Money Laundering and Terrorism in the Middle East - Research Paper Example

 Money Laundering and Terrorism in Middle East Table of Contents I. Background: Money Laundering ………………………………… 3 II. Effect of Money Laundering ……………………………………… 4 III. Money Laundering in the Middle East ………………………..... 5 IV. Money Laundering and Terrorism ………………………………….. 7 V. The Use of Money Laundering Infrastructure in Terrorism ………….. 10 VI. International Response ………………………………………….. 12 VII. Legal Framework and Specific Countermeasures ………………….. 17 VIII. How the US Tackles the Middle Eastern Case ………………….. 19 IX. Conclusion ………………………………………………………….. 20 Today, money laundering has become a commonplace term that generally connotes a criminal act. Since its first use, it now involves a process of concealing the existence, illegal source or illegal application of income, and then disguises that income in order for it to appear “clean” or legitimate. This paper will examine money laundering in the Middle East and its ties with terrorism. Specifically, this will be undertaken in the context of money laundering as previously defined - the act of converting money that is sourced from illegal activities so that it could be spent or consumed. The Middle East was chosen as the location for this research mainly because of its experience with terrorism. Such experience is expected to highlight how money laundering is utilized in terrorist activities considering the amount of available literature on the subject. I. Background: Money Laundering According to Richards (1999), early money-laundering texts suggest that the term “money-laundering” was derived from the practice of the 1920s Chicago mobsters – Al Capone and the like – of buying and operating local laundries with their gambling, rackets and liquor profits.1 Indeed, the word laundering connotes some washing of clothes or cleaning of shirts. The Watergate scandal is responsible for the popular use of money laundering today. It was used by law enforcement officials during the Watergate inquiry and the expression has since been used in the public arena as well as in jurisprudence. For instance, in 1982 it was used in a judicial or legal context in the case of US v. $4 255 625.39 and that since then it has become widely accepted as a term of art at both the international and domestic level.2 In 1990, the European Convention on Laundering, Search, Seizure and Confiscation of the Proceeds for Crime has established the concept, wherein it was underscored that “money laundering is the process of converting or cleansing property knowing that such property is derived from serious crime for the purpose of disguising its origin.”3 The most encompassing definition of money laundering has been developed by the United States Customs Service and to quote: Money laundering is the process whereby proceeds, reasonably believed to have been derived from criminal activity, are transported, transferred, transformed, converted, or intermingled with legitimate funds, for the purpose of concealing or disguising the true nature, source, disposition, movement or ownership of those proceeds. The goal of money laundering process is to make funds derived from, or associated with, illicit activity appear legitimate.4 It is in the context of the above definition that this paper will investigate the money laundering and its relationship with terrorism. II. Effect of Money Laundering The Financial Action Task Force or the FATF, reported that as much as $85 billion could be available annually for laundering and investment from the proceeds of drug trafficking in the US and Europe alone; and, that as far back as March 1998, the US State Department’s Bureau for International Narcotics and Law Enforcement Affairs placed the annual value of laundered funds derived from all crimes at between US$300 and US$500 billion. The sheer enormity of the amount involved underscore the reaches of the illegal activities and crimes involved to generate such money. The International Monetary Fund (IMF) estimated that the present scale of money laundering transactions is almost beyond imagination, which is 2% to 5% of the global gross domestic product (GDP). (21)5 The effect of money laundering, or its implication, is staggering. The current landscape, which can be characterized by the lack of solid global initiative and cooperation to curb the problem, has allowed money laundering to thrive. When dirty money could be easily tracked and confiscated in one country, an individual or an organization could simply wire the money to a bank located in a country with lax money laundering regulations. Such environment encouraged the proliferation of crimes, most of which are drug related. Madinger (2006) stated that the testament to this is the vast quantities of drug money traveling backward along the same routes on which the drugs were imported and because of this, drug problems from all corners of the globe is on a dramatic rise.6 III. Money Laundering in the Middle East The money laundering scandal during the 1990s that surrounded the collapse of the Bank of Credit and Commerce International (BCCI) based in Abu Dhabi continues to hound the Middle Eastern banking and financial