand). There is also an increase in MSBs’ suspicious transaction reporting on
terrorism and TF with over 350% growth in 2020 compared with 2019.
The common range of TF-related funds is between PHP 500 and PHP 5,000 (below USD 100).
In the AMLC terrorism and TF risk assessment study,35 over 6,000 STRs were reported by
stand-alone MSBs, electronic-money issuers, and pawnshops that are possibly related to
terrorism and TF from 2018 to 2020.
Domestic locations of beneficiaries of terrorism- and TF-related STRs involving international
remittance, include Basilan, Zamboanga, Metro Manila, and Sulu.
The extent of threat and emerging risks, inherent risk and availability of mitigating controls
show that MSBs are used extensively by criminals to move illicit funds, and warrant an overall
medium high ML/TF threat rating for the sector.
While there were alleged and anecdotal intelligence reports on the use of crypto currency, local
or domestic terrorist groups still primarily use the MSBs, and in some cases, communist
terrorist groups use the banking system to move and facilitate TF-related funds.
Possible terrorism financing (TF) activities linked to the use of cryptocurrency
From the 2021 Terrorism and Terrorism Financing Risk Assessment (T/TF RA) conducted by
the Anti-Money Laundering Council (AMLC)
A report36 in May 2020 stated that the Philippine Institute for Peace, Violence and Terrorism
Research noted that Islamic State-linked terror groups conducted their first transactions using
cryptocurrencies in the Philippines, which were then allegedly used to finance the activities of
terror networks operating in Mindanao like the Jemaah Ansharut Dalauh and the Mujahideen
Eastern Timur37.

35
http://www.amlc.gov.ph/images/PDFs/2021%20JAN%20TF%20RA%20EXECUTIVE%20SUMMARY%20(
WEBSITE).pdf
36
https://thediplomat.com/2020/06/how-terrorists-use-cryptocurrency-in-southeast-asia/
37
https://cointelegraph.com/news/researchers-in-philippines-track-crypto-use-by-terrorists
APG Typologies Report 2021 80
The report further detailed the use of cryptocurrencies consisting of two phases:
1) Channeling of cryptocurrency of suspicious origin through unidentified exchanges; and
2) Exchange of cryptocurrency into fiat currency and returning the funds to the legal money
cycle.
The report also stated that terror groups in Southeast Asia can trade cryptocurrency outside the
supervision of regulatory institutions. This is seen as a concern due to the loose legal framework
relative to cryptocurrencies. The report specifically cited the Marawi Siege in 2017 wherein
there were unconfirmed reports of private remittances and cash couriers with cryptocurrency
helping to finance the terrorist groups involved in the said siege.
While blockchain analysis techniques have been employed to decrypt and trace transactions,
services to increase encryption of the currencies have also been used to obscure traces of both
the sender and receiver of the transaction. Moreover, blockchain analysis is unable to pinpoint
the users involved in a transaction because individuals registering for a digital wallet could use
pseudonyms or change the wallet’s crypto address to maintain anonymity.
The Philippines, however, has allowed cryptocurrencies to be used as legal tender. The
conversion of cryptocurrency to fiat currency could easily be done via ATMs and other
registered remittance and transfer companies. While the conversion of cryptocurrency to fiat
currency is regulated by Bangko Sentral ng Pilipinas (BSP), authorities may find it difficult to
pinpoint individuals involved in the transaction as the PhilSys, the Philippine Identification
System, has not yet been completely implemented. Taken together, these factors provide
terrorists with enough room to exploit cryptocurrencies for TF purposes. As of 30 November
2020, there are 17 remittance and transfer companies with virtual currency exchange services
registered with the BSP.38
The T/TF RA identified covered persons engaged in digital currency exchange that reported
eight STRs in 2019 and 106 in 2020 with an estimated value of PHP 1.77 million (USD 37,027).
The reported suspicious transactions indicate emerging use of cryptocurrencies.

Singapore
Singapore Terrorism Financing National Risk Assessment (TF NRA)
Singapore updated the Terrorism Financing National Risk Assessment (TF NRA) in 2020.
The TF NRA is the collation of experience and observations from all relevant competent
authorities over the past few years, and includes inputs from the private sector and academia.
It seeks to further deepen the understanding by LEAs, supervisors/regulators and the private
sector of Singapore’s key TF threats and vulnerabilities, so that appropriate prevention and
mitigation measures may be taken.
The TF NRA has found that:
• Singapore continues to be exposed to TF threats posed by terrorist groups, both
regionally and internationally, in particular the propensity for individuals in Singapore to
be radicalised and influenced to carry out TF activities.

38
https://www.bsp.gov.ph/Lists/Directories/Attachments/16/MSB.pdf
APG Typologies Report 2021 81
 • Certain sectors, notably money remittance (or payment service providers carrying out
cross-border money transfer services) and banks, are more inherently vulnerable to TF
threats, given the relative ease of access to their services, coupled with Singapore’s status
as a financial and transport hub and proximity to jurisdictions exposed to terrorism
activities.

7.2 Association of types of ML or TF with particular predicate activities (eg

terrorist organisations, terrorist training, corruption, drugs, fraud,
smuggling, etc).

Bangladesh
Remote Gambling Scenario in Bangladesh
This study was published in the Annual Report of the Bangladesh Financial Intelligence Unit
(BFIU).
BFIU received 20 spontaneous intelligence reports from a foreign FIU. Each report described
the involvement of Bangladeshi nationals in online remote gambling. These 20 Bangladeshi
nationals registered remote gaming accounts with Maltese-registered remote gaming
companies. They deposited and withdrew gaming accounts funds through Neteller, Skrill,
Moneybookers etc. The FIU also informed BFIU that due to the lack of information on source
of funds and high velocity deposits by those individuals, the gaming company had closed their
accounts.
It has been found in the analysis that some of the gamblers provided false identity information
during account opening and hence could not be traced. Every player’s IP address was traced
back to many different jurisdictions of the world. It appears likely that they used Virtual Private
Networks so that their identities could not be traced. Before the accounts were closed, the
players operated their accounts for one to four years. The players mainly placed bets on sports
books and played casino games. The sum of the funds deposited by the 20 players was- USD
39,77,141 and the total withdrawal was USD 27, 09,154. In some cases, it was found that the
gamblers were maintaining bank accounts in Bangladesh. These cases were disseminated to the
Bangladesh Police Criminal Investigation Department (CID) for further inquiry. In several
cases, CID provided feedback that no concrete proof was found against the gamblers.
Gambling is a prohibited activity in Bangladesh. There are also strict legal sanctions against
gambling in the Public Gaming Act of 1867. Despite a ban on gambling, large numbers of
Bangladeshis are using online gambling sites. Still others pay to play games online. These
games have given rise to cybercrime through identity theft and theft of gaming accounts, fraud
and even fronts for ML and TF (since they depend on the user paying to play in the gaming
ecosystem). Therefore, it is important that ML & TF authorities trace how individuals are
investing their money into online gaming and gambling. Legally, online gambling account
cannot be loaded with funds through banking channels. Further, operation of Neteller, Skrill,
Moneybookers, Paysafe or such types of e-wallets (e-money service providers) is not legal in
Bangladesh. On the other hand, gamblers/players have to deposit funds to their gambling
accounts to play. So, they use an alternative channels, hawala/hundi to feed into their accounts
and most of the gamblers use Neteller, Skrill, Moneybookers, Paysafe that operates in multiple
currencies.
APG Typologies Report 2021 82
A person who wants to gamble online sets up an account with Neteller, Skrill or one of the
other companies or gets someone to do it for him or her. Then they get in touch with someone
who has dollars, say a freelancer who works for a foreign client. He pays in local currency to
the freelancer who then asks his client to pay part of his service fees into a Neteller or Skrill
account which belongs to the gambler. This is how a digital/e-money wallet is loaded and used
to make payments for gambling. There are agents/intermediaries who collect money from
different would-be gamblers/gamers (often through Digital Financial Services like Bkash) and
use multiple individuals to funnel money into these e-money accounts. Further, a search on
Facebook found that several websites such as PaymentBD.com advertise loading up Neteller,
Skrill and other similar e-wallet accounts. As per PaymentBD.com, they can load dollars in
Neteller account.
The intelligence reports related to the remote online gambling were received only when the
related accounts were closed. It is easily assumed that there are many more gamblers still
operating. Since funds are siphoned off abroad from Bangladesh through hawala/hundi for this
purpose, initiatives have been taken to communicate with foreign FIUs to collect information
on gamblers who are still operating as well as to work closely with law enforcement agencies
to identity the suspects.

Chinese Taipei
Case one:
Mr. W was the chairman of S Company, and since June 2017, he hired a number of employees
to run a string of online casino websites which included G1, G2 and G3. In order to launder
the gambling funds, Mr. W used a large amount of mule accounts which were opened in
Jurisdiction X from an unknown company nicknamed KT, and layered the money into three
different accounts. The first-layer accounts directly received the gaming funds from gamblers.
When the money in the accounts accumulated to a certain level of funds, Mr. W then removed
this money to second-layer accounts, and so forth to third-layer accounts. For the purpose of
concealing illegal gains, Mr. W subsequently borrowed some of his friends’ personal accounts
in order to receive the above money. It was estimated that between 2017 and 2020, those
accounts received a total of 0.6 billion foreign currency (USD 93,190,941).
In the interests of earning more profits from the gambling business, Mr. W also hired engineers
to develop a “Fourth Party Payment” system, which integrated the services with third party
payment providers and benefited from receiving the service fees. For instance, a third party
payment provider received a 3.2% service fee of the total stake, and if there was a certain casino
website which was willing to pay 3.5%, Mr. W’s system would match both parties and take the
0.3% as the margin profit.
The Prosecutors’ Office prosecuted Mr. W, along with his accomplices for violations of the
Criminal Code and Money Laundering Control Acts in August 2020.

Case two:
Person A had established "Century Dynasty", "Winning Century" and other short companies
since 2010, and engaged in illegal money solicitation in Jurisdiction X, Jurisdiction Y,
Jurisdiction Z and other places. The amount of fraud exceeded 100 million yuan (USD
15,532,009). There have been a large number of victims from Jurisdiction X, Jurisdiction Y,
APG Typologies Report 2021 83
and Jurisdiction A. Due to multiple investment fraud cases, the Central Bureau of Interpol in
Jurisdiction Z issued a red notice on 15 May 2018, and the Central Bureau of Interpol in
Jurisdiction X issued a blue notice on 25 July of the same year. Person A entered Chinese Taipei
on 31 December 2019. He had not left the jurisdiction due to the outbreak of the Corona virus.
During his stay in Taichung, he was seized by the police on 14 May 2020. With the joint
cooperation of the police, NIA and Jurisdiction X authorities, person A was repatriated to
Jurisdiction X on May 16.
According to Jurisdiction X’s information, person A was suspected of having been involved in
commercial crimes amounting to USD 672,000 in Jurisdiction Z since 2015. In addition, he has
also been involved in several investment frauds in Jurisdiction X. The initial estimated amount
is more than 1.35 million in foreign currency (USD 209,663), and the total amount is converted
to more than 30 million NTD (USD 1,068,154). Person A was stranded overseas after
committing the crime and travelled to and from Chinese Taipei, jurisdictions in the region and
other places. In June 2019, Person A’s spouse came from Jurisdiction X to Chinese Taipei to
meet person A briefly. The Jurisdiction X authorities cancelled Person A’s passport on 24
February 2020, in order to arrest him and requested the assistance of neighboring jurisdictions.
Person A was separately wanted by Jurisdiction Z and Jurisdiction X for investment fraud.
They feared that he would start a new business during the period of detention in Chinese Taipei,
endangering the economic order and damaging people’s property. After locating person A, the
CIB immediately found him in Taichung City on 14 May 2020.

