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| Illustration euros hung on the wire |
What is noticeable in these schemes is the presence of offshore companies, the establishment of fictitious businesses and the involvement of construction and infrastructure companies, dubious transfers and call center, a phenomenon that has been mentioned for about three years in the field of money laundering. But what are the typologies that have been observed and reported by GDPML.
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| Illustration, euros inside the washing machine |
The citizen X, during a period of 3 years has sent a considerable number of transfers to different countries, mainly in the direction of the Y-Albanian citizen, but also to Z-foreign and Albanian citizens, without a clear connection between them. Thee transfers made fluctuate in the limits of: 60 EUR - 6,000 EUR; 15,000 All - 110,000 All and 100 USD - 200 USD.
Regarding the above, based on the high number of transfers inside and outside the country carried out by the above-mentioned citizens X and Y with different citizens, the links between which are unclear and also the data on the involvement of citizen X in illegal activities is unclear, the case has been sent for further investigation to law enforcement agencies.
Typology 2: Suspicious transfer sent by a citizen of a country at high risk
The Albanian citizen X, 21, turns out to be the sole partner and administrator in two registered companies: the subject D Shpk, established in 1998, with the object "Trade of all goods and mainly tobacco” and the subject E Ltd. established in 2019, with the object in the field of construction and infrastructure.
During 2019, this citizen has benefited in his personal account in EUR currency, an international transfer from a Middle Eastern country at high risk in the amount of 300,000 EUR from a citizen named Y (age 45) - a citizen of another Middle Eastern at high-risk country and resident in the country from which the transfer was sent. The stated purpose of the transfer is to finance the company E shpk, based on a 1-year loan contract, signed the day after the establishment of the company E shpk. The signed contract states that in case of non-repayment of the loan within 2019, the citizen Y has the right to benefit 49% of the company's shares.
In summary, elements with anomalies are:
- Concluding a contract between citizens, while the purpose of its conclusion is declared as “for investments made in the newly established company E Shpk, signed a day later from the date of establishment of the company E Shpk.
- Uncertainty about the connection between citizens and lending in such a significant amount.
- Uncertainty over the reasons of why the citizen X is borrowing money from an Iraqi citizen to make investments for new business, while having sufficient funds in the amount of 555,000,000 LEK (capital) in his other company D Shpk.
- The condition imposed in case of non-repayment of the loan may affect the equality of the newly established parties. From open-source research, there is evidence that cooperation between the two citizens X and Y extends to the field of cigarette production and export. Company D has had a contract for the production of cigarettes for the subject F Shpk, a subject owned by citizen Y. This entity F Shpk - has been established in one of the countries considered a fiscal haven, makes investments in the field of cigarettes and tobacco, transport, oil, gas, telecommunications, etc. and has been accused of smuggling cigarettes in several different countries.
Based on:
- Doubts about the source of income of foreign citizens who seem to be derived from illegal activities for personal gain.
Financing of new business in the field of construction, a field known for the use of money laundering, through funds created illegally and their introduction into the financial system in order to tell them by addressing a third party, specifically foreign nationals who are suspected of exercising illegal activities and creating illegal funds from these activities.
- The unusual conditions stated in the non-loan agreement to justify the potential repayment of this loan.
- The suspicions that the citizen X may not be the de-facto owner of these businesses is suspected to be related to a money-laundering scheme realized through the creation of companies with minimal capital and then the sale of shares at higher values. The case was referred to law enforcement agencies.
Typology 3: Suspicious transfers benefited from performing a fictitious economic activity
During April 2019, the citizen X registered in the National Business Center (NBC) two companies: A Sh.pk and B Sh.shpk. Both of the above companies have as partner and sole administrator the citizen X (foreign citizen from an EU country) have the same object of activity in the field of financial consulting, market research, etc.
Information was requested from the subjects of the law and from the analysis of the bank data regarding the two companies, it results that:
- From the moment of their registration in the NBC and onwards, the companies have benefited from frequent transfers in values ranging from 985 Euros to 15,927 USD with the description "Finance consulting".