industry.7 Before this bank was exposed and brought to answer before the law enforcement authorities, it was a widely perceived as a successful and normal bank with offices in major financial centers across the globe. However, behind its convincing façade, BCCI was a criminal enterprise that catered to some of the most notorious villains of the late twentieth century, including Saddam Hussein, Manuel Noriega, terrorists, among others.8 Grosse (2001) wrote that the broad strategy of BCCI appears to have been to build up a deposit base without paying much attention to the quality of the clients involved and that while it was never proven that the bank was involved directly in cocaine trafficking, there was extensive evidence that BCCI bankers in many locations were willing to turn a blind eye to the sources of money coming into deposits and the uses of those funds when disbursed.9 The BCCI experience, highlighted how the Middle Eastern banking sector has previously became a tool for launderers and terrorists alike. Muslim states today are eager to demonstrate that they are willing to combat money laundering activities through banking reform. As a result of this sentiment, there has been a dramatic reduction of state entities that support terrorists and terrorist organizations.10 For instance, the United Arab Emirates passed into law a new money laundering policy that took effect in January 2002, wherein disclosure becomes mandatory for all cash movements of over $US550.11 There are many reasons for this development and the most fundamental of these include the economic consequences of being labeled as a terrorist sponsor. Another fundamental reason is the Article 51 of the United Nations Charter, which states that: Nothing in the present Charter shall impair the inherent right of individual or collective self-defense if an armed attack occurs against a Member of the United Nations, until the Security Council has taken measures necessary to maintain international peace and security.12 The US has invoked this in its retaliatory actions against Afghanistan and its campaign against the Taliban after the 9/11 attacks and that the United Nations has recognized such claims through the Council Resolutions 1368 and 1373.13 The responsibility shared by the state by sponsoring terrorism has since been established. The lesson has been learned and the Middle Eastern governments recognize this perhaps more than any other. By addressing money laundering and by adhering to the FATF standards, Middle Eastern states seek to avoid the dilemma of being linked to terrorists, the majority of which are of Middle Eastern ethnicity. IV. Money Laundering and Terrorism Money laundering is important in terrorism because it is pivotal in its financing. In order to understand this, it is helpful to examine how terrorist financing operates. According to Koh (2006), terrorist financing is characterized by two activities: money making and distribution: Money laundering begins with brushing off the audit trail and ends by achieving legitimization, while terrorist financing begins with money making and ends by distributing it (see diagram below. Despite the differences in their final goals, what money laundering and terrorist financing share in common is the concern about how to erase money trails… Out of this similarity, the skills of the money launderer have become an indispensable tool for terrorists to hide the flow of their money as well as to keep sustainable sources intact.14 Fig.1 Money Laundering and Terrorism Also, links between terrorist organizations and organized criminal groups such as drug traffickers are commonplace. According to Hardouin and Weichhardt (2006), this link can take many forms ranging from facilitation (such as protection, transportation and taxation), to direct trafficking by the terrorist organization themselves.15 In this case, money laundering takes a very important role as logistical needs require the easy and covert movement of goods, money and people. An important aspect or perhaps a dimension unique to the Middle East is that the money laundering infrastructure that is utilized by terrorist organization to acquire money that may not necessarily be criminal in origin. For instance, there is the informal money transfer system known as hawala. This is an Islamic system of transferring money, usually from one country to another through a broker. Hawala, the Middle East Review (2004) explained, is an important method by which low-paid and often illiterate immigrant workers can transfer money back to their families. Here, the lack of paperwork and the fact that no money physically crosses the borders has made hawala a channel for terrorist financing.16 The Al-Qaeda terrorist organization has reportedly used this established system particularly in its operations in Pakistan, the UAE and throughout the Middle East, after it found that the banking system in the Middle East has become unreliable due to reforms in the aftermath of investigations after the August 1998 East African Embassy bombings as well as the stricter regulations adopted since 9/11.17 Then, there is also the zakat practice, wherein money is collected across every walk of the Middle