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Transparency International Anti-Corruption Helpdesk AnswerCorruption and economic crimeAuthor: Jorum Duri, tihelpdesk@transparency.orgReviewers: Maira Martini and Matthew Jenkins, Transparency InternationalDate: 15 March 2021Historically, corruption has been seen as an enabler of some types of economic crime and organisedcriminality, for example through payment of bribes to law enforcement agencies or undue influence indecision-making. However, modern forms of corruption – which the paper interprets as usuallytransnational in nature – are even more intertwined with economic crime. Both sets of crimes sharesimilar drivers, rely on similar mechanisms to move and launder illicit funds, and deprive societies ofmuch needed financial resources, threatening not only economic and social stability of other countriesacross the globe, but also the rule of law and democracy.Due to these common characteristics, certain instruments to combat corruption and economic crimecould be productively brought into closer alignment. For instance, a public register on beneficialownership may prevent the use of shell companies to launder proceeds from both corruption andeconomic crime. Moreover, international cooperation is required in the investigation and prosecution ofboth corruption and economic crime schemes, as well as for asset recovery purposes. Transparency inpolitical funding may also ensure that political and electoral campaigns are not tainted by proceeds ofcorruption and economic crime, and could help prevent capture of state institutions. 2021 Transparency International. All rights reserved.This document should not be considered as representative of the Commission or Transparency International’sofficial position. Neither the European Commission,Transparency International nor any person acting onbehalf of the Commission is responsible for the use which might be made of the following information.The Anti-Corruption Helpdesk is operated by Transparency International and funded by the European Union.

QueryPlease provide an overview of the common characteristics between corruption andeconomic crime. In your overview, please include a discussion on what is meant by“modern forms of corruption”Contents1. Introduction2. Common characteristics betweencorruption and economic crime3. Conclusion4. ReferencesIntroductionMain points— This paper interprets “modern forms ofcorruption” as transnational in nature, andpotentially involving the use of technologyto illicitly acquire, move and dispose ofassets.— It is common for criminals engaged inCorruption sometimes is mistaken as a synonymcorruption and economic crime to abuseof economic crime, despite the distinction betweenshell companies as conduits for their illicitthe two sets of crimes. On one hand, corruption isactivities. There is currently a petition withwidely defined as the abuse of entrusted power1 ormore than 700 signatories calling for apublic office2 for private standard on public beneficialEconomic crime, on the other hand, is defined asownership.any “illegal act committed by an individual or agroup of individuals to obtain a financial or— Evidence shows that international schemesprofessional advantage” (Europol no date). It hasincreasingly involve networks ofbeen defined by some scholars as “fraud in itsprofessional individuals and entities whovarious manifestations”3, as well as includingenable both corruption and economicmoney laundering, bribery and corruptioncrime.(Grabosky (1998: 44-48). Likewise, Kolham andMezei (2015: 36-39) list typical forms of economiccrime as including capital investment frauds,— Dirty money from corruption and economicmisleading consumers, fraudulent bankruptcy, taxcrime often finds its way into politics.evasion, credit and insurance fraud, credit cardHence, ensuring transparency in politicalfunding could prevent criminals exercisinginfluence over politics.1See 0/02/19/anticorruption-fact-sheet23These include insurance fraud, credit fraud, fraud againstemployers or shareholders or government or clients,telemarketing fraud, credit fraud, forgery and theft ofintellectual property. See Grabosky (1998: 44-48).2Transparency International Anti-Corruption HelpdeskCorruption and economic crime