Indonesia
In the context of the crime of ML in Indonesia from 2016 to 2020, law enforcement officers
gave their perceptions regarding the risks of various typologies of money laundering offences.
The full typology of ML offences is assessed based on the experience of law enforcement
officials in handling ML-related cases.
The five methods with the highest frequency in descending order are:
 using a false identity;
 transfers to property assets/real estate;
 use of nominees or loan names as in the names of family members, people who work
for the perpetrators, or other trusted people;
 smurfing; and
 structuring.

a. Using a false identity

In many cases the use of false identities is due to the ineffectiveness of the single identity
number for citizens, making it is possible to make an identity card (ID card) of the same person
in different areas or also with a false identity. The invalid ID card is then used to open an
account to launder criminal proceeds. The next vulnerability is the integrity of sub-district or
village officials as officers who record data on citizens who apply for ID cards. If the sub-
district or village officials make administrative errors in making the ID cards, it can be assumed
that the data entered as material for making the identity card is also invalid.
For example, person A, an individual convicted of corruption who had fled abroad and had
already changed their citizenship, wanted to return to Indonesia and falsified his ID card by

APG Typologies Report 2021 84

colluding with the head of the sub-district. This resulted in the removal of the head of the sub-
district.
b. Using property company or property agents
The high rate of ML through property is due to tighter banking regulations and conversely weak
ML supervision in the property sector. The tighter regulations in the banking sector have made
criminals look for other places to store their criminal funds, one of which is property. For this
reason, Indonesia has strengthened its regulations to prevent ML in the property sector, namely
Law Number 8 of 2010 concerning the Prevention and Eradication of Money Laundering
(TPPU Law) and Government Regulation Number 43 of 2015 concerning Reporting Parties in
the Prevention and Eradication of the Crime of Money Laundering (second regulation). The
TPPU Law requires property companies or property agents to submit STRs for transactions
conducted in any currency with a value equivalent to IDR 500,000,000 (USD 35,020) or greater
to the Indonesian Financial Transaction Reports and Analysis Centre (PPATK). The second
regulation requires the land deed authorization officer (PPAT) to also report suspicious
financial transactions to PPATK regarding the purchase and sale of property.
c. Use of nominee (borrowed name), trusts, family members or other third parties
Based on PPATK’s research, in 2019 out of 174 ML cases currently undergoing legal
proceedings, 50 of them used a nominee usage typology, while in 2020, the figure was 58 of
the 86 ML cases. This shows an increasing trend in the use of nominees for ML. This typology
tends to occur frequently and it involves not only family members, but also associates of the
perpetrator. Nuclear family members are easily traced by law enforcement officials because
they are listed in the KK (family card), but if the person is outside the nuclear family, the
investigation is more difficult. Criminals usually do this by using the identities of the people
who work for them such as drivers, helpers, and other employees. Basically, the use of a
nominee is an attempt to remove traces of the proceeds of a criminal act by using the name of
another person who is trusted by the perpetrator of the crime. It is also possible to use nominees
to obscure the beneficial ownership of a legal business entity.
d. smurfing
Smurfing is the disguising of illegitimate transactions by breaking it up into multiple
transactions using multiple accounts with different names. This typology can still relate to the
use of nominees to collect proceeds from crime. The perpetrator uses many accounts with
different names to carry out his transactions in a certain period of time. Usually the owner of
these smurf accounts will be rewarded for lending their account services and the account owner
does not necessarily know where and for what reason transactions occur in the account.
e. structuring
Structuring is a transaction that is carried out in relatively small amounts, but with a high
frequency to disguise a larger transaction. This typology is commonly used to avoid the
suspicious transaction limit that is set at or below the cash transaction reporting threshold.
Usually the perpetrator will split the transaction with a nominal value below that limit so that
it does not appear as a transaction that is considered suspicious. Sometimes structuring is done
in the purchase of luxury goods, in this case a luxury car. The perpetrator of this crime utilises
financial services in purchasing a car then the perpetrator will deposit money monthly as
instalments for the credit for purchasing the luxury vehicle.
f. Use of professional services

APG Typologies Report 2021 85

ML is increasingly widespread in various sectors, not only in the financial sector or within
financial service providers or goods providers, but also in the professional sector. The modus
operandi that is usually used is to treat the professional person or body as an intermediary for
the purpose of ML. Professional services here include advocates, notaries, land deed
authorisation officers (PPATs), accountants, public accountants, and financial planners. The
professional services mentioned are a means for ML perpetrators to hide or disguise the origin
of assets that are the result of a criminal act, by taking cover behind the provisions on
confidentiality of professional relations with service users as regulated in accordance with the
provisions of laws and regulations.
In many cases, professional service providers are involved in the criminal acts of ML offenders,
such as the case of Person A, where lawyers were also arrested by the police for violations of
anti-corruption legislation and the criminal code. At the first and appeal court stages, the
lawyer, Person B, was found guilty of obstructing the investigation of the e-KTP (ID Card)
project corruption case with the suspect, former DPR (People Representative Council) Speaker
Person A. Person A himself also violated anti-corruption legislation and the criminal code.
Even other professional services, namely doctors, were also charged with the same charges as
the lawyers because they were deemed to have obstructed an investigation. Although in this
case the lawyer was not proven to be related to the crime of money laundering, at least it appears
that professional services are very vulnerable to being involved in the context of the main case.
g. New payment methods
Rapid technological advances have changed many things, including the world of financial
services. The market is no longer a physical market, but it has transformed into an online
market. Not only goods, but various kinds of services have also been marketed online.
Consequently, online payments also complement the online market. Transactions become
easier, people do not need to physically walk to the market nor do they need to pay physically
either. Online payment applications, both as part of banking service products such as mobile
banking and internet banking, as well as payments through online payment services such as e-
money and e-wallets offered by many financial technology companies (fintech) have become
increasingly popular in the last five years. Their use has also succeeded in advancing very
quickly to the small and medium enterprises sector. The banking world is one of the highly
regulated sectors while this is in contrast to the fintech world which is still new and of course
the regulations are not as comprehensive. In fact, many fintech companies offer the
convenience of opening accounts, making payments, and even investing.
In general, bank marketing still goes through the physical branch offices of each bank in person,
while financial technology companies market online without physically meeting consumers
meaning that supervision is weaker. The procedure for opening an e-wallet is simply to do it
with a photo of yourself, KTP (ID card), and telephone number, without any physical
verification or anything else. On the one hand, it makes it easier for consumers, but on the other
hand there is a concern that it could be misused for ML. The violation of regulations in the
world of financial technology and the ease of conducting transactions in it have ensured this
typology is considered a high risk by law enforcement officials as a means of ML.
h. Use of corporation (legal entity)
“Official” companies are often used as fronts to be a vehicle for ML, whereby the company is
used to conceal proceeds of crime as legitimate revenue for the company. It is said to be an
“official” company because from a legal point of view this company stands officially and
complies with regulations. Criminals usually have many companies which collect funds from
the proceeds of crime or are prepared as a means of money laundering. This is done to obscure
APG Typologies Report 2021 86
the traces of the flow of money because the name that is officially listed on the board of
directors or the owner of the company’s shares is not the beneficial owner (BO). Weak BO data
is also one of the main vulnerabilities in this typology. Even the banking sector cannot easily
find out the real name of the BO, when only a legal, formal company certificate without any
additional information is used when opening a company account.
One of the modes of corruption with the main perpetrator Person M that was revealed to the
public during a trial at the Corruption Crime Court, Jakarta, on 17 January 2020 was the
creation of a company called Company P, which uses the name of a person who actually works
as a personal driver for a director of the company. This driver, person O, works for a person
closely associated to Person M, namely person P, and he only borrowed his identity as a
condition for establishing the company and for the signing of the contract. Person O did not
know anything about the auction process carried out on behalf of the company of which he was
a director. This typology also contains the nominee typology discussed earlier. The identity of
this driver was borrowed to become a fake director of a company that did not actually belong
to him, even though the activities of it were not known to him. Person O’s position working for
someone left him no choice, but to follow his employer’s orders.
The TF NRA Document (updated 2019) maps domestic TF risks including:
a. Fund raising stage
- donation to terrorist groups
Example case:
On MTR's orders, HZ provided logistical assistance by opening an account in his wife's name,
namely RWI at Bank A, which was intended to accommodate donations from members of the
MIT group led by Santoso alias Abu Wardah, to help Santoso's struggle in his escape in the
mountains of Poso Regency in the form of food and tools used for training on the mountain,
with a total of IDR 49,600,000 (around USD 3,480).
- self-funding from legitimate sources
Example case:
NNG facilitated seven people including himself at his own expense by selling his house in East
Jakarta for IDR 590,000,000 (around USD 41,000) which was paid by transfer from the buyer's
Bank B account to NNG's Bank C account. Then the money was added to the money from the
sale of home furnishings, motor vehicles, and the proceeds from selling women's clothing, for
a total of IDR 33,200,000 (around USD 2,300). The total of all these funds were used to finance
seven people including NNG in the form of tickets and e-visas.
- donation through social media
Example case:
BA at the beginning of June 2016 had the idea to make a bomb that came from money from
selling narcotics, which was conveyed through his Facebook account inbox under BA's name
and person F's Facebook account to HB's Facebook account. Then BA raised funds of IDR
32,800,000 (around USD 2,300) from friends on Facebook as capital for the manufacture of
methamphetamine to be used to fund the making of bombs for terrorist acts.

b. Fund transfer/moving Stage

APG Typologies Report 2021 87
 - domestic and cross-border cash carrying
Example case:
AX received IDR 800,000 (USD 56) in cash from AG on the orders of BA, who is a member
of the East Indonesia Mujahidin terrorist group (MIT) for the purpose of purchasing materials
for making bombs to be detonated in the Pantangolemba area, Poso, Central Sulawesi. In
addition, AX also collects money from members of the Makassar MIT group using their
account at Bank D in the name of WW in the form of deposit funds of IDR 10,000,000, IDR
5,000,000 and IDR 3,000,000 (about USD 700, USD 350, and USD 200, respectively)
- money remittance
Example case:
In 2016, AP was asked by AJ to send money through a non-bank licensed money remittance to
SM using the name of a Jurisdiction X citizen with a total amount of IDR 150,000,000 (USD
10,536) sent for the purchase of firearms to be used in the shooting and bombing incident in
Thamrin, Jakarta.
- banking
Example case:
On the orders of BN, around March 2016 MK received the money transferred to the X Bank
account belonging to MK's wife (PA) in the amount of IDR 6,000,000 (around USD 400) and
was asked to send the money by transfer using the account to the AH’s Y Bank account
amounting to IDR 800,000 (around USD 53) in June, to DA’s Y Bank account amounting to
IDR 2,700,000 (around USD 180) at the end of June, and IDR 2,000,000 (around USD 140)
and at the beginning of July. All the funds were used for the suicide bombing incident at the
Surakarta Police Station.

c. Fund use stage

- purchase of weapons and explosives
Example case:
On S's orders, DN purchased weapons by sending money contributed by supporters of the MIT
to Jurisdiction X using a non-bank licensed money remittance, namely: on 5 March 2015
amounting to IDR 5,000,000 (around USD 350) and on 26 March 2015 amounting to IDR
16,150,000 (around USD 1,130). DN then left for Jurisdiction X to pick up the weapons that
had been purchased at a cost of IDR 2,000,000 (around USD 140).
- maintenance of terrorist networks
Example case:
On the orders of BS, HD made a small cell to carry out terrorist acts where the funds used were
funds that had been received from sympathizers. These funds were used to finance the
formation of new cells.
- mobility of terrorist group members and FTF travel
Example case:

APG Typologies Report 2021 88

AP facilitated the travel of foreign terrorist fighters 12 times, using the Z bank platinum ATM
card belonging to each group representative whose ATM card was used to purchase flight
tickets for departures to Jurisdiction Y and the Jurisdiction X as well as paying for electronic
visas via transfer for a total of IDR 468,376,080 (around USD 32,910).
- military training
Example case:
Based on AT's instructions, SU made a fund transfer through WA’s N Bank account to O Bank
for IDR 2,000,000 (around USD 140) for the purposes of MD's military training and also a
transfer to AZ’s P bank several times for IDR 3,000,000 (around USD 200) each. In addition,
at the direction of AT, SU was asked to send funds to MD and members in Tamanjeka Poso for
the purpose of buying a video camera costing IDR 2,500,000 (around USD 175).
- terrorist family compensation
Example case:
Funds collected by terrorists or terrorist groups are distributed to the wives of members of
terrorist groups, either those who died due to being shot by the police, who were imprisoned,
who fled because they were included in the wanted list (DPO) by the Police and individuals
who were on the move in Poso to join a terrorist group.