Eastern societies to be distributed to various sectors in need of help and charity. In this way, money could be funneled to terrorists without much government intervention. It was the United Nations General Assembly that first revealed how terrorist funds originate from charitable institutions.18 V. The Use of Money Laundering Infrastructure in Terrorism The conventional ways in which terrorists in the Middle East could use the money laundering and the financial systems is demonstrated in the way bank accounts are used to launder terrorist funds: Legitimate Accounts: individuals may open a number of legitimate bank accounts with several banks. This modus operandi is aimed at circumventing suspicion on irregular activity on the terrorist’s bank account. Dormant Accounts: on occasions, dormant accounts are used by terrorists in order to establish a legend upon which additional frauds are perpetrated. Here, facilities can be accessed which include the obtaining of bank loans. Unfortunately, for the bank, payment for the debt will not be met. This bank account could also receive funds from abroad. Telegraphic Transfer: This approach of financial fraud to finance terrorists use telegraphic transfers or wire transfers because of the ease in both sending and recieving funds. Owners of the account need no longer visit the bank personally and risk being captured on video just so the money could be released. Here, certain companies do not even request documentation because what is being required was the use of a pre-agreed question and answer in order to transfer funds. Money Service Businesses and Alternative Remittance Systems: the previously mentioned hawala system, the zakat, as well as the hundi, fei-chen and the black market are examples of these alternative methods – channels of funds, whose diversity suits the requirement of terrorist funding which are sourced from an equally diverse activities such as extortion, drug trafficking.19 It must be underscored that money laundering is not similar to money laundering, as demonstrated by the previous graph and several arguments, which include but not limited to the facts that: terrorist financing typically involves smaller amounts of money than does traditional money laundering, hence, combating relatively small-scale laundering could prove daunting for authorities; then there is also the fact that the stakes in terrorist financing is higher even though the amounts involved through laundering activities are small.20 (Reuter and Truman 2004, p. 3) Here, the benefits of its prevention or elimination to societies are huge. From another perspective, and fortunately for the law enforcement authorities, there is the fact that money laundering infrastructure and regime can be used in order to solve the terrorism problem, especially for the West, the region that often bears the brunt of terrorist attacks. First, the money laundering system can provide numerous tools that can be used as investigative devices to learn something not only about the origins of funds but also their destinations. This fact underscores how the existing infrastructure could lead authorities not only to persons and organizations that finance terrorist organizations but also the identity and location of terrorists and terrorist organizations. Reuter and Truman (2004) also added that the money laundering system in place today can be used as a prosecutorial device, as demonstrated in a 1998 US confiscation case involving a scheme to finance terrorism in the Middle East, or in the more recent US case involving a Chicago-based charitable organization, Benevolence International Foundation. Finally, and as mentioned elsewhere in this paper, the money laundering system could be utilized in order to suppress terrorist funding. Through its economic, legal and political infrastructure, it would be easy to clamp down on terrorists by isolating them from their financiers, eventually reducing their capabilities to mount terrorist attacks. The most important factors in this area is the exchange of information, the blocking or confiscation of funds as well as the closing down of channels that are used to transfer money to terrorists. These variables would be examined more in details in the following sections. VI. International Response Because of the seriousness of the act and its role in the proliferation of crime, several initiatives have undertaken in order to criminalize the act. For instance, the UN Convention in 1998, established the modern anti-money laundering strategy, which was eventually accepted in both the law enforcement and policy-making circles, internationally, so much so that it has been characterized as the white collar crime of the 1990s.21 Gilmore argued that progress in this area is seen as a critical element in the fight against organized crime and, increasingly, as crucial in efforts to combat corruption.22 The international nature of money laundering, wrote Stessens (2000), requires an international response and that international harmonization efforts must be undertaken in respect of confiscation and the criminalization of money laundering. His main argument is that the effective fight against money laundering depends