FATF REPORT Money Laundering And Terrorist Financing Risks Arising From .
FATF REPORTMoney Laundering andTerrorist Financing RisksArising fromMigrant SmugglingMarch 2022
The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotespolicies to protect the global financial system against money laundering, terrorist financing and the financing ofproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-moneylaundering (AML) and counter-terrorist financing (CFT) standard.For more information about the FATF, please visit www.fatf-gafi.orgThis document and/or any map included herein are without prejudice to the status of or sovereignty over anyterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area.Citing reference:FATF (2022), ML/TF Risks Arising from Migrant Smuggling, FATF, Paris, odsandtrends/documents/migrant-smuggling.html 2022 FATF/OECD. All rights reserved.No reproduction or translation of this publication may be made without prior written permission.Applications for such permission, for all or part of this publication, should be made tothe FATF Secretariat, 2 rue André Pascal 75775 Paris Cedex 16, France (fax: 33 1 44 30 61 37 or e-mail:contact@fatf-gafi.org)Photocredits coverphoto:
Table of contentsAcronyms . 2Executive summary . 4Introduction . 6Scope of the report. 6Objectives and structure . 7Methodology . 8Part One. Migrant Smuggling routes, flows and networks . 9Global estimates and statistics . 9Geographical routes and smuggling flows . 10Structure and profile of migrant smuggling organizations and networks. 13Part Two. ML/TF risks, investigations and international cooperation .18ML/TF associated with migrant smugging . 18ML/TF Mitigating Measures linked to Migrant Smuggling . 29International cooperation . 34Domestic cooperation, coordination and priority setting . 37Part Three. Good practices combating ML/TF from migrant smuggling.39Conclusion and recommendations .43Conclusion . 43Recommendations . 44References .46Annex A. Additional case studies .48Annex B. List of indicators of ML/TF Arising from Migrant Smuggling .67Annex C. Actions/Initiatives in preventing/combating ML/TF arising from MS .69
2 ML/TF RISKS ARISING FROM MIGRANT SMUGGLINGAcronymsAML/CFTAnti-Money Laundering/Counter Terrorism FinancingAPGAsia-Pacific Group on Money LaunderingCARINCamden Assets Recovery Inter-Agency NetworkCDDCustomer Due DiligenceCFATFCaribbean Financial Action Task ForceCTRCurrency Transaction ReportEAGEurasian Group on Combating Money Laundering andFinancing of TerrorismESAAMLGEastern and Southern Africa Anti-Money Laundering GroupEUEuropean UnionFATFFinancial Action Task ForceFIAFederal Investigation AuthorityFIUFinancial Intelligence UnitFRONTEXEuropean Border and Coast Guard AgencyFSRBFATF-style regional bodyFTFsForeign Terrorist FightersGIABAInter-Governmental Action Group against Money Launderingin West AfricaHTHuman TraffickingILOInternational Labour OrganizationIOMInternational Organization of MigrationJITJoint Investigation TeamKYCKnow Your CustomerLEALaw Enforcement AuthoritiesMENAFATFMiddle East and North Africa Financial Action Task ForceMLMoney launderingMLAMutual Legal AssistanceMoUMemorandum of UnderstandingMONEYVALCouncil of Europe Committee of Experts on the Evaluation ofAnti-Money Laundering Measures and the Financing ofTerrorismMROSMoney Laundering Reporting Office Switzerland FATF/OECD 2022
ML/TF RISKS ARISING FROM MIGRANT SMUGGLING 3MSMigrant SmugglingMVTSMoney or Value Transfer ServicesNPONon-profit organsationNRANational Risk AssessmentOCGOrganized Criminal GroupSITSpecial Investigation TechniquesSTRSuspicion Transaction ReportTFTerrorism financingTHBTrafficking of Human BeingsUN CTEDUnited Nations Counter-Terrorism Committee ExecutiveDirectorateUNODCUnited Nations Office on Drugs and Crime FATF/OECD 2022
4 ML/TF RISKS ARISING FROM MIGRANT SMUGGLINGExecutive summaryOver the last decade, regional conflict, political instability and repression, poverty, andthe impact of climate change have led to increasing numbers of migrants and refugeesseeking to move elsewhere. This has led to numerous crises associated with the illegalsmuggling of migrants and resulting in thousands of deaths. Every year, millions ofmigrants in search of a better future put their lives in the hands of migrant smugglerswho see them as an opportunity to make huge financial gains. While it is difficult toquantify the exact amount of the proceeds generated, recent increases in migrationmay mean proceeds currently exceed USD10 billion per annum.12This report aims to update the understanding of money laundering and terroristfinancing (ML/TF) risks associated with migrant smuggling to help countries mitigatethe risks, and disrupt and recover the proceeds – an important driver of this crime. Itfocuses on several relevant parameters associated with the ML/TF risks, in particularthe geographical routes, structure of migrant smuggling organisations