Anti Money Laundering Game

The AMLC and Price Waterhouse Coopers (PwC)[1] have jointly developed a new anti-money laundering game: the AML pressure cooker. The game was developed to make private parties that may unwittingly get involved in money laundering systems, such as webstores, aware of the adverse consequences of money laundering. The pressure cooker is a great example of public-private partnership in the fight against money laundering. By publishing this article, we hope to inspire our international partners.

What is the pressure cooker?
The pressure cooker involves players taking on the role of advisers of a fictitious company called NaBook. The advisers help NaBook to find out whether and, if so, how, NaBook has unwittingly been used by criminals for money laundering purposes. All players receive some starting information and, during the game, they get access to a dashboard containing loads of data. Players have to find solutions within the span of 60 minutes. The goal of the game is to learn to work using a hypothesis-oriented approach and to obtain knowledge about money laundering.

Basic information
Prior to starting the game, all players receive some basic information on the NaBook company and about the methods deployed by criminals when they wish to launder their illegal assets. Criminals wish to have funds enter the financial system, to conceal the origin of the funds, and to present justification for their possession of the criminal assets, allowing them to spend it without issue. All players are informed that NaBook is a Dutch company that originally was established as a second-hand book store. At some point, a webstore was built in order to be able to also sell books via the Internet. The company witnessed rapid growth, making NaBook interesting for other book stores, as well. At present, NaBook’s business model is comprised of multiple pillars: the sale of second-hand books provided by hundreds of thrift shops, the sale of unsellable second-hand books to recyclers, and the provision of a platform for the online sale of books by other book stores. All sales via the NaBook webstore are conducted using an online payment system. Payments are made by NaBook to the book store in bulk, with NaBook withholding a fee. The book store is itself responsible for the shipping of books, so NaBook has no control over this.

Course of the game
The game starts with an urgent call by NaBook’s CEO. Next, all players form subgroups. The various groups must first formulate hypotheses on how use can be made of NaBook in money laundering systems. The players require the basic information about NaBook and money laundering to formulate hypotheses. In addition, the PwC and AMLC moderators provide hints to the various subgroups. The groups are then given access to a dashboard containing all sorts of data on the company NaBook: Which publishers use the platform, how many books are sold by those publishers and against what prices, what bank accounts are used to purchase books, etc. The data are reviewed on the basis of the hypotheses formulated by the group, which are then verified or falsified. Next, the various groups meet up again to provide feedback to each other. Each group offers a short pitch, explaining the group’s findings. Next, the way NaBook has been misused and which data could have been considered to identify this are explained in a structured manner. The game is targeted mainly to companies that may unwittingly be abused for money laundering purposes, allowing them to identify the risks present in their business operations and to take mitigating measures.

Public-private partnership
When working on this project, AMLC and PwC had one joint objective: to get as many companies as possible involved in the joint effort to keep out criminals. Everyone was thus on the same wavelength. PwC has a lot of experience in data analysis and has, inter alia, put a lot of energy into constructing a beautiful and highly realistic dashboard. The AMLC presented knowledge and experience collected from investigations in order to create realistic hypotheses. It is exactly because the two worked together that this great result was produced. Of course, each has its own interests and priorities, but having a joint objective in mind means that, in the end, solutions are always found. Some food for thought: how would you like to raise awareness in your own country, and who is an obvious cooperation partner? Reach out and connect!

[1] PwC is an international accounting and tax advisory firm.