upon the harmonizing of the international substantive criminal laws, in order to solve the jurisdictional problems that would likely arise.23 Indeed, this is reasonable because often, it will not be clear which country would have jurisdiction to investigate money laundering offences and to prosecute and try those who commit the act or to seize and order the confiscation of the proceeds from crime. In addition, while there is some capability on the national level, especially those with determination and good policies, the successes would be limited due to the international scope of the problem. There would always be diversity in the degree of control and regulations across countries and jurisdictions. As previously mentioned, when more effective and strident control are effected in a country, the launderers could just easily exploit the lenient environment somewhere else. According to Tanzi (2000), the solution to the money laundering problem must be sought via international mechanisms, specifically by eliminating the differences in policies and regulations among countries in this area.24 The money laundering control system, wrote de Koker (2006), enlists the financial services industry as one of the key partners in the combating of money laundering and the suppression of financial terrorism.25 Here, the industry is required to actively prevent its services from being abused to launder money. The FATF is one of the results of the several initiatives undertaken according to purpose outlined above. The policies that are promulgated under the auspices of the FATF are not really legally binding but could only sanction member countries and blacklist countries for non-compliance in its standards. All in all, one can consider the FATF as a regulatory regime – an organization that does not aim to control illegal financial flows across the globe but instead, it just encourages and supports individual states in their drive to strengthen the policies against money laundering.26 While it appears that the capability of the FATF and similar world bodies lacks teeth or any significant power especially in the context of meting out punishments for non-cooperative countries, this is not the case. For example, being blacklisted by the FATF could cause severe economic consequences for a country because it affects market integrity and that it taints a state in the eyes of the investment community and the international financial market.27 In addition, it would also make the country a target for international scrutiny in regard to potential money laundering activities. According to Bagella, Bachetti and Hasan (2006), the blacklist instrument represents the cornerstone of the international effort to reduce the risks that single countries or territories became havens for money laundering activities.28 According to its most recent mandate: FATF will continue to sent anti-money laundering and counter-terrorist financing standards in the context of an increasingly sophisticated financial system, and work to ensure global compliance with those standards. FATF will enhance its focus on informal and non-traditional methods of financing terrorism and money laundering, including through cash couriers, alternative remittance systems, and the abuse of non-profit organizations.29 In 2004, fourteen countries have banded together in order to establish their own regional financial action task force that is similar to the FATF, the Middle East and North African Financial Action Task Force or MENAFATF.30 The cornerstone of these world bodies, particularly the FATF and MENAFATF, is the detailed description of appropriate countermeasures for countries to adhere to, set out in the ‘Forty Recommendations’ that was formulated and adopted by countries during the 1990s. These recommendations included: The criminalization of money laundering and the enactment of laws to seize and confiscate proceeds of crime; Obligations for financial institutions to identify all clients and to keep appropriate records; The requirement that financial institutions report suspicious transactions to competent national authorities and implement a range of internal control measures; Adequate systems for the control and supervision of financial institutions; and, The need for international treaties/agreements and the passing of national legislation allowing countries to provide cooperation at all levels.31 In regard to initiatives by these international organizations that are specifically aimed at combating terrorism, there are numerous proposals and initiatives that are currently being worked out. Some of these include: Setting international Anti-Money Laundering and Counter-Terrorist Financing standards; Monitoring and compliance with these standards through a peer or mutual evaluation process; Encouraging compliance of non-FATF members through the FATF-style regional bodies and the non-cooperative countries and territories (NCCT) initiative and technical assistance needs assessments (TANAs).32 The FATF also released the Eight Special Recommendations on Terrorist Financing and that these are very focused and nuanced demonstration how the agency understands terrorist groups’ financial processes. The eight