Macao, China
Couple from Macao, China arrested for involvement in fraud, forgery and ML
Several STRs received by the Financial Intelligence Office revealed that an education centre
was related to a fraud case. The education centre was owned by a couple from Macao, China.
After checking the account information of the company, the education centre’s bank account
received a government subsidy amounting to almost MOP 4,680,000 (around USD 585,000)
for the “Continuing Education Development Program” in Macao, China in the period from
August 2016 to August 2017. However, the funds were mainly withdrawn in cash and a small
portion was transferred to the couple from Macao, China and a wedding planning company.
Information showed that the wedding planning company was also owned by the same couple
and their source of funds was mainly cash deposits by ATM or OTC with cashier orders then
issued to other third parties.
By analysing the account transaction patterns, the Financial Intelligence Office discovered that
the accounts of the company only conducted a small number of transactions before August
2016. Most of the transactions occurred in the period of August 2016 to August 2017 and the
funds were mainly withdrawn in cash that was not in line with normal business practices. In
addition, FIU discovered that the couple were related to fraudulent activities in the past.
Therefore, the Financial Intelligence Office passed the cases to the Public Prosecutions Office.
The Public Prosecutions Office then requested the Judiciary Police to investigate the cases. It
was discovered that the case was related to fraud in relation to wedding banquet deposits and
the swindling of a subsidy under the “Continuing Education Development Program” in
February 2017 and June 2019 in succession. The couple who ran the wedding planning
company deceived over 40 customers by collecting their wedding banquet deposits amounting
to a total of MOP 5 million (around USD 625,000) in two years. At the same period of time,
they owned an education centre and received a government subsidy of MOP 140,000 (around

APG Typologies Report 2021 89

USD 17,500) but had not actually held any kind of education course and forged student
attendance records.
After conducting follow-up investigations on the two cases, it was found out that the wife had
remitted a total of HKD 3.3 million (around USD 424,936) of suspected fraudulent proceeds to
a bank account held by the husband and his brother in a nearby jurisdiction, via the account of
the wedding planning company on multiple occasions. The funds were further remitted to other
banks, as well as used for the issuing of cheques and repayment of credit card loans so as to
launder the criminal proceeds.
Additionally, during the financial investigation of the suspect’s bank account transactions, the
Judiciary Police found out that the suspect had submitted documents such as a forged proof of
income and a falsified bankbook to a bank when applying for a mortgage loan of HKD 2.23
million (USD 287,160) in 2017.
In May 2020, the Judiciary Police mobilised personnel to the residence of the suspects and
brought them back for investigation. The suspects denied having committed the crime. Yet,
they failed to give reasonable explanations for the investigative findings of the Judiciary Police.
Therefore, the Judiciary Police transferred them to the Public Prosecutions Office for three
offences including fraud, forgery of documents and money laundering.

Malaysia
As identified in the 2017 National Risk Assessment (NRA), fraud, corruption, illicit drug
trafficking, organised crime and smuggling remain as the prevailing crimes in the jurisdiction,
mainly as attributable to the STR reporting and investigations conducted. Currently, Malaysia
is in the midst of finalising its 2020 NRA covering the development of trends and patterns of
ML and TF since the last round of NRA. The 2020 NRA aims to identify, assess and understand
the ML/TF risks in the jurisdiction, including threat and sectoral inherent risk, control
measures, relevant emerging trends and the interconnectedness between sectoral and threat
assessments.
With regard to illicit drug trafficking, the Royal Malaysia Police (RMP), had in January 2020,
seized RM 366 million (USD 88,812,328) worth of assets linked to its investigation into the
opening of a company account used in the smuggling of 12 tonnes of cocaine worth RM 2.4
billion (USD 582,375,921) that was seized in September 2019. The cocaine was mixed with
charcoal to avoid detection and was believed to be from an international drug syndicate using
Malaysia as a transit jurisdiction. Eight individuals including six foreign nationals were
subsequently charged for the trafficking of dangerous drugs.
The investigation revealed a large network of companies and the key involvement of a
businessman who was the chairman of publicly listed companies. The businessman, a proxy of
the main suspect who is still at large, was identified as owning several joint accounts with his
associates. Between 2012 and 2020, these accounts received substantial cash deposits from
various locations nationwide which were transacted on a daily basis and were conducted below
the reporting threshold, as well as fund transfers from numerous companies including those
related to one of his publicly listed companies. The funds circulated among the joint accounts,
creating many layers of transactions before their subsequent withdrawal to various companies
and individuals. The case revealed the significant utilisation of funds towards purchases of
properties, shares and vehicles that were owned by the suspects, relatives and proxies.
Pakistan
Terrorism Financing- Proscribed person under UNSCR-1373
APG Typologies Report 2021 90
The transactional activity of an individual Mr. XYZ was suspicious as he was placed on
Schedule-IV of the Anti-Terrorism Act, 1997 (UNSCR-1373) in October 2020 under Category
A (Terrorism) due to his affiliation with a banned group.

Upon proscription under UNSCR-1373, STRs were filed by different banks on the personal
and business accounts of Mr. XYZ. As per KYC documents, he was the sole proprietor engaged
in a business involving dried fruit and a commission agency in the terrorism-hit area near the
border of a neighbouring jurisdiction. As per the National Identification Card for Overseas
Pakistanis (NICOP), the individual was an overseas Pakistani and had a permanent address in
a terrorism affected area in the jurisdiction. FMU received multiple STRs from different banks
upon proscription of the individual under UNSCR-1373.

After analysis, it was found that the suspect was maintaining multiple individual, business and
joint accounts in different cities of the jurisdiction. Overall, 14 accounts were identified in eight
different banks. Furthermore, a high volume of transactional activity was noted in the accounts
before proscription over the last three years with rapid movement of funds. The transactional
activity revealed that funds were transacted through cash and internal transfers with unrelated
counterparties indicating the involvement of Mr. XYZ in a Hawala/Hundi business. The
accounts were frozen by the banks upon proscription of the individual.

Upon analysis of the accounts of the counterparties of Mr. XYZ, it was identified that one of
his counterparties Mr. A, the proprietor of MT Traders engaged in the business of scrap, cloth
and dried fruit, was already referred by FMU to a LEA for investigation on suspicion of being
involved in the Hawala business. One counterparty Mr. B, proprietor of HAC, engaged in the
business of food grains and dried fruit, was also already under investigation by a LEA and
listed in the Red Book of the Most Wanted Terrorists due to his association with a person
designated under UNSCR-1267. Similarly, many other counterparties were suspected of being
involved in Hawala.

Keeping in view the analysis, it was suspected that the individual might be involved in the
illegal business of hawala/hundi or using this channel for moving funds. Furthermore, he was
listed on the Schedule-IV of Anti-Terrorism Act, 1997, and therefore the possibility of him
being involved in terrorism financing could not be discounted. The financial intelligence was
shared with relevant LEAs for an investigation into the matter. The matter is under
investigation.

APG Typologies Report 2021 91

7.3 Emerging trends; declining trends; continuing trends.

Fiji
Emerging Trend
The FIU noted an increase in individuals using alternative technology and channels to transfer
funds to other individuals. This includes the use of Post Fiji telegraphic money orders (TMO)
and Paypal. In some instances it was noted that the use of these alternative technologies and
channels was to deliberately avoid detection.
Reported cases of illegal pyramid schemes have also increased in 2021.
Continuing Trend
The FIU observed a continued occurrence of individuals falling victim to various online scams
in 2020. Cybercriminals have taken advantage of the current global Covid-19 situation and
have offered fake loans, packages, and relationships to vulnerable sectors of the community
that remitted hundreds of thousands of dollars to these cybercriminals.
Indonesia
An emerging threat is a new mode of money laundering that has not been mitigated by the
relevant authorities. From several funding cases that have occurred recently, it was found that
there were a number of funding modes that could become a new threat, including e-commerce
transactions, especially start-ups that facilitate buying and selling accounts.
a. No strict regulations regarding punishment of sales and purchase and use of accounts on
behalf of others
Fraudulent acts relating to sales and purchases online are increasingly occurring. There is a
method involving online account trading. Sales and purchases made online through certain e-
commerce/marketplaces are conducted as illegal acts of account takeover victimising the
customer who actually owns the account. In the case of an account buyer as a victim, usually
the seller targets a target buyer who does not understand the risks involved in buying this
account. Most of the accounts sold were blocked accounts belonging to other people, or
secondhand accounts. In the case of the buyer as a criminal, it is very likely that the account is
bought for abuse or as a deposit for fraud. Logically, if customers really need accounts for
personal needs and not for misuse, they will find it easier to open accounts in their own names.
These are some facts related to the prevalence of sales and purchases and the use of other
people's accounts.
b. Limited supervision regulations on e-commerce and fintech practices
The rapid growth and development of the financial technology industry has raised concerns.
The simplicity and practicality contained in it seems to be a double-edged sword. This concern
stems from the absence of clear regulations related to the implementation of the AML-CFT
programmes from regulators.
Meanwhile, the current state of technological development, coupled with the increasingly
encouraging efforts to prevent and eradicate TF, has caused terrorist groups to continue to look
for new alternative routes to seek financing of terrorism in ways that tend to be difficult to
detect and trace, including:

APG Typologies Report 2021 92

 • Use or misuse of corporation/companies
Through a legal company, terrorist groups can use banking facilities and financial service
providers for the purpose of collecting, transferring and using funds so that it looks as if it is an
ordinary business transaction. Criminal acts of terrorism financing committed by person B that
were successfully revealed by law enforcers show that terrorist groups own oil palm plantations
to fund their activities.
• Illegal drugs
According to the United Nations Office on Drugs and Crime (UNODC), in raising funds to
support terrorist acts, terrorist organisations can rely on traditional criminal activities, including
the sale of illegal drugs, or commonly known as narcoterrorism. The UNODC report regarding
the existence of narcoterrorism in Afghanistan shows a correlation with the development of
terrorism financing through criminal channels in Indonesia and there is a potential new threat
in terrorism financing through the sale of illegal drugs.
• Virtual currency
The development of technology 4.0 in fintech companies led to the emergence of a funding
model using virtual currency as happened in the case of person E who used bitcoin in terrorism
funding. Virtual currency has features including fast transaction processing, low transaction
fees, and relative ease; however, they are vulnerable to being exploited by criminals because
they allow transactions to occur without using their real names, do not have reporting
obligations and some do not require third-person intermediaries to carry out the transactions.
• Online loans
The emergence of fintech in the form of online loans makes it easy to get the desired funds in
a short timeframe and with an easy process. However, the ease of technology also influences
the ease of online lending to customers and can therefore be exploited by terrorist groups.
• Fundraising through social media (crowdfunding)
Fundraising through social media or crowdfunding, especially during the pandemic, such as
raising funds raised for the purchase of medical devices can be used by terrorist groups to
finance terrorism. In addition, the ease of creating social media accounts by utilising
anonymous/ fake/other people's accounts allows the use of social media to spread fundraising
messages more and more frequently.
In the 2020 NRA ML preliminary document, there are a number of technical and strategic
issues that are considered important in determining the effectiveness of the eradication and
prevention of ML in the future, include the following:
a. There is still limited attention, awareness and partisanship of state and government elites
on the importance of law enforcement of ML for all predicate crimes. The optimisation of
ML can be directed as a step to "impoverish" criminal acts so that criminals think again,
given the higher consequences of crime.
b. A number of law enforcement agencies have shown their commitment to support the
AML regime by establishing a special unit or ML task force.
c. The limited number of ML investigators and the inadequate coordination pattern between
institutions, especially related to cases in the forestry and environmental sectors, which
often stop at actors in the field.
APG Typologies Report 2021 93
 d. It is necessary to strengthen the institutional quality of the MLA central authority at the
Ministry of Law and Human Rights to increase the effectiveness of coordination and
cooperation, and to eliminate a reluctance to share information amongst competent
authorities.
e. The absence of an integrated data system or some kind of big data analytics that can help
law enforcement, supervisory and regulatory agencies, as well as reporting parties, to
optimise their ability to identify, monitor, and mitigate risks to the ultimate beneficial owner
and PEPs related to ML.
f. The absence of a system of "Integrated ML Analysis Data" that can be implemented by
the stakeholders of the AML regime.
g. The need for optimising the whistleblowing system related to ML crimes committed by
corporations and individuals based on corporate identification on the alleged occurrence of
ML.

Macao, China
Continuing trends
Internet-related fraud
In the first half of 2020, the trend for internet-related fraud cases was still of concern. Fraud
cases mainly happened via the internet in relation to investment fraud, romance scam, etc.
Sometimes local banks received telegraph messages from the ordering bank or an email from
the victim claiming the relevant remittances were related to fraudulent acts. Through the
continuing promotional campaign from law enforcement agencies, front-line bank staff would
also alert a suspected victim to think twice before remitting money to a third party’s account
and stay vigilant against deception, in order to avoid losing money to scams.