fraud, cybercrime, corruption and moneylaundering.Thus, while corruption can be described as a formof economic crime, the two phenomena are notsynonymous. Economic crime is better understoodas an umbrella terms for a wide variety ofoffences, many of which do not contain theelement of abuse of entrusted power that isintegral to definitions of corruption.Modern forms of corruptionAccording to the G20 Working Group on AntiCorruption, the current Italian Presidency willemphasise “modern forms of corruption”, which isincreasingly linked to economic and organisedcrime. However, there seems to be littleconsensus about what this phrase means or howto interpret it. This paper understands “modernforms of corruption” as (i) transnational in nature,and/or (ii) possibly involving the use of technologyAccording to Europol (no date), economic crime isa “low risk and high profits” business, and it hasbecome increasingly associated with organisedcrime groups. Article 2(a) of the United NationsConvention against Transnational OrganisedCrime define an organised crime group as “astructured group of three or more persons, existingfor a period of time and acting in concert with theaim of committing one or more serious crimes oroffences in order to obtain, directly or indirectly, afinancial or other material benefit”.to illicitly acquire, move or dispose of assets.According to Chouglay (2016), “as the world hasbecome ever more connected, so has the conceptof corruption”. Economic and political globalisationhas resulted in corruption becoming moretransnational in nature; as businesses expandabroad to compete in international markets so docorrupt players increasingly conspire acrossborders. Various scholars have pointed to thecomplex and serious nature of forms of corruptionthat involve more than one jurisdiction (Ware andEvidence indicate the close relationship betweenNoone 2005: 30-31; Zagaris 2015; 105; Law,organised and economic crime. For instance,Lamoree and London 2015). These acts haveEuropol’s latest Serious and Organised Crimeproven difficult to effectively prosecute given theThreat Assessment (2017) lists the eight topinherent need to coordinate law enforcementorganised crime threats as including cybercrime,actions between agencies based in differentdrug production, trafficking and distribution,countries and operating according to differentmigrant smuggling, organised property crime,legislative frameworks.trafficking in human beings, criminal finances andmoney laundering, document fraud and onlinetrade in illicit goods and services. However, it isalso important to note that organised andeconomic crime are not exactly synonymous. Forinstance, some small scale economic crime suchas corporate theft or fraud, may not involveorganised criminal groups.In one of the largest known cases of suchtransnational bribery, Siemens — one ofGermany’s biggest companies – was implicated inthe payment of bribes estimated at US 1.4 billionto government officials and civil servants in Asia,Africa, Europe, the Middle East and the Americas(US Securities and Exchange Commission 2008;Vernand 2018). Siemens had allegedly put inplace a global bribery scheme, which made illicitpayments to foreign officials through payment3Transparency International Anti-Corruption HelpdeskCorruption and economic crime

mechanisms such as cash desks and slush fundslegal assistance with their colleagues in other(Department of Justice 2008).countries can wait months to hear back (Chouglay2016). Such evolving “modern forms” of corruptionIn some circumstances, professionalpose a real challenge to anti-corruption effortsintermediaries are involved in facilitating thearound the world.transfer of illicit proceeds across borders, makingof funds using a dizzying array of legal vehiclesCommon characteristics ofcorruption and economiccrimeand jurisdictions (Cooley and Sharman 2017;Whilst various studies have analysed theOECD 2021).relationship between corruption and economicmodern corruption even more complex as these“gatekeepers” to the legal financial system wittinglyor unwittingly assist in obfuscating the true sourceA good example is the Panama Papers, whichexposed how prominent figures around the worldtransferred their tainted funds to offshorejurisdictions. Investigations by the InternationalConsortium of Investigative Journalists and othermedia partners showed that more than 214,000crime, most have assumed the relationship to bemutually reinforcing, that is corruption enables orfacilitates (organised) economic crime, and viceversa (Center for the Study of Democracy 2010;Gounev and Ruggiero 2012; Rose-Ackerman andPalifka 2018; Rahman and Duri 2020).offshore entities appear in Panama papers,This paper contends that while that may indeed beconnected to people in more than 200 countriesthe case, it is worth investigating the roots of theand territories, with names of 140 politicians andproblem - in other words the common drivers andpublic