recommendations are: 1) take immediate steps to ratify and implement the relevant United Nations instruments; 2) criminalize the financing of terrorism, terrorist acts and terrorist organizations; 3) Freeze and confiscate terrorist assets; 4) report suspicious transactions linked to terrorism; 5) provide the widest possible range of assistance to other countries’ law enforcement and regulatory authorities for terrorist financing investigations; 6) impose anti-money laundering requirements on alternative remittance systems; 7) strengthen customer identification measures in international and domestic wire transfers; and, 8) ensure that entities, in particular non-profit organizations, cannot be misused to finance terrorism.33 A ninth recommendation was added by the FATF in 2004 calling on countries to stop cross-border movements of currency and monetary instruments to terrorist financing and money laundering.34 As illustrated above, in the global initiatives and policymaking against money laundering and terrorism, the term financing is crucial. However, there are variations in regard to country-specific usage. The UK and Canada have the widest approach while Nigeria seems to have the narrowest in an analysis conducted by Chukwuemerie.35 All in all, the growth of the global anti-money laundering regime has so far generated very little resistance from public, business and most countries. For example, Reuter and Truman maintained that while the banking sector initially resisted increased government interference in its relationships with clients, they have since learned how to accommodate AML requirements in ways that impose relatively modest costs and inconveniences on both banks and their customers.36 Also, having anti-money laundering initiatives or its accommodations affect the competitiveness of banks internationally, has since been dispelled because most countries have adopted or accommodated similar regime. VII. Legal Framework and Specific Countermeasures Money laundering and terrorism, in the context of international legal framework, is viewed differently, at least in the context of the FATF objectives and regulations and similar organizations. This is demonstrated in the way international bodies reject the initiatives of some countries, which implement the criminalization of the financing of terrorism but adopted and integrated in their respective money laundering legislations. According to the International Monetary Fund (2003), this policymaking is not responsive to the spirit and proposals of the international conventions. It states: It should be borne in mind that the Convention establishes separate, autonomous offense of financing terrorist acts. Although both financing of terrorism and money laundering offenses are based on the common idea of attacking criminal groups through measures aimed at the financing of their activities, the two offenses are distinct.37 This is indeed the case since, as mentioned elsewhere in this paper, terrorist financing involves funds that are not necessarily proceeds of illegal act and sources and need not have been laundered. “It is not their criminal origin that makes them ‘tainted,’ but their use, or intended use, to finance terrorist acts, or to provide support to terrorists or terrorist organizations.”38 Here, it is important to underscore that money laundering is in no way fundamentally connected with terrorism. The case is that terrorists or terrorist organizations take advantage of the money laundering infrastructure in order to bankroll their operations. This relationship does not mean that both can be taken as one or that one could be a component of the other. Nevertheless, there is an explicit emphasis on the FATF Special Recommendations wherein financing terrorism is a predicate offense to money laundering. According to the IMF, such inclusion is automatic for countries that define predicate offenses as “all crimes” (as is required in the Strasbourg Convention) or all serious crimes (as long as the terrorism financing offenses fall within the definition of “serious crimes” in the jurisdiction).39 In the case of the United Kingdom, there are separate set of laws that apply to terrorist money as determined by the Terrorism Act 2000, which created a series of criminal offences relating to handling terrorist money. The most relevant of these were listed by Haynes (2008), which include: receiving of terrorist funds; possessing terrorist funds; being involved in the arrangement of suspected terrorist money; the retention, use and control of terrorist property; failure to report the offence; among others.40 These offences are penalized from a fine or up to six months of imprisonment on summary conviction and a fine or up to 14 years on indictment.41 Then, there is also the creation of the UK Serious Organized Crime Agency in 2006, which has both domestic and international responsibilities to prevent and detect serious organized crime and to reduce the harm from such crime.42 The UK Financial Intelligence Unit, which is tasked with receiving reports made under the Proceeds of Crime Act and the Terrorism Act, is under its auspices. After 9/11, a flurry of reforms on international legislations