Malaysia
Continuing trends
Over the years between 2017 and 2020, criminals’ use of mule accounts to facilitate financial
fraud, notably telecommunication scams, remains prevalent in the jurisdiction. More recently,
there are also signs of the exploitation of companies incorporated onshore and offshore by
international fraud/ML syndicates in moving or layering the funds via various fraud schemes
including business email compromise (BEC) scams, personal protective equipment (PPE)
fraud, etc. The increase in fraud-related STRs received by the Malaysian FIU coupled with the
public complaints last year indicated that fraud schemes have become more predominant as
criminal groups resort to exploiting the financial misfortunes of the public due to the COVID-
19 pandemic. The modus operandi of these fraud schemes continue to evolve with the use of
corporate mules as well as individual mules utilising non-conventional methods such as non-
bank remittance service providers, e-money issuers and virtual assets to launder the proceeds
of these fraud schemes. More sophisticated scams involve networks across multiple
jurisdictions and the use of advanced technologies e.g. spoofing technology such as VoIP and
the use of mobile internet rather than WiFi to avoid a trace of an IP address is also emerging.

APG Typologies Report 2021 94

Vietnam
Currently, the 4.0 technology revolution has had a strong impact on all sectors of the economy,
especially in the fields of banking and finance. Accordingly, many types of payment
intermediaries, including e-wallets and virtual money, have appeared, creating favorable
conditions for consumers in transactions and payment for goods purchase and sale. However,
these forms of payment also pose potential risks of being used by criminals to conduct money
laundering and terrorism financing activities; in which, Mobile Money is one of the services
with many potential risks to be used by criminals to commit money laundering due to its
characteristics such as anonymity, difficult to control and fast execution.

APG Typologies Report 2021 95

8. EFFECTS OF AML/CFT COUNTER-MEASURES

This section of the report provides a brief overview of recent results from legislative, regulatory
or law enforcement counter-measures.

8.1 The impact of legislative or regulatory developments on detecting and/or

preventing particular methods (eg tracing proceeds of crime, asset forfeiture
etc).

Australia
Following the conviction of Christchurch, New Zealand, mosque shooter Person A in August
2020, the New Zealand government imposed targeted financial sanctions on Person A, with the
Australian Department of Foreign Affairs and Trade imposing similar sanctions on him shortly
afterwards.

Chinese Taipei

On 7 November 2018, Chinese Taipei passed the Amendments to Counter-Terrorism Financing

Act (CTF Act). The amendments ensure that the scope of TFS applies to the agent of a
designated individual, legal person or entity, or other entities acting on behalf of, or under the
direction of, designated persons and entities, in order to comply with international regulations.
On 31 March 2018, Chinese Taipei implemented TFS on a citizen person A and froze the assets
of entities controlled by person A after the aforementioned amendments.
In addition, on 1 February 2019, Chinese Taipei passed the Regulations on Competent
Authorities Governing Specific Foundations for Anti-Money Laundering and Counter-
Terrorism Financing. As stated in these regulations, competent authorities shall take
appropriate measures to supervise foundations under the definition of FATF, which engage in
the pursuit of raising or disbursing funds for charitable, cultural, educational, social, fraternal
or other similar types of purposes beneficial to the public and which have been listed as
foundations with high risk by the competent authorities through the procedures of risk
assessment, to avoid those foundations being subject to ML/TF abuse. In addition, the
Prosecutors’ Office prosecuted person B and his accomplices in September 2020 for violations
of the CTF Act which involved the illegal sale of oil to DPRK. It was the first prosecution case
of this kind made by Chinese Taipei.

Chinese Taipei
The FSC has required the Bankers Association to send “Suggested Best Practices for Banks to
Identify Beneficial Owners” to financial institutions for reference on 24 March 2020.
Regarding the enhanced cooperation between law enforcement and private sectors, the FSC has
asked relevant financial industry associations to hold compliance forums periodically. For
example, the Bankers Association has invited law enforcement to share Fintech and emerging
crime typologies and cases, and invited financial institutions to share their best practices for
identifying beneficial owners and financial groups to share AML/CFT information in 2020.
APG Typologies Report 2021 96
These measures could make financial institutions better understand risks and threats and
effectively assist law enforcement authorities to investigate the proceeds of crime.
In 2020, the FSC revised the AML/CFT questionnaire, and updated the risk rating and risk
profile of financial institutions in early 2021.
The FSC will continue to implement its AML/CFT Strategy Map, review the related regulations
to conform to international standards, and supervise the financial institutions to comply with
AML related regulations and implement AML/CFT works.
Chinese Taipei is currently working on a draft which will include third-party payment service
providers as a DNFBP in Subparagraph 5, Paragraph 3, Article 5 of Money Laundering Control
Act (MLCA) when handling specific businesses, and will issue regulations governing the
internal control system, audit system, identity verification mechanism, record keeping on
necessary services, STR filing and all reporting on designated sanctioned individuals and
entities.

Fiji
In March 2019, following a Fiji Police Force search for possible illicit substances, Person B
was found in possession of FJD 28,000 (USD 13,718) in cash. Person B is the wife of the drug
suspect and stated that the cash was from the sale of a vehicle, however, there was no evidence
of the sale of a vehicle and there was no evidence that she was able to initially purchase a
vehicle with that residual value. The police suspected that the cash was from the proceeds of
the sale of drugs. Person B continued to maintain that the cash was from the sale of a vehicle
to Person X, however, Person X denied purchasing a vehicle from her and there was no
evidence of a vehicle transfer from her during this time period. Person B failed to provide an
adequate explanation for the cash, ultimately resulting in the funds being declared as
unexplained wealth by the High Court of Fiji in 2020 and forfeited to State. This successful
trial was Fiji’s first unexplained wealth case since the introduction of unexplained wealth laws.

Macao, China

AML/CFT/CPF Strategic Plan (2021-2025)

To respond to the complex changes in the development of international trends of ML/ TF /PF,
and to further protect the sustained healthy growth and the diverse development of the economy
of Macao, China, the government formulated the first AML/CFT/CPF Strategic Plan for the
year 2016 to 2020 based on the result of the 1st overall risk assessment project. With the
expiration of the first AML/CFT/CPF Strategic Plan, the second was developed to set out the
policies and goals for the period from year 2021 to 2025.
The AML/CFT/CPF Strategic Plan (2021–2025) of Macao, China outlines the strategic
direction of the government in the relevant regime. These include the following ten strategic
goals:

APG Typologies Report 2021 97

 Goal 1: Continuously maintain a comprehensive AML/CFT/CPF legal and
institutional framework to cope with the evolving economic development
of Macao, China and international standards
Goal 2: Enhance overall Macao, China ML/TF/PF risk assessment
Goal 3: Foster international cooperation in relation to AML/CFT/CPF and related
predicate offences
Goal 4: Further reinforce parallel financial investigations for all major predicate
offences
Goal 5: Continuously maintain the high transparency of legal persons and legal
arrangements
Goal 6: Enhance confiscation and asset recovery to deprive criminals of criminal
instrumentalities and proceeds
Goal 7: Prioritise terrorist financing investigations as higher policy level
objectives in accordance with international standards
Goal 8: Uphold a sound Risk-Based Approach in supervision for all sectors and in
criminal investigation
Goal 9: Strengthen the implementation of CFT and CPF freezing mechanisms in
accordance with international standards
Goal 10: Promote a compliance culture, awareness and understanding of ML/TF/PF
risks to all regulated entities to enhance the level of AML/CFT/CPF
compliance
More detailed sub-goals and action items were further developed under the framework of the
ten strategic goals. This new five-year strategic plan, as in the past, was read and discussed by
the Executive Council which was headed by the Chief Executive of Macao, China, thus
showing the high level political commitment to address AML/CFT/CPF issues.
Other AML/CFT Legislative or Regulatory Developments in 2020
In order for the reporting entities to have a better understanding on the implementation of the
law “Asset Freezing Regime”, the supervisory agencies, the Monetary Authority of Macao,
China and the Gaming Inspection and Coordination Bureau, issued Circulars and Practical
Guidance to financial institutions and gaming concessionaires in March and June 2020
respectively. The Circulars and Practical Guidance aim to explain in more detail the
requirements of the law “Asset Freezing Regime”, assist the reporting entities to refine their
SOPs, as well as establish an expedited coordination and reporting mechanism with industries.
Statistics
(i) In the first half of 2020, a total of 947 STRs have been received and 57 STRs were
reported to the Public Prosecutions Office.
(ii) In the first half of 2020, the number of AML/CFT investigations, prosecutions and
convictions are given as follows:

Activities AML/CFT
Investigations by the Judiciary Police 25
Investigations by the Commission Against 2
Corruption
Investigations by the Public Prosecutions Office 20
APG Typologies Report 2021 98
 Prosecutions 6
Convictions 2*
` * 1 case is still under appeal.

For cases developed directly from STRs, please refer to Macao, China’s Case, ‘Couple from
Macao, China arrested for involvement in fraud, forgery and ML’ in section 7.2.

Malaysia
To complement the principle-based requirements in the revised Anti-Money Laundering,
Countering Financing of Terrorism and Targeted Financial Sanctions Policy Documents for
FIs, DNFBPs and non-bank FIs (AML/CFT Policy Documents) which came into effect on 1
January 2020, Bank Negara Malaysia (BNM) has issued two guidance documents on beneficial
ownership and verification of individual customers. The documents aim to facilitate the
operationalisation of the requirements under the AML/CFT Policy Documents and provide
recommendations for reporting institutions to strengthen the appropriate controls that are
commensurate with risk levels.
To support industry players in navigating the COVID-19 pandemic, BNM issued a Circular on
Regulatory Expectation on AML/CFT Measures during the COVID-19 pandemic in April
2020. It outlined regulatory flexibilities already accorded within the revised AML/CFT Policy
Documents, such as the implementation of a RBA to determine appropriate CDD measures that
are commensurate with ML/TF risk levels.
In addressing rising cybercrimes, the Royal Malaysia Police also took the initiative to develop
a mobile application, “Semak Mule”, in addition to its existing website 39, to enable the public
to authentically check bank accounts and telephone numbers which have been linked to
criminal activities. The mobile application also lists the top 10 bank accounts and phone
numbers used in scams to allow the public to make an early check wherever they are and to
avoid becoming victims of cybercrime in Malaysia. As the public can access it anytime of the
day, this initiative has yielded results with a total of 9 million people having accessed the web
portal and 120,000 have downloaded the application as at October 2020.

Philippines
The Philippines has an existing legal framework addressing terrorism. In 2007, the Philippines
enacted Republic Act (RA) No. 9372 titled “An Act to Secure the State and Protect our People
from Terrorism, also known as the Human Security Act of 2007”. In 2012, the Senate and
House of Representatives of the Philippines in Congress also enacted RA No. 10168, otherwise
known as “The Terrorism Financing Prevention and Suppression Act of 2012” (TFPSA). RA
No. 9732 was repealed through the enactment of RA No. 11479, or the Anti-Terrorism Act of
2020 (ATA).

39
http://ccid.rmp.gov.my/semakmule/

APG Typologies Report 2021 99

RA 11479, titled “An Act to Prevent, Prohibit and Penalize Terrorism, Thereby Repealing
Republic Act No. 9372, otherwise known as the Human Security Act of 2007”, was signed into
law by the President on 3 July 2020 and took effect on 18 July 2020.
Section 25 allows the Anti-Terrorism Council40(ATC) to:
a) automatically adopt the UNSC Consolidated List of individuals, group of persons,
organization or associations designated and/or identified as terrorists, financiers of
terrorism;
b) adopt upon determination, requests for UNSCR 1373 designation of foreign states; and
c) designate domestic terrorists, upon determination of probable cause.
The passage of the ATA provides additional awareness to covered persons in identifying
potential terrorists, and terrorism- and TF-related transactions. While the ATA is a welcome
addition, LEAs in the Philippines can still use the TFPSA to prosecute TF.
An assessment of STRs showed a 580% increase in 2020 compared with the 2019 STRs. The
monthly trend shows a surge in STRs from September to December 2020, in the months after
the enactment of the ATA. There was also a surge of over 500% in STR reporting during the
COVID-19 pandemic particularly from March to July during the imposition of the community
quarantine.

