Money laundering indicators
Indicators for money laundering can be divided into three subgroups.
Firstly, there are money laundering typologies. A money laundering typology describes the characteristics that point towards money laundering on the basis of experience. An extensive analysis of criminal investigations usually forms the underlying basis. Typologies are internationally established by the FATF and at national level by FIU – the Netherlands [Financial Intelligence Unit-the Netherlands]. The Explanatory Memorandum on money laundering shows that both the Public Prosecution and the Courts may admit money laundering typologies in evidence. Refer to the Parliamentary Papers II 1999/2000, 27159, 3 (Explanatory Memorandum), page 9. FIU – the Netherlands also always publishes the most recent list of typologies on its website.
Generally known facts are facts that everyone is deemed to know. It is a legal concept. Generally known facts do not require evidence according to article 339(2) of the Dutch Code of Criminal Procedure. We included generally known facts in our overview when these have been qualified as such in Dutch case law. The overview lists the source in order to be able to refer to it in official reports, for example.
What remains is the group referred to as other indicators. These are characteristics that point towards the act of money laundering, but they are not a generally known fact, nor have they been established as a typology.
All these categories of money laundering indicators may play an important role both in terms of giving rise to the suspicion of money laundering as well as in providing actual evidence of money laundering. Below is a summary. We start with the money laundering typologies established by FIU – the Netherlands. This is an exhaustive overview. The summary continues by listing the generally known facts and other indicators, all categorised by subject. This is a non-exhaustive overview. We have listed a number of frequently used generally known facts and indicators, however, there are numerous other generally known facts and indicators that could also be applied. We conclude with an overview of FATF reports. These reports show typologies and / or indicators in relation to specific subjects.
Click here for the full overview of money laundering indicators.