officials revealed in the scandal. About 500enabling factors that allow both phenomena tobanks were also implicated in creation of overflourish. This effort can improve the precision of15,000 offshore companies for their customersour analysis, for while some types of transnationalthrough the law firm Mossack Fonsecacorruption are increasingly displaying common(International Consortium of Investigativecharacteristics with economic and organisedJournalists 2017).crime, other more localised forms of corruption areThe rapid growth and adoption of newqualitatively distinct.technologies such as online payment systems,Nonetheless, when corrupt networks overlap withblockchains and crypto currencies has alsoorganised criminal groups, they are likely to exhibitenabled the corrupt to remain two steps ahead ofseveral common characteristics, underlyinglaw enforcement agencies, who struggle to detectmechanisms and consequences. These include i)illicit flows in real time (Asia-Pacific Economicthe use of anonymous legal vehicles such as shellCooperation Anti-Corruption and Transparencycompanies; ii) reliance on a series of outwardlyWorking Group 2019). Such new technologiesrespectable professionals such as lawyers,make it easier for the proceeds of corruption tobankers and investment advisors; iii) a tendency tocross borders at the click of a button, while lawtry and co-opt state institutions and political partiesenforcement agencies that file requests for mutual4Transparency International Anti-Corruption HelpdeskCorruption and economic crime

to reduce the risk of enforcement actions that willpartially concealed beneficial ownership. Aboutdamage their interests.817 corporate vehicles were involved in these 150Use of anonymous corporate vehiclesCorporate vehicles, such as companies and trusts,cases, and the estimated total proceeds ofcorruption amounted to US 56.4 billion (van derDoes de Willebois et al. 2011: 117,121).are targeted by criminals as conduits to launderproceeds of corruption and other economic crime(OECD 2001: 13; FATF 2018: 20). In particular,shell companies are appealing to criminals as theyprovide anonymity in terms of the true beneficiaryof financial transactions while simultaneouslyguaranteeing control over the company and itsresources. They can be used as part of complexstructures with a tangled web of companies spreadacross multiple jurisdictions (FATF 2018: 26, 29).Various reports have revealed the common use ofshell companies in grand corruption cases. Forinstance, the recent Luanda Leaks revealed howthe Isabella dos Santos, the former daughter of theAngolan president, allegedly shopped for shellcompanies in Mauritius as she reportedly movedhundreds of millions in public money from Angola(Fitzgibbon 2020). The leaked documents alsorevealed how the businesswoman and herhusband controlled shell companies in the BritishThe use of shell companies is especially commonVirgin Islands, the Netherlands and Maltain offshore financial centres, which offer favourable(Freedberg et al. 2020). The Panama Papersconditions such as easy creation of bank accounts,discussed above revealed more than 214,000favourable tax treatment, non-disclosure ofoffshore entities that were connected to people ininformation, and reluctance to cooperate withmore than 200 countries and territoriesforeign law enforcement authorities (Koligkionis(International Consortium of Investigative2017: 1357; OECD 2001: 7-8). The light-touchJournalists 2017).regulation, low taxes and anonymity offered by theoffshore centres make them attractive to criminalsin possession of the proceeds of corruption oreconomic crime (Unger 2017: 22). This isevidenced by financial intelligence centres andlaw enforcement authorities having regularlyidentified criminals to be using corporate vehiclesand bank accounts established in tax havens(FATF 2018: 79).Foreign bribery cases have also included the useof shell companies to cover up the bribe paymentsand kickbacks (Dell 2020: 19). For instance, theAirbus scandal revealed how the Europeanaerospace group for years paid bribes to foreignofficials through shell companies (Carolan 2018;Hollinger, Beioley and Shubber 2020). In 2020, amultinational meat and agriculture company J&F,admitted to having created shell companies andThe use of shell companies as “getaway cars” byopened bank accounts for the shell companies incorrupt individuals and organised crime networksthe United States in order to facilitate payments ofhas been widely recorded. According to a 2011bribes and kickbacks to foreign officials in BrazilWorld Bank report, which reviewed 213 grand(US Department of Justice 2020).corruption cases from 1980 to 2010 in 80 differentcountries, at least 150 cases (about 70%) involvedthe use of a corporate vehicle that wholly orSimilarly, shell companies are used in economicand organised crime activities. Two decades ago,5Transparency International Anti-Corruption HelpdeskCorruption and economic crime