STRs are reported through coordination between the AMLC and covered persons (CP) in the
possible nexus of the accounts, with terrorism and TF. Other contributory factors are the regular

40
Section 45 of the ATA provides for the creation of the Anti-Terrorism Council (ATC). The ATC is composed
of nine (9) members of the Cabinet including the Executive Secretary, National Security Adviser, Secretary of
Foreign Affairs, Secretary of National Defense, Secretary of Interior and Local Government, Secretary of
Finance, Secretary of Justice, Secretary of Information and Communications Technology, and the Executive
Director of the AMLC.

APG Typologies Report 2021 100

updating of risk understanding through regular engagement of the AMLC and other LEAs with
CPs and industry associations; and the continuous and coordinated efforts of various agencies
in the campaigns for AML/CFT.

Singapore
Legislative development to enhance intelligence sharing with FIUs

With effect from 1 April 2019, Singapore has amended Section 41 of our Corruption, Drug
Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (Chapter 65A) (“CDSA”)
which enables the Suspicious Transaction Reporting Office (STRO) to exchange financial
intelligence with FIUs in the Egmont Group without the need for a MOU/LOU, if the following
conditions are fulfilled:
- the financial intelligence may be relevant to an investigation into a drug dealing offence
or a serious offence in the foreign jurisdiction;
- the foreign FIU is able to provide STRO with financial intelligence upon our request;
and
- the foreign FIU has given appropriate undertakings for protecting the confidentiality
and controlling the use of the financial intelligence.
This legislative amendment allowed for collaboration with more FIUs to aid in detection of
ML activities, its predicates as well as TF activities. In 2020, the numbers of requests for
assistance that STRO sent out and received respectively from our foreign counterparts both
saw an increase of approximately 10% each, as compared to 2019.
Legislative development of Payment Services Act
Under the Payment Services Act (PS Act), VASPs (or digital payment token service providers
as referenced in the PS Act) that buy, sell or exchange digital payment tokens (DPTs) are
required to be licensed and are subject to AML/CFT requirements. Service providers that deal
in virtual assets for investment purposes are similarly required to be licensed under the
Securities and Futures Act and comply with AML/CFT requirements.
To align Singapore’s regulatory regime with the revised FATF standards for virtual assets,
amendments to the PS Act were passed in Parliament in January 2021 to expand the scope of
regulated DPT services to include the transfer of DPTs and the provision of custodial wallet
services for DPTs. A DPT service provider that provides any of these services would similarly
need to be licensed under the PS Act and be subject to MAS’ AML/CFT requirements. This
will include the need to conduct customer due diligence, monitor transactions and report
suspicious transactions. MAS is also making legislative amendments to include entities
incorporated in Singapore that are providing VA services (i.e. services relating to payments
and/or investments) solely outside of Singapore within its regulatory ambit.
MAS applies a risk-based approach to supervising VASPs in Singapore. Robust AML/CFT-
focused checks are conducted on licence applicants as part of the licensing process, to ensure
that DPT service providers that intend to operate in Singapore have the relevant ML/TF risk
awareness and appropriate AML/CFT controls in place. MAS also conducts risk-targeted
inspections to examine the effectiveness of licensees’ AML/CFT controls, including their
monitoring and surveillance activities to detect unusual behaviours and suspicious transactions.
MAS also leverages on its surveillance capabilities to proactively detect unlicensed DPT
APG Typologies Report 2021 101
activities for enforcement action, using both public and other data sources, such as corporate
registry information and STRs.
As the VAs sector continues to evolve, Singapore authorities, including MAS and law
enforcement agencies, work closely together to identify and detect ML/TF/PF risks and
typologies, and take necessary steps to mitigate these risks.
Enhancing BO transparency in Singapore
Under the Companies Act and Limited Liability Partnerships Act, companies and LLPs are
required since 31 March 2017 to obtain and maintain beneficial ownership information, and to
make the information available to law enforcement authorities upon request.
As part of the Accounting and Corporate Regulatory Authority’s (ACRA) ongoing efforts to
uphold Singapore’s reputation as a trusted financial hub, and to further enhance the
transparency of ownership and control of corporate entities, the Companies Act and Limited
Liability Partnerships Act were amended with effect from 30 July 2020 to require all companies
and limited liability partnerships (LLPs) to file the information that they maintain in their
Register of Registrable Controllers (RORC), with ACRA’s Central Register of Controllers. The
RORC information in ACRA’s Central Register of Controllers is made available to law
enforcement agencies for the purpose of administering or enforcing the laws under their
purview.

8.2 Cases developed directly from suspicious or cash/threshold transaction

reports.

Malaysia
Business email compromise (BEC) and involvement of a bank branch manager in facilitating
the opening of mule accounts
The FIU received an STR from Bank X reporting on Entity A, a newly established sole
proprietorship, which received a substantial amount of inward remittance funds from
Jurisdiction S despite being in operation for only two weeks. Before the sender bank was able
to alert Bank X that the inward funds were related to fraudulent transactions involving BEC, a
small portion of the amount was immediately withdrawn over the counter. The remaining funds
were transferred out to another account held by Entity B in a different financial institution.
Upon further checks, it was discovered that there was also an STR reported on Entity B’s
account on a similar basis of suspicion, in particular receiving a substantial amount of funds
from a foreign entity and with an immediate outgoing transfer to another entity. The
transactional behaviour of Entity B closely mirrored Entity A.
Further analysis by the FIU revealed that this BEC activity involved a group of sole
proprietorships as mule account holders, with similar names of legitimate businesses
established in foreign jurisdictions to deceive potential victims. These sole proprietorships were
created to mask as these foreign businesses and employ the same modus operandi as Entities A
and B.
In addition, after an internal investigation initiated by one of the financial institutions involved,
it was discovered that the syndicate was facilitated by a bank branch manager to ease the
process of account opening and withdrawal of funds.

APG Typologies Report 2021 102

The case was forwarded to the Royal Malaysia Police (RMP), which resulted in an investigation
and the main suspects were charged under Section 420 of Penal Code while the seized funds
were returned to the victim under section 60 of AMLA.

Filing of an incorrect return by a professional

A doctor served as a surgeon consultant in a private hospital and he also owned a clinic.
Surveillance activities conducted by the Inland Revenue Board of Malaysia (IRBM) on the
doctor’s assets, liabilities, income and other related information showed that the doctor’s
reported income was understated. He had partially omitted earnings from his private practice
and service at the private hospital.
Investigation by the IRBM revealed that the large total savings held in the doctor’s accounts
was not commensurate with his declared income. Inspections were conducted at the doctor’s
business premises and personal residences, and on various third parties related to or doing
business with him. The doctor was charged under Section 114 (1)(a) of the Income Tax Act
1967 for wilful evasion of income tax for five years, which amounted to approximately RM 6.5
million (USD 1,577,096) in unpaid taxes. The case was subsequently withdrawn upon
settlement of the payable tax and penalties through civil recovery.
An STR reported by a bank revealed that within a five month period, RM 8.2 million (USD
1,989,576) was deposited into a personal account jointly maintained by the doctor and his wife,
who is a housewife. Some of the funds were from his fixed deposit accounts which had been
closed, and he issued cheques for more new fixed deposit placements. According to the bank,
he had a total of 12 fixed deposit facilities. In view of the large transactions in the account and
his profession, the bank suspected that the doctor had used his personal account for business
purposes, and he might be involved in tax evasion.

Tax Evasion Involving Illegal Income / Profit

A joint investigation was conducted by the IRBM with other LEAs on a group of 55 entities in
a State in East Malaysia suspected to be involved in the smuggling of cigarettes and liquor from
a neighbouring jurisdiction. The smuggled cigarettes and liquor were distributed to groceries
and chain stores in the State.
Investigation by the IRBM revealed that the entities had a high turnover in their bank accounts
with large transactions. The amount involved in transactions was not commensurate with
income declared to the IRBM. The case was subsequently settled as a civil recovery under the
Income Tax Act 1967. The total amount of tax evaded of RM 19.7 million (USD 4,779,828)
has been paid.
Multiple STRs were reported on the two main subjects, Mr P and Mr T, who were involved in
the wholesale and retail of food and groceries. A summary of suspicious transactions which
indicate Mr P’s and Mr T’s possible involvement in illegal activities, ie. smuggling and tax
evasion is as follows:
 Mr. P’s personal accounts showed a high volume of deposit transactions via cash over
the counter, cash deposit machine and cheques. The funds were withdrawn via cash
cheques encashment.
 Mr. P informed the RIs that transactions conducted in his accounts were for business
purposes. However, the source of funds and purpose of transactions performed by Mr
P could not be determined/verified by the RIs.

APG Typologies Report 2021 103

  Mr. P had claimed one non-winning cheque from a casino despite no gaming activity at
the casino, indicating that Mr P could have used channels other than banking institutions
(e.g. casino) to receive business proceeds.
 Based on his declaration to the RIs, Mr P was related to Mr T, i.e. owning the same
business or having the same employer.
 Mr. T had multiple roles, as director/shareholder and/or authorised signatory in various
business entities involved in businesses such as transportation and hotel. Some of the
entities had no clear nature of business.
 Mr. T was investigated previously by LEAs (an order under Section 48 of AMLA was
issued against him).
 Mr. T appeared to be actively conducting transactions through a casino. He was reported
to have conducted cash transactions in large amounts in a casino and claimed some non-
winning cheques. Total amount of transactions which were not related to gambling was
high.
 Mr T had also placed a large amount of funds in share investments.

Singapore
Person prosecuted in a tax evasion case developed directly from STR

STRO received a STR on Person A. Analysis revealed that there were numerous cash deposits
of more than SGD 1 million (approximately USD 0.75 million) deposited into Person A’s
personal bank account over a period of four months. Person A had mentioned that the deposits
were earnings from her pub businesses.
Acting on the STR, the Inland Revenue Authority of Singapore (IRAS) initiated an
investigation into Person A. Using data analytics and advanced statistical tools, IRAS detected
anomalies in the income tax declarations of two pub establishments. IRAS also noted that all
the businesses registered in Person A’s name had ceased before the time the deposits were made
into Person A’s personal bank account.
Investigations revealed that although Person A was not listed as a shareholder or director of the
two pub establishments, Person A was actually the decision-maker for the businesses carried
on by both companies and orchestrated an arrangement to omit cash sales. The companies had
made false entries in their Income Tax Returns and had also understated output tax in their GST
Returns.
Person A was convicted of assisting two pub establishments to evade Income Tax and Goods
and Services Tax (GST). Person A was sentenced to 41 weeks’ imprisonment and ordered to
pay total taxes, penalties and fines amounting to SGD 2,318,452 (approximately USD
1,747,045).

STR supporting overseas investigation into possible fraud and embezzlement

STRO received intelligence on Person B’s involvement in possible fraud and embezzlement of
monies from a Savings and Cooperative Loan Fund based in a Southeast Asian jurisdiction
APG Typologies Report 2021 104
where repayments amounting to more than SGD 1 billion (USD 751,680,134) were defaulted
from February 2020.
STRO conducted further analysis on the financial intelligence relating to Person B during the
possible offence period. Our analysis uncovered that during this period, Person B had money
flows of more than SGD 5.9 million (approximately USD 4.45 million) overseas through a mix
of money changers and wire transfers via bank accounts. With the recent unravelling of Person
B’s alleged embezzlement, STRO had reasons to suspect that the money flows could potentially
be related to the said Fund.
STRO expeditiously shared our analysis with our foreign FIU counterpart and received
feedback from it that our analysis and information had provided insights for their ongoing
investigations against Person B.