- Senders of these funds are citizens with generalities M, D, F, G, N, L, etc. and deliveries are made by more than 10 different countries all over the world, as EU countries but also abroad.
- The obtained values are withdrawn in cash from the citizen X and only the amount of 14,000 Euros is transferred to an EU country in favor of the company C established in an offshore country (a well-known country of tax haven).
These commercial entities have not carried out genuine economic activity, based on the declarations made in the relevant institutions.
In October 2019,
the bank V received a SWIFT message from by the bank Z through which information is given that their client, a citizen with M generals, has deposited in the Police Office of another state (non-EU country). ) a report of fraud in connection with a transfer made by him to the company A, in the amount of about 1,000 USD.
Also in October 2019, the company A has benefited from two transfers in the total amount of about 2,000 EUR at the bank Z with the sender the citizen L (non-EU country), with the description "Finance Consulting" and then the ordering citizen has requested the return of funds with the claim that the latter was involved in a fraudulent investment by the company B.
Considering:
- Allegations of fraud by citizens sending funds in relation to entities administered by citizen "X",
- Citizen X has established two commercial entities with the same object of activity, which has benefited from transfers in significant values in a relatively short time;
- The transferred transfers are of the same typology (finance consulting) and the deliveries are performed by different subjects and places without a visible connection between them.
- A part of the received funds are transferred from the bank accounts of the subjects A sh.p.k and B sh.p.k towards an EU country, on behalf of the company C established in the offshore country. The case was considered anomalous, therefore the information was sent for further investigation to the law enforcement agencies.
Typology 4: High transfers on arrival in favor of Call Center companies
In the period January 2019-August 2019, at Bank X, there have been many transfers of big value in favor of some Call Center companies, funds which were then immediately withdrawn cash from authorized persons of these companies. The citizens A and B, who appeared as authorized persons in economic activities which apparently had no connection between them, turned out to be known among themselves.
During the in-depth analysis of the case, it was noticed that about 16 activities of the type "Call Center" with the same object of activity were established, respectively in 2 single days. Partners of these companies were different citizens from an EU country, namely the citizens D, E, K, L, and M.
After verifying their entry-exit, it turned out that these citizens have entry-exit on common dates, which precede the creation of companies.
Considering:
- Transfers on arrival, followed by cash withdrawals immediately, from Albanian citizens who know each other;
- Societies established with the same object of activity, established by different foreign nationals from the same EU country, who have traveled on the same dates;
The case was considered anomalous, so the information was sent for further investigation to law enforcement agencies.
Typology 5: Suspicious transfer on arrival from a citizen of a country at high risk in the Middle East
In March 2019, a transfer in the amount of 50,000 Lek arrived at the bank Z, with beneficiary the Albanian citizen X. The transfer is ordered by a citizen A, with birthplace in a Middle Eastern country, and with residence in an EU country. This transfer is ordered by a non-EU country.
The receiver (female) of X funds states that this amount was sent in order to "help in the development of economic activity in Albania". Past funds were not of high value and this raised doubts about the purpose of the transfer, which could be testing the system for the arrival of funds to the destination, while with many such it is not expected to achieve the stated goal.
From the verifications carried out by the financial institution, in the data of World-Check, it results that the generals of the name and surname of the citizen A and his birthplace, as a person suspected of involvement in militant/terrorist groups.
Considering:
- Transfer sent from a non-European country, from a citizen of a country at high risk in the Middle East and residing in a European Union country;
- Suspicious description of the transfer on arrival in relation to the purpose of delivery;
- Lack of a connection between the parties;
- Indication of compliance with the generalities of the listener with a person inclined to be involved in militant/terrorist groups; the case was considered suspicious, therefore information was sent for further investigation to the law enforcement agencies within the country and spontaneous information was sent to the country of origin of the transfer.