The IUP Journal of Bank Management
The Pandora Papers: How Anti-Money Laundering Procedures and Controls Should Have Flagged $300 mn Hidden in New Zealand Trusts

Article Details
Pub. Date : May, 2022
Product Name : The IUP Journal of Bank Management
Product Type : Article
Product Code : IJBM050522
Author Name : Ehi Eric Esoimeme
Availability : YES
Subject/Domain : Finance
Download Format : PDF Format
No. of Pages : 06

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Abstract

This paper aims to discuss the risk-based policies, procedures, and controls reasonably designed to identify and minimize money laundering and other illicit financing risks associated with Non-Profit Organizations (NPOs). This paper uses the "Pandora Papers" to illustrate the vulnerability of the banking system to money laundering and other illicit financing risks associated with NPOs, and to solidify the hypothesis that effective implementation of risk-based policies, procedures, and controls can help flag illicit funds before a lengthy asset recovery process becomes necessary. This paper determines that adequate policies, procedures, and controls, if implemented, could help manage the money laundering and other illicit financing risks associated with NPOs, and ensure monitoring systems are set up to adequately detect suspicious transactions.


Introduction

A trove of leaked documents reviewed by the International Consortium of Investigative Journalists (ICIJ) and 150 media partners provide an unprecedented view of how millions of dollars are secretly moved around the world by individuals and entities under investigation by law enforcement agencies or other designated authorities. Those records are part of the Pandora Papers, a cache of more than 11.9 million documents obtained by the ICIJ. The investors revealed in the leaked documents include offshore trusts holding $300 mn for the Legion of Christ in the wake of the Vatican investigation.1 The trusts holding money for the Legion in New Zealand maintained four Swiss Bank accounts, including one at a Geneva-based bank, Lombard Odier, that the US Justice Department later found had helped American clients


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