APG Typologies Report 2021 105

9. COVID-19 RELATED ML & TF TRENDS

9.1 Association of types of ML or TF with particular predicate activities

linked to COVID-19 (e.g. welfare fraud, scams, counterfeit medicines,
corruption, drugs, smuggling, etc).
Brunei Darussalam
On 16 March 2020, the Government of Brunei Darussalam implemented the closure of all
borders and strictly monitored any persons claiming essential travel to arrive in the jurisdiction.
Since then, there has been a steep increase in the discoveries of drug-related offences involving
larger amounts of illegal narcotics.
Based on open source reports, it is estimated that a total of BND 5.9 million (USD 4,432,815)
worth of drugs and BND 419,000 (USD 314,806) of cash suspected to be proceeds of crime
(including foreign currency) as well as other assets such as cars, boats, jewellery and mobile
phones was seized.
These discoveries also occurred in parallel to the increase in the smuggling of contraband goods
such as alcohol and tobacco. This observation brings forth a correlation between border closure
and the rise in the discovery of smuggling incidents and the amount of products being smuggled
into Brunei Darussalam.
Drug smuggling offences cases
a. In September 2020, the Brunei Narcotics Control Bureau (NCB) recorded its largest
ever confiscation of drugs, money and property. In an operation called ‘Musang King’, the
NCB raided residential homes and arrested several individuals believed to be involved in a
family drug business network suspected to be the largest supplier of methamphetamine in
Brunei.
The operation saw the seizure of 19 kilograms of methamphetamine with an estimated market
value of more than BND 3,700,000 (USD 2,779,833).
Other significant items seized included foreign currencies amounting to more than BND
250,000 (USD 187,828), various gold jewellery items, handbags and watches, gym and
electronic equipment, home furniture, 13 cars, two boats and one motorcycle. Also found, were
202 cartons of various brands of cigarettes. The case is currently still under investigation.
b. In May 2020, the NCB conducted the seizure of 100 pills believed to be ecstasy, 155g
of ketamine and cash from an individual attempting to smuggle it into the jurisdiction through
a border control post. The suspect was driving a vehicle owned by a locally registered
forwarding agency (parcel runner). The estimated value of the seized narcotics totals about
BND 25,000 (USD 18,782).
Alcohol and tobacco smuggling cases
a. In December 2020, an Indonesian national was found to be guilty of the illegal
possession of 12 boxes, 480 cartons and 10 packets of various brands of cigarettes. He was
fined BND 460,000 (USD 345,626) or to serve 35 months’ jail in default of payment. The
cigarettes were found to be hidden in the person’s house.
b. In November 2020, two men were ordered to settle fines well over BND 100,000 (USD
75,138) after pleading guilty for possessing large amounts of smuggled cigarettes.
APG Typologies Report 2021 106
A 29-year-old local man was fined BND 170,000 (USD 127,748) and would have to serve 23
months’ jail in default of payment after he pleaded guilty to the charge. He was found to have
kept 537 cartons and 107 packets of cigarettes in his car when the authorities inspected his
house in March 2020.
A foreign national was ordered to settle a fine of BND 105,000 (USD 78,902) for possessing
smuggled cigarettes and beer. He would have to serve 23 months’ jail in default of payment of
the fine after he pleaded guilty to the charge and admitted that he was caught red handed by the
authorities while driving his vehicle in Pekan Bangar, Temburong District. He was found with
125 cartons of cigarettes in his vehicle and further inspection at his home in Kampong Subok
revealed he had kept four cartons of beer without an import permit.

Chinese Taipei
Case One
Mr. C is a recidivist of fraud with several criminal convictions on his record. During the
COVID-19 pandemic, he impersonated a foreign tycoon Mr. Y’s secretary, and phoned the
CEO of a Chinese Taipei mask manufacturing company M, claiming that he wanted to order
5,000 adult masks, 5,000 children masks, and 100 boxes of alcohol swabs as gifts for medical
staff in U hospital. Besides this, in order to convince the CEO of M, Mr. C provided U hospital’s
address to company M as the shipping address. However, he gave his phone number to
company M as a contact. When those masks and alcohol swabs arrived, Mr. C then intercepted
the goods for his own private use. The Prosecutors’ Office prosecuted Mr. C for violations of
the Criminal Code in August 2020.
Case Two
The Telecommunications Investigation Corps of CIB received information about illegal sellers
on the Internet who lied to consumers while selling medical-grade masks. Consumers found
that the quality was different after purchasing, so they reported to the police. In order to prevent
inferior medical masks from being sold in the market, the Telecommunications Investigation
Corps of CIB and Lukang Branch of the Changhua County Police Department jointly organised
a project and reported to the Prosecutor's Office.
The taskforce analysed the above-mentioned intelligence and relevant information then arrested
an online seller person A in Yunlin County. According to the confession by the seller person
A, the taskforce continued to trace its upstream shipping merchant person B, and searched his
residence in Taichung City, and seized 20 boxes of fake and inferior masks on the spot. The
taskforce continued to trace the source of the fake and inferior masks. It was discovered that
the source of the goods was supplied by the suspect person C.
After the collection of evidence in this case was complete, the undertaking prosecutor
commanded the taskforce to conduct a search on the suspect person C’s factory. It is found that
person C is a mask manufacturer. He used the opportunity of importing mask machine
equipment from China to falsely claim to be a national team mask machine manufacturer, and
using the reason of testing the yield rate of masks to produce a large number of masks which
claimed to be medical masks. Then he sold them wholesale to online sellers for profit. The
taskforce seized 440 boxes of finished masks and account books on the spot. In this case, a total
of 1.15 million fake and inferior masks were seized. The whole case was transferred to the
Prosecutor’s Office on suspicion of violating the Special Act for Prevention, Relief and

APG Typologies Report 2021 107

Revitalization Measures for Severe Pneumonia with Novel Pathogens and special regulations
for rescue and promotion, criminal law of fraud and pharmaceutical law.

Fiji
In March 2020, the Fiji FIU issued a press release advising members of the public to be aware
of Covid-19 related online scams. Fiji FIU received a report of a product scam connected to
COVID-19 whereby a local pharmaceutical company paid for an order of PPE it never received.
The FIU also received a report of a fake foreign entity attempting to engage with a local
accounting firm to facilitate payments for PPE. The local accounting firm was advised not to
engage with the entity and cease all communications.

Hong Kong, China

With the support of the Hong Kong Monetary Authority, the Hong Kong Association of Banks
(HKAB) held a sharing session on "Impact of COVID-19 Pandemic from AML and/or other
Financial Crime Risk Perspective" in September 2020 to share financial crime trends observed
and challenges encountered during COVID-19, and good practices of banks in managing and
mitigating ML/TF risks. The information shared was based on member banks' responses to a
questionnaire distributed by HKAB to collect the industry's observations and experiences amid
the pandemic. Following the sharing session, a summary of the responses was circulated to the
industry to help individual banks in identifying suspicious accounts and undertaking mitigating
measures where appropriate. The summary includes, among others, key observations on
financial crime trends as below:

Trends in Criminal Activities

Types of fraud

 COVID-19 related: Sales fraud on personal protective equipment / pharmaceutical

products especially via online or via social media, fake charities set up to receive
pandemic-related fundraising donations, fraud to take advantage of anti-pandemic fund.
 Others: Romance scam, telephone deception (e.g. impersonation of government
officials/ bank staff), investment frauds, business email compromise (BEC) frauds.

Modus Operandi / Commonalities regarding the Opening / Usage of Mule Accounts

 Due to difficulties for non-HK residents to visit Hong Kong, China owing to travel
restrictions and quarantine requirements worldwide, there was a shift in profile of
accounts opened by suspected money mules from individuals of a particular nationality
on short-term stays in Hong Kong to domestic helpers based in Hong Kong and Hong
Kong residents with vulnerable background.
 Dormant accounts receiving surge in deposits marked as pandemic-related fundraising
or donations.
 Surge in transaction volume during COVID-19 period, temporary repository, via cash
/ faster payment system (FPS) and online banking platform. The frequency and pattern
of transactions were not in line with the customer’s stated purpose of account and/or
nature of business.
APG Typologies Report 2021 108
  Some mule accounts with one beneficiary owner were opened within one year and the
initial transactions were related to personal protective equipment sales to other
jurisdictions, which were not consistent with the business areas provided in the CDD
profiles.
Case 1
The government implemented subsidy schemes for businesses affected by the COVID-19
pandemic. Eighteen persons who had made fraudulent subsidy applications by submitting false
information and forged documents purporting that the alleged businesses were in actual
operation before the specified dates were arrested for ‘Fraud’ with over HKD 6 million (USD
772,444) involved. An investigation is ongoing.
Case 2
In response to online advertisements of the sale of surgical masks and medical equipment, an
owner of a healthcare products trading company in Hong Kong, China was deceived to transfer
HKD 450,000 (USD 57,936) into various accounts in Hong Kong and Jurisdiction X and
bitcoin equivalent to HKD 4 million (USD 514,963) to virtual asset accounts held by the
scammers. All of the scammers became out of reach after receiving the payment. An
investigation is ongoing.

Indonesia
According to PPATK Research related to ML/TF Risks related to the COVID 19 Pandemic,
there were cases of Business Email Compromise (BEC) fraud committed by Indonesian citizens
by involving companies in the management and maintenance of medical equipment in
Jurisdiction X. The company entered into a cooperation contract to purchase 1,500 lung
ventilators and 5,000 multi-parameter monitors with companies in Jurisdiction Y with a total
value of EUR 17,011,980 (USD 20,643,657). The method used by the perpetrators was to
establish several companies with Indonesian legal entities that were engaged in trading
laboratory, pharmaceutical and medical equipment with names similar to those of the
Jurisdiction X company's business counterpart in Jurisdiction Y. The perpetrator also opened
an account in the name of the company at a bank in Indonesia. Furthermore, by using a fake
email domain similar to the corporate email domain in Jurisdiction Y, the perpetrator sent
information on changes to payment bank accounts on the grounds of the COVID-19 situation,
causing companies in Italy to send funds to fake company accounts in Indonesia totalling IDR
58.8 billion (USD 4,116,254) in three incoming SWIFT transactions.
In the adjacent period, the total incoming funds of IDR 2.7 billion (USD 189,105) were
transferred to several company accounts where the funds were held and transferred to many
individual parties in 72 transactions for further cash withdrawal transactions leaving only a
minimal balance in the account. Meanwhile, the remaining funds of IDR 56.1 billion
(USD 3,928,718) were successfully postponed by the financial services provider.

Macao, China
For the financial sector (excluding the insurance sector), a study was conducted to understand
the impact of emerging risks related to COVID-19 from an AML/CFT perspective on the sector
in July 2020. The result revealed that there was no material impact on the AML systems of the
APG Typologies Report 2021 109
financial institutions and they resumed normal operations swiftly since the pandemic in Macao,
China was adequately controlled at its early stage. Financial institutions did not identify any
emerging ML/TF trends or typologies specifically related to COVID-19, but were aware of an
increase in the number of internet fraud cases. The Monetary Authority of Macao, China
reminded financial institutions to remain vigilant to detect suspicious transactions and the
related ML/TF risk trends and typologies in other jurisdictions.
For the insurance sector, due to strict border-control during the COVID-19 pandemic, an
insurance referral business was launched by insurers, of which non-resident customers were
referred by brokers or third parties out of Macao, China. As the selling would be carried out by
salesmen in Macao, China, the risk associated with such transactions would inevitably be
increased. However, such ML risk was controllable as long as the required CDD/EDD
procedures were well implemented. As for the potential risk on market conduct, a mechanism
of close communication with and on-going monitoring of involved insurers had been
established and a new declaration form has been adopted to ensure customers are well aware
of potential associated risks. Further, insurers were requested to submit regular reporting of
referral business status to the Monetary Authority of Macao, China for review of any
irregularities.

Malaysia
Consistent with the change in the global threat landscape as a result of the COVID-19
pandemic, Malaysia also observed emerging crimes and/or an increase in fraud activities
particularly linked to the counterfeiting of medical goods e.g. PPE and face masks, as well as
cybercrime, illegal online gambling, the smuggling of cigarettes, illegal investment scheme’s
online promotional activities and drug trafficking. The growth in the amount of cybercrime is
attributed to the increase in internet-related activities in the jurisdiction, with criminals
increasingly leveraging on the uncertainties during the pandemic to exploit victims’ financial
insecurities.
Case study 1: Counterfeiting of Medical Goods
FIU Malaysia received a request for information from a jurisdiction in Europe (Jurisdiction A)
concerning a suspected facemask scam amid the COVID-19 pandemic. Approximately EUR 5
million (USD 6,088,976) was transferred by a government agency in Jurisdiction A to an entity
in Jurisdiction A, namely Company ABC for the purchase of facemasks from Jurisdiction B. It
was discovered that only a portion of the facemasks was delivered where all were found to be
unfit for hospital use. Financial intelligence gathered by Jurisdiction A later revealed that
Company ABC may have subsequently transferred a significant amount of money intended for
facemask purchase to another entity, namely Company XYZ in Malaysia. Further transaction
review of the company account also revealed an inward remittance received by Company XYZ
from an entity located in Jurisdiction C with transaction remarks that may potentially indicate
facemask related transactions. Within the same day, another large sum of monies amounting to
approximately USD 150 000 was received from Company DEF, another entity in Jurisdiction
A, believed to be engaging in sales of healthcare products including gloves, goggles and hearing
protection. The funds received by company XYZ were observed to have been disbursed to
various entities in Jurisdiction C and Jurisdiction D.