the OECD noted that almost every economic crimeaccounts of shell companies, gaining over 12involved the misuse of corporate entities asmillion (Europol 2020).criminals exploit these entities to disguise theorigins of their illicit gains (see foreword of OECDDespite the abundance of evidence on the abuse2001). Recent scandals have continued to showof shell companies by criminals and internationalthe abuse of shell companies for economic crimecommitments aimed at increasing beneficialby organised criminal groups. For example,ownership such as the G20 High Level Principlesinvestigations by the Organised Crime andon Beneficial Ownership Transparency, reformsCorruption Reporting Project on the Russianand implementation of the commitments haveLaundromat - a money laundering scheme thatbeen slow. For instance, recent investigations bymoved billions of dollars out of Russia - showedTransparency International and the Anti-Corruptionhow shell companies played a central part in theData Collective found that approximately 80 perscheme. The criminals created 21 shell companiescent of private investment funds in Luxembourg,in the United Kingdom, Cyprus and New Zealand.which is home to the largest number of investmentThese shell companies made 26,746 payments tofunds in Europe worth more than 4.5 trillion Euros,96 countries, passing almost without obstacle intostill hide the identity of beneficial owners (Szakonyisome of the world’s biggest banks (Organisedand Martini 2021: 2).Crime and Corruption Reporting Project 2017).Other research by Transparency International alsoA criminal organisation engaged in VAT fraudrevealed that only seven out of the 47 countriesacross Europe had a network of more than 100surveyed had public and central beneficialcompanies, mostly offshore, in different Europeanownership registers, while 17 countries includingcountries and in the US (Europol 2018). Thekey financial centres such as the United States4proceeds of fraud were layered in the network ofand Switzerland had no central registers in placecompanies before being moved to bank accounts,(Dell 2020: 20).with the criminal group laundering more than 140million in two years (Europol 2018a).In 2020, a joint operation by Europol, SpanishNational Police (Policía Nacional) and the USSecret Service dismantled an organised crimegroup involved in fraud and money laundering. TheThere are available international commitments thatmay help in preventing the use of shell companiesas conduits for corruption or economic crime.These include the following: G8 Action Plan Principles to prevent thecriminal network set up shell companies in themisuse of companies and legalUnited States and later opened bank accounts forarrangements, which contains measures tothese companies that allowed them to accessensure the integrity of beneficial ownershipdebit and credit cards. They then defrauded overand basic company information, the timely50 financial institutions through these bankaccess to such information by law4The United States recently enacted the Anti-MoneyLaundering Act of 2020, which includes measures onbeneficial ownership.6Transparency International Anti-Corruption HelpdeskCorruption and economic crime

enforcement for investigative purposes, aspublic registers of beneficial ownershipwell as, where appropriate, the legitimate(Transparency International 2021).commercial interests of the private sector. G20 High-Level Principles on BeneficialTransnational and/or organisednetworksOwnership Transparency, which set out“Modern forms of corruption” are typicallyconcrete measures that G20 countries willtransnational in nature, meaning that they involvetake to prevent the misuse of and ensuremore than one jurisdiction. For instance, foreigntransparency of legal persons and legalbribery cases involve transactions in more jurisdiction as multinational corporations“export corruption” through bribery of foreign public Recommendations 24 and 25 of theofficials (Dell 2020; Bueno 2017). In addition, thereFinancial Action Task Force, which providemay be an organised scheme in place, or inclusionthat countries should take measures toof various players in the scheme, similar toprevent the misuse of legal persons andeconomic or organised crime.arrangements for money laundering