and networksand, to a lesser extent, the impact of COVID-19. The report also considers the mitigatingmeasures in place.Key findings of this study include:12 Migrant smuggling has grown in recent years but the number of smugglersarrested remains very low. Many countries do not consider migrantsmuggling a ‘high risk’ crime for money laundering and only very fewinvestigations or prosecutions are initiated or concluded. This is due to arange of factors including a lack of effective international cooperation andoften a lack of focus and resources to support a ‘follow the money’approach. An informal money transfer system, known as hawala, is the most commonmethod of transferring funds generated from migrant smuggling betweenjurisdictions. This makes it extremely hard for law enforcement agencies toperform financial investigations. Other methods include the physicaltransportation of funds via cash couriers or money mules. In recent years, smugglers have started to widely use social media andencrypted digital communication services in their operations forrecruitment and coordination. This provides opportunities for smugglersto enhance their efficiency, but also opportunities for law enforcement todetect and trace the activity of smugglers including financial flows. Migrant smuggling groups also appear to increasingly outsource theirmoney laundering activities to professional laundering networks. Overall, there is limited information available on the connections betweenterrorist financing and migrant smuggling. However, there is evidence ofterrorists receiving money from smugglers along various African ing-migrantsThere is more concrete data on the price for trips along some of well-known migration routes(Asia/Africa – Europe; Latin America – North America). FATF/OECD 2022
ML/TF RISKS ARISING FROM MIGRANT SMUGGLING 5routes in the form of ‘tolls’ for safe passage through the territory theycontrol, and links with facilitation of FTFs. Many countries face difficulties in understanding the ML/TF risks they facefrom migrant smuggling. While some countries have access to qualitiveinformation and case studies, a large percentage of countries were unableto provide complete statistics on aspects of the performance of theirAML/CFT systems in relation to migrant smuggling. Migrant smuggling is a transnational crime, yet national and internationalcollaboration between relevant authorities has been challenging for manycountries. To prevent migrant smuggling, countries need to proactivelyfollow the money linked to migrant smuggling. The report identifies anumber of good practices and recommendations. These includestrengthening inter-institutional, international and regional cooperation,with a particular focus on supporting countries that are directly affected bymigrant smuggling. The report also highlights the importance of strengthening cooperationwith the private sector and providing them guidance and information onthe specific methods that the smugglers are using to transfer and concealproceeds. Financial institutions and in particular banks and money or valuetransfer services have an important role to play in providing accurate andtargeted suspicious transactions reports that can help authorities profilemigrant smugglers’ financial behaviour.Migrant smuggling might not yield as high sums compared to other majortransnational crimes, but it often causes significant physical harm and suffering.Countries need to take action so that they are more effective in pursuing, disruptingand recovering the illicit profits that incentivize criminals to smuggle migrants. FATF/OECD 2022
6 ML/TF RISKS ARISING FROM MIGRANT SMUGGLINGIntroductionScope of the reportMigrant smuggling is a crime that has an often significant consequence on the lives ofmillions of civilians, with criminals taking advantage of the sometimes desperate plightof individuals seeking to escape nature disaster, conflict, persecution or poverty, orlooking for economic opportunity. It is an issue that is high on the list of priorities formany governments and has been subject of a number of resolutions adopted by theUnited Nations Security Council.3As with other major proceeds generating crimes, identifying pursuing and disruptingthe proceeds and instrumentalities, and sanctioning those in laundering them, can playa key role tackling the crime itself. Since the FATF last focused on migrant smugglingin 20114 there have been significant changes that have affected both migratorypatterns, and the financial flows associated with the facilitation of irregular migration5around the world. A number of factors has driven these changes, including thecontinuing advancement of globalisation through the reach and influence of globalcommunication tools such as social media; a series of economic crises and politicalevents, affecting the employment opportunities of young people in particular; and theincreasing presence of online market places that are facilitating the sale of, andpayment for, smuggling services.Under its German Presidency (2020-2022), the FATF made it one if its priorities toupdate the understanding of the money laundering and terrorist financing risksassociated with migrant smuggling. This report represents the conclusion of thatwork, bringing together key intelligence from competent authorities around the worldon what is inherently a cross-border risk, and drawing on the findings of research345See Resolutions 2240 (2015), 2359 (2017), 2374 (2017), 2380 (2017), 2388 (2017).