APG Typologies Report 2021 110

Case study 2: Counterfeiting of Medical Goods
FIU Malaysia received a request for information from a jurisdiction in Europe (Jurisdiction E)
concerning suspected fraud with protective equipment for testing of COVID19. A national
health agency in Jurisdiction E received a commercial proposal from Company OPQ in
Jurisdiction E, to purchase protective equipment for testing of COVID-19 worth millions of
euros. Company OPQ had defrauded the national health agency in Jurisdiction E into signing
a contract for equipment of a higher price by providing false product information. Financial
intelligence gathered by Jurisdiction E later revealed that Company OPQ may have
subsequently transferred EUR 6.05 million (USD 7,367,814) intended for the purchase of
protective equipment for testing of COVID-19 through networks of companies involving
companies in Jurisdiction E and two neighbouring jurisdictions and eventually to another
entity, namely Company RST in Malaysia. A transaction review of the company account
revealed a pattern of rapid and high frequency of incoming and outgoing transactions involving
multiple counterparties consisting of inward SWIFT and foreign wire transfers. Further review
of the account revealed that Company RST received an inward remittance from Company
UVW which was based in one of the neighbouring jurisdictions. Funds received were later
transferred to entities outside Malaysia via wire transfers.

APG Typologies Report 2021 111

Mongolia
As per the observation and based on the statistics of STRs received by FIU-Mongolia from
reporting entities in 2020, the number of suspicious transactions related to online gambling has
escalated steadily. While the total number of STRs related to online gambling submitted by
reporting entities was 42 in 2019, this number increased to 362 in 2020. It is presumed that this
type of activity has been increasing on an unprecedented scale due to the impact of the
pandemic and quarantine measures as some people are not being able to earn income as before
and are willing to make money easily from home regardless of its illegal nature. “Organizing
gambling” is considered as a crime under Article 20.17 of the Criminal Code of Mongolia.

New Zealand
Abuse of Covid-19 government stimulus measures
Between March and December 2020, the FIU received more than 450 SARs relating
specifically to suspected abuse of government COVID-19 financial subsidies, detailing tens of
millions of NZD worth of suspicious transactions. The predominant themes and trends within
these SARs include:
 Individuals with either no known employment or who received unemployment
benefits receiving wage subsidies credited to their accounts. A significant number
of these individuals are adversely recorded in police systems for prior involvement
in dishonesty offending, drugs, and in some cases organised crime.
 Businesses claiming wage subsidies for their employees but not passing the
payments on to the employees, instead using the funds for personal or miscellaneous
expenditure.

APG Typologies Report 2021 112

  Newly incorporated companies, with little to no identifiable trading profile,
receiving wage subsidies.
 Individuals with no known employment or business links receiving multiple wage
subsidies seemingly intended for multiple recipients, with these funds then
withdrawn as cash, transferred to third party accounts, or sent offshore.
 Individuals with no known business associations receiving Inland Revenue (IR)
‘small business loan’ payments to their accounts; with the funds then withdrawn as
cash, transferred to third party accounts or sent offshore.
 Individuals receiving IR small business loans when their only source of funds
appears to be wages (i.e. they appear to be an employee rather than an employer and
would therefore be ineligible for the loan)

Philippines
1. Fraudsters pretending to be affiliated with government units in soliciting Covid-19 donations
from victims
Local Government Unit
A certain account, opened last 27 May 2020 under the name of an alleged fraudster, is
purportedly being used to solicit donations or funds for COVID-19 using the name of the
current governor of a certain province in Luzon. The solicited funds were deposited to the bank
account of the fraudster. A review of the transactions shows that large cash deposits totalling
PHP 622,000 (USD 13,004) were made into the account with subsequent same day
withdrawals. It was also observed that frequent balance inquiries in one day were made by the
alleged fraudster. Breakdown of material information is as follows: (1) review of documents
gathered showed that the alleged fraudster is a TNVS41 driver with gross monthly income
between PHP 20,000 (USD 418) and PHP 50,000 (USD 1,045), which is the only source of
funds as declared during the onboarding process. An open source search identified a social
media post of another government agency regarding an advisory against a similarly named
individual (alleged fraudster) who is using the name of the agency’s Executive Director to
solicit donations supposedly intended for Taal Volcano victims and that the donations were
being deposited to another bank account of the fraudster.

41
Transport Network Vehicle Service or TNVS is the term used to describe a Public Utility Vehicle accredited
with a Transport Network Corporation (TNC), which is granted authority or franchise by the LTFRB to run a
public transport service. A TNC is an organization that provides pre-arranged transportation services for
compensation using an internet-based technology application or digital platform technology to connect
passengers with drivers using their personal vehicle. Example of TNC are Grab Philippines and Angkas.
Accessed from https://ltfrb.gov.ph/wp-content/uploads/2020/06/DO-2017-011-1.pdf on 8 October 2020.

APG Typologies Report 2021 113

Domestic Government Agency

Allegedly, the perpetrators are two females and one male, posing as employees of the
Department of Public Works and Highways (DPWH), while the victim is an
engineer/contractor in a regional office of DPWH. On 20 April 2020, the victim received a call
from a female, who introduced herself as part of the staff of one of DPWH’s regional offices.
After telling the victim that the DWPH regional director (DRD) wanted to speak with the
victim, the caller passed the phone to another woman, who pretended to be the DRD. The fake
DRD informed the victim that the DPWH undersecretary was planning to give subsidies or
relief packs to their employees relative to the COVID-19 pandemic. To augment this plan, the
victim was told to raise funds, amounting to PHP 150,000 (USD 3,136), and to deposit the
money directly into the undersecretary’s bank account in Manila. Due to time constraints, the
victim was advised to send the funds through an MSB instead of a bank. The fake DRD
provided the name and the mobile number of the recipient of the funds—a male accomplice,
who was introduced as the undersecretary’s personnel. The victim sent PHP 150,000 (USD
3,136) through the MSB branch in Catbalogan City, Samar and texted the fake male personnel
that the money was available for pickup. The victim then received text notifications that the
remittances were claimed by the recipient in several branches in the province of Rizal.
2. Swindling/estafa (various product scams)
Confidential information indicates there has been overpricing and unauthorised selling of
medical items, such as alcohol, medical masks, and thermal scanners. Moreover, other fake or
bogus sellers took the crisis as an opportunity to scam victims into buying essential items. Most
often, offenders will post items for sale in their social media account/s. After receiving the
advanced payment from the buyer/victim, the seller/offender cuts off communication and
blocks the buyer/victim in social media. The majority of these transactions involve local buyers
and sellers. While violators were located in various cities and provinces in the jurisdiction, a
substantial concentration of violators was observed in the National Capital Region (NCR).
3. Donation scam (social media influencer)
Perpetrators set up a faux donation campaign in social media platforms to solicit funds from
the public. During the enhanced community quarantine (ECQ), a purported social media
influencer became popular for his social media challenge, where he posts his alleged donations

APG Typologies Report 2021 114

to COVID-19 relief efforts and encourages the upper class to donate. Based on information
gathered from different sources, this person uses fictitious identities in order to deceive people
and has been allegedly charged with various "swindling"/estafa cases over the years.
1. Possible terrorism financing activities linked to COVID-19
A group allegedly staged a protest rally demanding for the release of relief goods (food support)
during the ECQ, as they claimed that they have not received any support from their local
government unit (LGU). The said protest rally was purportedly organised and premeditated by
two left-leaning organisations (LLOs) and other allied personalities to alienate the government
from the marginalised community and agitate them to sow chaos and disorder in order to
portray that the present government is incapable of governing during the COVID-19 crisis.