relating to terrorism was introduced. Foremost of these was the Terrorism Order 2001 of the United Nations. This act addresses the main issue arising in context of laundering being the seizing of terrorist funds and that it allows the forfeiture of funds in civil proceedings in a magistrate’s court where the monies concerned are: intended for use for terrorist purposes; consists of the resources of a proscribed organization; or, amounts to property obtained through terrorism.43 VIII. How the US Tackles the Middle Eastern Case In the case of the incidence of money laundering and its close ties with terrorism in the Middle East, there are very specific initiatives established to counter their growth and prevent them from being able to operate. For example, there is the Operation Green Quest, which is a multiagency terrorist financing task force established for the purposes of identifying, disrupting and dismantling terrorist financial networks by bringing together the financial expertise of the US Treasury department in tandem with other branches of the US government.44 This agency has been recently successful by gathering proofs and evidences that showed how millions of dollars have been sent to the al-Qaeda in order to fund the 9/11 attacks in New York. Then, there is also the creation of the National Counter Terrorism Center in the US Federal Bureau of Investigation (FBI). This department has four subunits: the International Terrorism Section, the Domestic Terrorism Section, the National Infrastructure Protection Center, and the National Domestic Preparedness Office. Recently, in December, the failed attempt of Umar Faruok Abdulmutallab to smuggle a bomb onto Northwest Airlines Flight 253, highlighted the increase in the emphasis on the Middle Eastern counterterrorism operations.45 Analysts working on the Middle East Branch are responsible for integrating and analyzing millions of pieces of fragmentary data relevant to terrorism in the region, as provided by partner agencies such as the Central Intelligence Agency and the National Security Agency. 46 IX. Conclusion It must be underscored that terrorism has evolved through the years. As technology and modern processes developed, it has adopted and has thrived as demonstrated by its grim successes in the past decade. One of the most effective ways to combat terrorism has been through the attack on its financial supply. Here, money-laundering and its countermeasures become essential. Without terrorist money, it would not be able to successfully operate. The discourse on money laundering and terrorism reveals a lot of insights in regard to the financial sector in the Middle East and its ties, both alleged and substantiated, with terrorism. For example, there are the unique financial practices such as the hawala and zakat, which demonstrate how actors - including states, banking institutions and private individuals - play important roles in the capabilities of terrorists and terrorist organizations. On the one hand, the discussion also underscores the significant development in anti-money laundering initiatives in the region as well as its eager cooperation to stop money laundering and terrorist financing within the region. With all variables considered, the successes and failures of the global initiatives against terrorism and money laundering in the context of the Middle Eastern experience rest mainly on the international cooperation. The positive outcome of multilateral strategy to combat the problem has resulted to the creation of an anti-money laundering regime and infrastructure that often effectively addresses the problem both on national and international levels. Unarguably, there are still much to improve on the current situation and that a lot of them are in the area of cooperation and jurisdiction. However the case is, one cannot deny the fact that various international policies, regulations and conventions on money-laundering has helped a great deal in solving terrorism as demonstrated by the case of the Middle East. References Andrew Chukwuemerie, "International legal war on the financing of terrorism." (2006) 9 JMLC, 71-88. Andrew Haynes,"Money Laundering: from failure to absurdity (2008)11:4 JMLC 303-319. Armin von Bogdandy and Rudiger Wolfrum, Max Planck Yearbook Of United Nations Law 2004, Volume 8; Volume 2004 (Martinus Nijhoff Publishers, Leiden 2004). 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Spencer Ackerman 'Counterterrorism Center Has Only Eight or Nine Middle East Analysts' [2010] . The Washington Independent. accessed 18 May 2010 The Stationery Office, Money laundering and the financing of terrorism: 19th report of session 2008-09, Vol. 2: Evidence (The Stationery Office, London 2009). Wayne Bennett and Karen Hess, Criminal investigation (Cengage Learning, 2006). William Gilmore, Dirty money: the evolution of money laundering counter-measures, Part 609 (Council of Europe, 1999). Yu Guiying, "The Offence of Money Laundering and its Constitutive Characteristics in China" Association Internationale de Droit Penal. (2010) accessed 17 May 2010. Vito Tanzi, Policies, institutions and the dark side of economics (Edward Elgar Publishing, Cheltenham 2000) Read More