(FATF, 2011) Money Laundering Risks Arising from Trafficking in Human Beings and Smuggling ofMigrantsSee all the definitions related to migration at IOM website, www.iom.int/key-migration-terms FATF/OECD 2022
ML/TF RISKS ARISING FROM MIGRANT SMUGGLING 7conducted by partner organisations such as Europol, INTERPOL, UN CTED, UNODCand FATF-style regional bodies such as CFATF and MENAFATF.The Protocol against the Smuggling of Migrants by Land, Sea and Air,6supplementing the United Nation Convention against TransnationalOrganised Crime (UNTOC), defines in its article 3 “smuggling of migrants”as “the procurement, in order to obtain - directly or indirectly - a financialor other material benefit, of the illegal entry of a person into a State Partyof which the person is not a national or a permanent resident, with illegalentry referring to crossing borders without complying with the necessaryrequirements for legal entry into the receiving State.”This report focuses on the financial component of migrant smuggling: the nature of themoney laundering and terrorist financing threats and vulnerabilities, how to identifythe financial flows related to this crime, and how the associated risks are and can bemitigated.In accordance with the FATF Recommendations, all countries must apply the crime ofmoney laundering to all serious offences including migrant smuggling.7 Article 6 of theabovementioned Protocol against the Smuggling of Migrants provides a set ofmeasures on the criminalisation of smuggling with intent to generate a financial orother material benefit. It is also important to note that the offence of migrantsmuggling has several distinct aspects that differ from other offences, and in particularhuman trafficking.8 Firstly, migrants have consented to be transported, whereas thevictims of human trafficking have not; secondly, the smuggling ends with the arrival ofthe migrant in the destination, whereas human trafficking often involves ongoingexploitation in some other way; and thirdly, migrant smuggling is always transnationalwhereas human trafficking may not be. In addition, the routes and amounts ofproceeds that are generated are often different. Nevertheless, there are some linkagesbetween the two crime types, for example the same criminal networks may be involvedin both migrant smuggling and human trafficking. For more information on ML and TFassociated with human trafficking, see the FATF/APG report Financial Flows fromHuman Trafficking published in 2018.Objectives and structureThe key objective of this project is to strengthen and update the understanding ofML/TF risks arising from migrant smuggling at a global level. The target audience isboth competent authorities, in particular financial investigators and expertsresponsible for assessing and monitoring national ML and TF risks, and the privatesector. Ultimately, this project should help countries and the private sector to aligntheir national and institutional controls and strategies through an enhancedunderstanding of ML/TF risks from this criminal market.678Annex III, https://undocs.org/en/A/RES/55/25In addition to human trafficking and 20 other categories of offences.See also ues/differences-andcommonalities.html FATF/OECD 2022
8 ML/TF RISKS ARISING FROM MIGRANT SMUGGLINGThese objectives are delivered through three parts: Part one provides an overview of migrant smuggling routes and flows, andthe structure of migrant smuggling organisations and networks. Part two analyses cases studies and responses of the countries to thequestionnaire, drawing insights on ML/TF risks, investigations, andinternational cooperation. Part three identifies good practices for countries to consider.MethodologyExperts from Greece and Mexico co-led this project with the support of the FATFSecretariat. The project team consisted of representatives from Brazil, China,European Commission, Europol, Germany, Greece, IMF, Italy, Malaysia, Russia, Spain,Sweden, the United States, UN CTED and UNODC. The following 43 jurisdictions fromFATF and FSRBs and one international organisation have provided inputs (responsesto the questionnaire and/or case studies related to the first call for inputs in July 2021)for this report: FATF members (19): Australia, Belgium, Brazil, Canada, EuropeanCommission, Germany, Greece, Finland, Hong Kong