As the crowds became unruly, some protesters were arrested and charged with criminal
offences, including violation of ECQ rules, and resistance and disobedience to lawful order.
The accused were temporarily released from jail after posting bail bonds. Their legal counsel
claimed that the money used to cover the cost of bail was sourced through online fundraising
for legal assistance services. The said legal counsel claimed to have solicited money via social
media and asked donors to deposit their donations in two bank accounts and through web-based
donation/shopping platforms.
The LGU denied the allegation that there was no food support distributed to this group. Further,
the arrested protesters appeared to be non-residents of the concerned LGU and were identified
as members of the two LLOs associated with a communist group (CG) and its armed-wing
group (AWG). The bank accounts used to solicit funds were also identified to be common
depository bank accounts used by the allies and LLOs of CG and AWG for their fundraising
activity.
1. Possible bulk cash smuggling using cruise ships
One notable attempted transaction was reported due to a deviation from the client’s usual
activity. The client requested the bank to pick up bulk foreign currency cash from a cruise ship
docked at a Philippine port via a deposit pick up arrangement (DPA). The amount will then be
deposited in the client’s foreign currency account maintained in the local bank. This kind of
transaction is usually done via telegraphic transfer from a bank abroad, but because of COVID-
19 concerns, the client requested the funds to be picked up by the bank under the DPA. The
amount involved, however, is above the average daily foreign currency volume of the client.
Further, the client could not present any document as proof of source of funds.
2. Possible fraud - NPO to receive Covid-19 funds from suspected shell company
A non-profit organization (NPO) opened an account on 15 July 2020 for the purpose of
accepting donations. The NPO stated that the account will also be used for their operating
expenses, and funds relating to charitable works. As per the NPO’s website, its advocacy is to
APG Typologies Report 2021 115
conduct Bible studies. Aside from account opening, the NPO also inquired about the
documentary requirements if it is expecting to receive a donation of EUR 10 million (USD
12,143,443) from a company overseas. The NPO submitted a memorandum of agreement
whereby it was stated that the company will be partnering with the NPO in a worldwide
corporate social responsibility programme on the prevention of the COVID-19 pandemic and
improvement of the quality of life and overall health situation in the Philippines, among others.
While no actual credit has been made, it was noted that the documents provided are insufficient
to support the large amount of funds expected to be received.
3. Continuous financial transactions despite business affected by lockdown
Fish Trading
A female client declared her fishing business as source of funds. Her account was noted to have
170 transactions from 15 November 2019 to 26 May 2020, ranging from PHP 50 (USD 1) to
PHP 1,000,000 (USD 20,906) with a total value of PHP 41 million (USD 857,210). The client
claimed that the transactions were related to the purchase of fingerlings as her business is fish
trading. However, as noted by the bank, the transactions were mostly made during the ECQ,
when all commercial flights and sea travels are prohibited. Moreover, the client was unable to
present any document to support her claim.
Food court and restaurant
A corporate client is involved in the food court and restaurant business, and it was observed
that between 21 January 2020 and 24 June 2020, there were 90 cash deposits into the client’s
account, ranging from PHP 183,103 (USD 3,828) to PHP 5,411,042 (USD 113,124), with a
total value of PHP 140 million (USD 2,926,923). The bank requested for documents to support
the substantial cash transactions. The client presented cash transmittal slips, but the branch
confirmed that these were not enough to support the cash deposits. The bank also observed that
the transactions were mostly made during the ECQ, when most restaurants are not allowed to
operate.
4. Large transactions purportedly received from government units as payment for Covid-19
related products and services
Food pack
The subject is an owner of a construction and general merchandising business. On 30 July 2020,
the subject’s personal account received a fund transfer from a third-party account amounting
to PHP 53 million (USD 1,106,822). According to the subject, this amount is inclusive of the
PHP 21.8 million (USD 455,262), which the third-party claimed to be payment received from
the Tagaytay City Government for food packs related to the 6th wave of COVID-19 ECQ
assistance. It was further said that the entire PHP 53 million (USD 1,106,822) will be used to
finance an alleged joint venture of the subject and the third-party for a real property acquisition.
Hotel Coordination on behalf of a Domestic Government Agency
The subject opened three bank accounts between August 2019 and June 2020 in different
branches with declared source of funds as income from his real estate leasing business. Further,
one of the accounts is a joint account with his wife. On 11 June 2020 and 10 July 2020, three
cash deposits were made into the three different accounts of the subject with total amounts of
PHP 1.2 million (USD 25,054) and PHP 1.05 million (USD 21,922), respectively. As per the
bank’s investigation, the subject said that they were coordinators for the Overseas Workers
Welfare Administration (OWWA) and partner hotels, where Overseas Filipino Workers (OFW)
APG Typologies Report 2021 116
are being booked for quarantine. The subject further added that they also coordinate with the
caterers and disinfection service providers. The subject disclosed that they have no signed
contract with the OWWA and that the funds deposited were payment of the hotels, which would
then be used to pay the service providers. Red flags included: (1) inability to provide acceptable
supporting documents for the transactions with OWWA, (2) the nature of the transaction
deviates from the declared source of funds during account opening, and (3) the amount of
transactions appears to be structured.
5. Large cash deposit allegedly for COVID-19 donation for residents of a province in
Mindanao
The subject opened a savings account in Iligan City on 25 November 2019 to serve as a
settlement account for her insurance account. As per a declaration of the subject, she owns a
jewelry shop, but her gross monthly income was not recorded in the system. The subject is the
sibling of another bank client whose account was also opened on 25 November 2019 and who
was also reported for suspicious transactions due to attempted significant cash deposits from
unknown sources. On 7 May 2020, a certain blacklisted individual attempted to deposit PHP
4.5 million (USD 93,971) into the subject’s account. The blacklisted individual is the same
person who conducted the transactions in the account of the subject’s sibling. The blacklisted
individual claimed that the funds were donations accumulated due to the ECQ and the funds
were intended for the people of Marawi City. The branch, however, denied the deposit for lack
of supporting documents. Financial review of the subject’s account from 25 November 2019 to
22 May 2020 showed 14 cash deposits ranging from PHP 2,000 (USD 41) to PHP 246,000
(USD 5,137), totalling PHP 1,473,000 (USD 30,756). According to the branch, these deposits
are cash assistance from the subject’s relatives intended for her living expenses. Funds
withdrawn via ATM totaled PHP 471,000 (USD 9,833) and online payments and purchases via
Express Payment System (EPS) totaled PHP 195,665 (USD 4,084). The subject’s current
account balance is PHP 406,782 (USD 8,493).
6. Unsubstantiated deposits based on declared business and source of funds
From ready-to-wear (RTW) business to lending
On 18 January 2019, the subject opened a savings account in Pampanga. The subject’s declared
source of funds was from a ready-to-wear (RTW) business. On 29 April 2020, a representative
made a deposit of PHP 499,000 (USD 10,419) into the subject’s account at Juan Luna Branch
in Cebu City and another deposit on 14 May 2020 for PHP 500,000 (USD 10,440). The branch
called the client to verify the source of funds, and based on the interview, the client disclosed
that during the ECQ she engaged in a small lending business, which involved mostly cash and
unsecured transactions since most of the malls are not open. She advised the branch that she
will forward a copy of her Department of Trade and Industry (DTI) renewal certificate as a
supporting document and other records to support the significant deposits. On 29 May 2020,
her account was tagged as high risk due to the change in her nature of business and source of
funds. Since then, the branch is unable to contact the client, and after several attempts, the client
has yet to provide enough supporting documents to justify the source of funds.
From seafood trading to second-hand car trading
The subject opened a current account on 30 June 2020 with an initial deposit of PHP 25,000
(USD 521) and declared source of funds as income from a seafood trading business. However,
due to the pandemic, the subject shifted to being a freelance agent of second-hand cars. As per
the result of a transactional review covering 1 July to 13 August 2020, notable transactions on
the account include: (1) 47 cash deposits ranging from PHP 500 (USD 10) to PHP 1.37 million
APG Typologies Report 2021 117
(USD 28,604), totalling PHP 9 million (USD 187,912); (2) 130 Instapay remittances, totalling
PHP 2.47 million (USD 51,566); and (3) 11 local cheque deposits, totalling PHP 1.9 million
(USD 39,641). As per the subject, the aforementioned deposits and remittances were payments
from the selling of second-hand cars. Subsequently, the subject made cheque issuances totalling
PHP 11 million (USD 229,572), payable to a certain company that accordingly owns the
second-hand cars. The bank requested the subject to provide deed/s of sale or other proof of
transaction, but the subject claimed that he was just a middleman/freelance agent of the
aforementioned transactions and cannot provide any documents. As per open source, the
aforementioned company, who allegedly owns the second-hand cars, was selling/leasing
disinfection stations.
PEP engaging in second-hand car trading
The subject opened a premium cheque account on 15 February 2010 with an initial deposit of
PHP 400,000 (USD 8,345) and declared salary as municipal mayor of a northern province as
source of funds. It has been noted that during the transactional review covering April to June
2020, the subject had total deposits of PHP 4.36 million (USD 90,957) in cash and PHP 3.4
million (USD 70,930) in cheques. Subsequently, these amounts were used to issue cheques
payable to a certain third-party. As per the bank’s telephone conversation with the subject, the
deposits were from his buying and selling of used cars and construction business. However, the
subject stated that both businesses have no business documents. Further, the subject allegedly
referred to the third-party as a business partner. The subject presented copies of deeds of
absolute sale for the two vehicles he recently purchased.
7. Abusing digital KYC/CDD to create suspected pass-through/money mule/smurfing accounts

More than 2,000 newly on-boarded e-money customers made multiple high value transfers,
totalling PHP 180 million (USD 3,755,876), to third-party bank accounts. These transfers were
transacted in a span of less than six months. Majority of the customers were on-boarded
between July 2019 and February 2020. Most were identified to be residents of various provinces
in Luzon. These account holders were profiled as tricycle drivers, loading station owners,
freelancers, sari-sari store owners, fruit vendors, and private employees, who declared business
APG Typologies Report 2021 118
proceeds and salaries as source of funds. Suspicious indicators involving these accounts are as
follows: (a) high value deposits from unidentified sources received in one day via certain
financial technology (fintech) or payment system companies; (b) activities appear excessive
considering the customers’ profiles; (c) layering concerns as evidenced by the rapid movement
of funds through subsequent cash withdrawals and transfers to a third party account; (d)
majority of the customers’ KYC videos have similar backgrounds; and (e) consecutive mobile
numbers were registered in succession. Other notable activities seen are online purchases at an
online furniture shop abroad.

In addition to the abovementioned case, between 1 March and 30 May 2020, an Electronic
Money Issuer (EMI) reported 2,933 STRs related to suspected money mules or smurfers. These
transactions have an estimated value of PHP 18.89 million (USD 393,956) transacted in less
than four months. Individuals, usually using the same mobile phone, use different mobile
numbers to create multiple e-wallet accounts. Once the e-wallet is created, individuals would
cash-in via convenience stores on separate dates with only a few days apart. Another cash-in
method is through another EMI, which is different from the EMI that issued the e-wallet. On
the same day of credit to the e-wallets, the funds were subsequently transferred to several bank
accounts and/or other e-wallets through Instapay. Transactions were also geographically
concentrated in areas in Davao del Sur, Davao del Norte, Pangasinan, Ilocos Norte, Tarlac,
Negros Occidental, Siquijor, Laguna, Zamboanga, Quezon City, and the City of Manila. Most
account holders’ declared occupation was student, while one was an employee of a convenience
store.

Singapore
TBML from Purchase Order Scams
The Singapore Police Force have observed a re-emergence of purchase order scams, whereby
scammers would pose as procurement officers from local universities or government agencies,
and induce unsuspecting companies into delivering goods with false promises of payments at
a later date. These illicit goods were then sent to foreign jurisdictions, which may then
constitute as trade-based money laundering into these foreign jurisdictions.
APG Typologies Report 2021 119
The said companies would receive e-mails purportedly sent by a procurement officer from a
local university or Government agency such as the Ministry of Health (MOH), asking for
quotations for electronics, IT-related items or medical devices. The scammers would use e-
mails bearing the template ‘procurement@___ -sg.com’ or ‘purchasing@___,org’ to convince
the companies that they were genuine.
Once an agreement has been made, a purchase order (PO) would be sent to the company via
email. Believing that they had received a genuine PO, the company would deliver the goods to
the delivery address indicated in the PO. The delivery address indicated in the POs of such
scams usually belonged to freight forwarding companies engaged by the scammers to ship the
illicit goods overseas, including to the United Kingdom, Gambia, and Nigeria. No payments
were eventually received.
For the second half of 2020, the Police have received at least thirteen reports of such scams,
with total losses amounting to at least SGD 909,000 (approximately USD 684,970). Where
timely information was provided to the Police, the Police managed to successfully intercept
some goods before its intended shipment.

9.2 Displacement of ML or TF methodologies to established typologies (e.g.

increase in reporting of the internet for ML/TF as use of cash decreases, impact
of lockdowns and border closures on smuggling and trafficking, etc.).
Australia
The impact of hard international border closures on the counter terrorism space in Australian
law enforcement has been significant, with POIs and potential POIs wishing to travel to conflict
zones and neighbouring regions no longer possible. While this has the immediate effect of
reducing the movement of physical currency which may have been used to finance terrorism,
Australian authorities remain alert to wire transfers and remittances to jurisdictions of concern.

9.3 Any research or reports conducted on the impact of pandemics, natural

disasters or economic crises on ML/TF trends and typologies.
Hong Kong, China
The Joint Financial Intelligence Unit of Hong Kong, China conducted in-depth thematic
analyses and holistic reviews on selected STRs, FIU to FIU exchanged information and other
information from various sources on prevalent crime trends with reference to the overall ML/TF
threat and vulnerability in Hong Kong, China including crimes arose from the ML/TF trends
linked to COVID-19.
Besides, the Fraud & Money Laundering Intelligence Taskforce (FMLIT) published alerts on
COVID-19-related fraud and deception cases in 2020, which were shared with local institutions
and overseas agencies. Anti-scam messages and publicity campaigns had also been published
on various social media platforms to raise public awareness.

APG Typologies Report 2021 120

Malaysia
In 2020, Central Bank of Malaysia produced a series of advisories to selected industries on
COVID-19 related crimes, ML/TF trends and red flags to assist in transaction monitoring and
detection of suspicious transactions during the pandemic.
This includes the COVID-19 related scams published by the Securities Commission Malaysia
in the form of videos/infographics to the public as well as the alerts issued by the Labuan
Financial Services Authority to its reporting institutions on areas such as AML/CFT monitoring
of emerging risks & threats arising from COVID-19, advice on CDD measures and reminder
on STR lodgement obligations.

APG Typologies Report 2021 121

10. ABBREVIATIONS AND ACRONYMS
ABF Australian Border Force
AFP Australian Federal Police
AML Anti-Money Laundering
AMLA Anti-Money Laundering Act
AMLC Anti- Money Laundering Council
APG Asia/Pacific Group on Money Laundering
ATM Automatic Teller Machine
AUSTRAC Australian Transaction Reports and Analysis Centre
C&ED Customs and Excise Department (Hong Kong, China)
CDD Customer Due Diligence
CFT Countering the Financing of Terrorism
CTR Cash/ Currency Transaction Report
DNFBP Designated Non-Financial Businesses and Professions
EAG Eurasian Group
FATF Financial Action Task Force
FINTRAC Financial Transactions Reports Analysis Centre (Canada)
FIU Financial Intelligence Unit
FMU Financial Monitoring Unit (Pakistan)
FPTBTS Fictitious tax invoices (Indonesia)
FSRB FATF-Style Regional Bodies
GIF Financial Intelligence Office (Macao, China)
HT Human Trafficking
IDR Indonesian Rupiah
ICRG International Cooperation Review Group
IFTI International Funds Transaction Instruction
INTERPOL International Criminal Police Organisation
JAFIC Japan Financial Intelligence Center
KYC Know Your Customer
LEA Law Enforcement Agency
ML Money Laundering
MR Money Remitter
MSP Money Service Provider
NCC National Coordination Committee to Counter Money Laundering (Malaysia)
NGO Non-Government Organisation
NPO Non-Profit Organisations
NRA National Risk Assessment
PS People Smuggling
PEP Politically Exposed Person
PKR Pakistan Rupee
POI Person of Interest
RI Reporting Institutions
SAR Suspicious Activity Report
SEC Securities and Exchange Commission (Philippines)
STR Suspicious Transactions Report
SVF Stored Value Facilities
TF Terrorist Financing
VAT Value Added Tax

APG Typologies Report 2021 122