China, Italy, Ireland,Japan, Malaysia, Mexico, Portugal, Russia, Spain, Switzerland and Turkey; FATF observer: Europol; APG (2): Fiji and Pakistan; CFATF (2): Cayman Islands and Salvador; EAG (2): Tajikistan and Turkmenistan; ESAAMLG (3): Botswana, Tanzania and Zimbabwe; GIABA (4): Burkina Faso, Cape Verde, Senegal and Togo; MENAFATF (1): Egypt; MONEYVAL (10): Albania, Estonia, Gibraltar, Latvia, Lithuania, Romania,Serbia, Slovakia, Slovenia and Ukraine.The above-mentioned questionnaire focused on countries’ legal framework onmigrant smuggling and assessments of risks, ML/TF investigations and internationalcooperation. Supporting information for this study included a literature review toidentify recent trends in modus operandi of smugglers, to gather available informationon financial aspects of this criminal business and its linkages with other offences. Theproject was also informed by the analysis of additional case studies provided bydelegations,9 and discussions held in the framework of the special session of the FATFJoint Expert Meeting, involving participation of 106 operational experts from aroundthe world and held on 6 December 2021.9Additional case studies and other information in relation to a call in October 2021 was provided byGermany, Greece, Luxembourg, Spain and UK, by GAFILAT members (Chile, Costa Rica, DominicanRepublic, Ecuador, and Peru), GIABA members (Senegal and Togo) and MONEYVAL members(Bosnia and Herzegovina, and Poland). FATF/OECD 2022
ML/TF RISKS ARISING FROM MIGRANT SMUGGLING 9Refugee camp in Lesvos, Greece. Many migrants refugees, arrivedin inflatable dinghy boats on one of the most dangerous migrantsmuggling routes globally.Part One. Migrant Smuggling routes, flows and networksGlobal estimates and statisticsMigration is a phenomenon that has accompanied humanity for centuries and, often, iscaused by a combination of circumstances, such as “international economicimbalances, poverty and environmental degradation, combined with the absence ofpeace and security and lack of respect for human rights”. This is reflected in the UNNew York Declaration for Refugees and Migrants, which aims to address the questionof large movements of refugees and migrants.10 Nevertheless, globalisation of theworld economy has increased the movement of people across borders, legally andillegally, especially from developing to developed countries. Cross-border organisedcriminal groups have taken advantage of opportunities presented as a result of theincreased flow of people, money, goods, and services to extend their reach.11Due to its clandestine nature, there are no reliable global statistics on the number ofmigrants who are smuggled each year. The UN estimated that each year there areapproximately three million irregular entries into the United States of America, whilein 2016, more than 181 000 migrants crossed the Mediterranean from North Africa toItaly. In both instances, most of these individuals were smuggled by migrant smugglers(UNODC, 201612). In 2015, due to the crisis in Syria, approximately one million101112UN, New York Declaration for Refugees and Migrants, 2016, p. 22, p.fas.org/crs/misc/RL34317.pdfUNODC , Smuggling of migrants: the harsh search for better life, .html FATF/OECD 2022
10 ML/TF RISKS ARISING FROM MIGRANT SMUGGLINGirregular migrants and refugees reached Greece via the Eastern Mediterranean Route(Turkey – Greece).13 In 2019-2020 the United States Custom and Border Protectionencountered almost 1.5 million individuals attempted to enter the country illegally atthe border with Mexico.14 In 2018, Frontex detected nearly 140 000 irregular bordercrossings along the three Mediterranian routes (Eastern, Central, Western)15 while in2020 this figure decreased to nearly 76 000 due to COVID-19 countermeasures.16Migrant smuggling is “a deadly business operated by groups that seek to profit fromthousands of people, without any respect for their rights and dignity”.17 For example,the migrant flow from Morocco, Algeria, Tunisia, Libya, and Egypt, through theMediterranean Sea towards the coasts of Italy, Greece and Spain is estimated to haveresulted in more than 20 000 deaths of which 1 369 occurred in 2021, one of the mostdangerous routes globally.18Geographical routes and smuggling flowsMigrant smuggling thrives due to a range of factors including war, violence and a lackof employment opportunities in the migrants’ countries of origin. In most cases, thehope of security and a better life drives individuals to undertake often perilousjourneys at the hands of migrant smugglers who see them as a source of profit. Thereare about 60 identified smuggling routes, with many services along these Frontex, Risk Analysis for 2021, p. isk Analysis/Risk Analysis/Risk Analysis d-global-story FATF/OECD 2022
ML/TF RISKS ARISING FROM MIGRANT SMUGGLING 11The main destination countries for migrants are the United States, Canada, Spain,France, UK, Switzerland, Sweden, Germany, Italy, Japan, South Korea, Australia andMalaysia, most of which are considered developed countries.20 Many other countriesalso host a large number people fleeing conflicts and disasters.Over the last five to six years, most of the countries that are considered transitcountries (Togo, Zimbabwe, Fiji, Brazil, Cayman Island, Mexico, El Salvador, Greece,Italy, Russia, Slovakia, Spain, Turkey, and Switzerland) have reported not only anincrease in the flow of irregular migrants, but also a multiplication in the routes oftransit (by air, land and sea) and the incorporation of new nationalities to thesemigrant flows. Such an increase ultimately poses some challenges for destinationcountries as well.The following are examples of the countries’ detection of increasing flowsof migrants over the last 5 years: 20In 2021, the flow of irregular migration from Belarus to Lithuaniahas increased dramatically. As of 4 August 2021, 113 irregularmigrants and refugees have been detected illegally crossing theborder from Belarus compared to just 74 in 2020. The number ofirregular migrants and refugees in 2021 was almost 20 times morethan the numbers registered in 2018, 2019, 2020 combined.In 2020, more than 23 000 irregular migrants reached the CanaryIslands, a 10-fold increase compared to the same period in 2019.BBVA-CONAPO, 2021, migration-andremittances-mexico-2021/ FATF/OECD 2022
12 ML/TF RISKS ARISING FROM MIGRANT SMUGGLING Brazil also detected significant inflows of irregular migrants fromAfrican and Latin American countries. The incoming flows ofVenezuelans are constantly increasing, while Haitians, Bengalis andAfrican migrants are also known to enter Brazil to reach the US.The Spanish government has observed that migratory routes haveshifted towards the Atlantic and northern coasts of Algeria. This hassignificantly increased the number of migrants in the Canary Islandsand the Mediterranean corridor (mainly to the provinces of Almeria,Murcia and Alicante).Countries in the Americas have noted a significant increase ininbound or outbound flows of irregular migrants heading to theUnited States over the last 5-6 years. While the flow of irregularmigrants came mainly from Central America before, this has beenexpanded to migrants and refugees from Haiti, Venezuela, Cuba andEcuador, as well as from various regions of Africa and Asia. Malaysia,Hong Kong China and Pakistan see migrants and refugees arrivingfrom Indonesia and Myanmar, from South Asia and Afghanistan,respectively.Source: Lithuanian FIU (FCIS), Brazilian FIU (COAF), Spanish FIU (SEPBLAC), MexicanFIU (UIF)It is estimated that the majority of irregular flows are guided or accompanied bymigrant smugglers. For example, in 2019, approximately two thirds of migrantstransitting through Mexico hired a person as a guide to cross into the United States.Despite the increases in cases of migrant smuggling, complaints and arrests ofsmugglers remain very low. Most arrests are concentrated in the destination andtransit countries.21Impact of the COVID-19 pandemicThe COVID-19 pandemic has had an impact on the movement of migrants – both legaland illegal. The closure of official border entry points, increased security presence atborders, movement within countries and the disruption to air travel have all impactedmigratory flows.22 This led to some smugglers temporarily stopping or delaying theirservices.23 Nevertheless, according to a report issued by the UNODC, travel andmovement restrictions have not stopped the movement of people fleeing conflict,violence, and persecutions, who have no option but to use migrant smugglers’ services.UNODC indicated that the closure of land, sea and air borders might increase212223Turkey has the highest number of migrant smuggling cases under investigation (7 672) in 2021(January – August) among those who provided information for this study.Global Initiative against Transnational Organized Crime, “Smuggling in the time of COVID-19. Theimpact of the pandemic on human-smuggling dynamics and migrant-protection risks” (April ing-covid-19/European University Institute, “Stranded: The Impacts of COVID-19 on Irregular Migration andMigrant Smuggling”, 2020, e-en FATF/OECD 2022
ML/TF RISKS ARISING FROM MIGRANT SMUGGLING 13smuggling of migrants, because people would have an even greater need for theservices of smugglers in order to cross borders.24Also, it is worth noting that migrant smuggling is significantly affected by geo-politicaland socio-economic factors which vary greatly by region and in the ways they drivevulnerable communities in those regions to migrate. According to INTERPOL, key landmigration routes, for example those connecting Central America to North America andthe Horn of Africa to South Africa, have remained active as smugglers monitor bordermanagement in order to evade controls, whereas the pandemic appeared to diminishmigrant smuggling in Asia and in the Middle East.25 Migrant smuggling relies on airtravel along the west-bound routes from South Asia into Africa, South America, Europeand the Middle East Gulf countries, and these routes were disrupted due to thepandemic. In Europe, smugglers were using smaller boats to cross water-borders, suchas the English Channel, and migrants were being dangerously concealed in thecompartments of trucks, freight vehicles, and cargo trains to cross land borders.26In the instances where there is increased demand by migrants or there are travelrestrictions , smugglers may adapt by using more risky routes, and charge higherprices for smuggling services. The economic impacts of the pandemic may also haveimplications on the flows of irregular migrants, with increases in numbers ofindividuals attempting to migrate to countries that have a faster recovery.27Structure and profile of migrant smuggling organizations and networksThere is a consensus that smuggling networks function as an “enterprise” model withlarge numbers of smaller, flexible crime groups or individual criminals that interactwhen necessary.28More sophisticated networks carry out migrant smuggling in regions where antismuggling law enforcement strategies are particularly robust.29 With some exceptions,migrant smuggling organisations are generally not systematically involved in othermajor transnational organized crime activities.30 Nevertheless, migrant smuggling canbe carried out by members of sophisticated and often unscrupulous organisationswhich may make large profits from the smuggling and/or
Money Laundering and Terrorist Financing Risks Arising from Migrant Smuggling March 2022. The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes policies to protect the global financial system against money laundering, terrorist financing and the financing of
This revised version focuses on the banking sector. 3, and a separate guidance will be developed for the securities sector. The FATF will also review its other RBA guidance papers, all based on the 2003 Recommendations. 4. 2. The RBA guidance for the banking sector was drafted by a group of FATF members, co-led by the UK and Mexico. 5File Size: 1MBPage Count: 50Explore furtherFATF Recommendations - Financial Action Task Forcewww.fatf-gafi.orgFATF 40 Recommendationswww.fatf-gafi.orgWolfsberg Group Principles On A Risk Based Approach For .www.wolfsberg-principles.comHandbook on Anti-Money Laundering and Combating the .www.adb.orgHigh-Risk Industries For Money Laundering And Terrorist .sanctions.ioRecommended to you b
b) Other relevant FATF Guidance documents such as: The FATF Guidance on National Money Laundering and Terrorist Financing Risk Assessment (February 2013) FATF Guidance on Transparency and Beneficial Ownership (October 2014) FATF Guidance on the Risk -Based Approach fo
in combination with other money laundering techniques to further obscure the money trail."5 1 Financial Action Task Force (FATF), Trade Based Money Laundering, June 23, 2006. The basic techniques of trade-based money laundering (TBML) include over- and under-invoicing of goods and services, multiple-invoicing of goods
Defining trade-based money laundering and trade-based terrorist financing 11 Trade process and financing 12 Section 2. Trade-based money laundering risks and trends 15 Risk-based approach to trade-based money laundering 16 Economic sectors and products vulnerable to TBML activity 20 Types of businesses at risk of trade-based money laundering 24
FATF Guidance on the Risk -Based Approach for Trust and Company Service Providers (TCSPs) (June 2019) FATF Guidance on the Risk-Based Approach for Accountants (June 2019) c) Other relevant FATF reports such as: FATF Report on Money Laundering and Terrorist Financing: Vulnerabilities of Legal Professionals (June 2013)
2.1 The Financial Action Task Force: Who? The Financial Action Task Force (FATF) is the international standard setter mandated with countering money laundering and the financing of terrorism. Initially set up in the 1990s to tackle money laundering and the misuse of financial institutions resulting from the drugs trade, the FATF's mandate was
THE DEMAND FOR A BET TER UNDERSTANDING OF MONEY LAUNDERING AN D TERRORIST FINANCIN G RISKS The first FATF. 1. recommendation requires that states identify, assess and understand the money laundering and . laundering or terrorist financing offences, whether on the national level or cross-border; The vulnerabilities make it possible to identify .
Wei Yang Introduction to Mean field games and applications. Introduction Our results and applications Mean field game Methodology consider an N-playerstochastic dynamic game study amean field game(a limit for N !1) which can be expressed bya system of coupled equations: Fokker-Planck equation Hamilton-Jacobi-Bellman equation any solution to the mean field game is an -equilibriumto the N .