orterrorist financing, as well as ensure thatA good example is the Lava Javo investigation orthere is adequate, accurate and timely“Operation Car Wash” in Brazil, which unearthedinformation on beneficial enormous transnational scheme involving bothcorruption and economic crime. At first, the Lava The 4th and 5th European Union Anti-Javo investigation focused on a petrol station inMoney Laundering Directives, whichBrasília which was being used for moneyprovide measures for identification andlaundering purposes. It was then discovered that averification of beneficial ownershipblack-market money-dealer under investigationinformation. Article 30 (3) of the 4th EUalso had ties to a former director of Brazilian oilAnti-Money Laundering Directive providesgiants Petrobras, which had been awardedthat members states should ensure thatimportant government contracts. This led to thebeneficial ownership information is held inexpansion of the investigation, which latera central or public register.unearthed one of the largest grand corruptionschemes in Brazil (Watt 2017; The EconomistA public register on beneficial ownership would2021).assist in addressing both corruption and economiccrime by ensuring that dirty money is not hiddenAccording to investigators, a network of more thanthrough shell companies. At the time of writing,20 corporations – including Brazilian oil andmore than 700 civil society organisations,construction giants, Petrobras and Odebrecht –renowned academics, businesses, businesswere involved in bribes and kickbacks in Latinleaders and public officials have signed a petitionAmerica and Africa (Smith, Valle and Schmidtasking the United Nations General Assembly2017; Nolen 2019; Pinotti 2020). In 2016,Special Session against Corruption, UNGASSOdebrecht admitted in the US District Court in2021, to require all countries to set up central,Brooklyn to having paid about US 788 million in7Transparency International Anti-Corruption HelpdeskCorruption and economic crime

bribes in 12 countries across Latin American and5For instance, Europol assisted Italian andAfrica, which helped it to secure more than 100Romanian enforcement authorities to disrupt ancontracts that generated around US 3.3 billion ininternational criminal network responsible forprofits for the company (US Department of Justicelarge-scale misuse of compromised payment card2016).data and money laundering (Europol 2017: 32). Inaddition, German law enforcement authorities inOdebrecht even established a "Division ofclose cooperation with the United States Attorney’sStructured Operations” which reportedly operatedOffice for the Western District of Pennsylvania, thea systematic bribery scheme, and had off-bookDepartment of Justice and the FBI, Europol,contact with outside financial operators and otherEurojust and other global partners, took down anco-conspirators regarding bribes via secure emailsinternational criminal infrastructure platform knownand instant messages, using codenames andas ‘Avalanche.’ This had been used to launch andpasswords. A Brazilian petrochemical company,manage mass global malware attacks and moneyBraskem S.A, admitted to transferring US 250mule recruiting campaigns. The network wasmillion into Odebrecht’s secret, off-book bribeestimated to have illicitly obtained hundreds ofpayment system, and authorised the payment ofmillions worldwide, and it took more than fourbribes to politicians and political parties in Brazilyears of investigation and a network involvingand to an official of Petrobras, helping theprosecutors and investigators from 30 countries tocompany to make approximately US 465 millionsuccessfully take it down (Europol 2017: 28).(US Department of Justice 2016).Transnational crime groups in Europe areAs pointed earlier, the investigation was initiallyincreasingly involved in VAT fraud schemes. Mosttargeted at black-market money-dealers engagedof the VAT schemes are carried out by organisedin economic crime but eventually unearthed ties tocriminals groups that operate in different countriesPetrobas, which was running a transnationaland can only be dismantled through internationalcorruption scheme. This shows the interlinkagescooperation (Europol 2018a). It is estimated thatbetween corruption and economic crime, as twoVAT fraud schemes cost the European Unionset of crimes may cross paths.about 60 billion euros annually in tax losses (KleinEconomic crimes also transcend national bordersin an organised manner for centuries, with2020).Use of professional enablerstransnational organised groups engaging ineconomic crime such as fraud, counterfeitinggoods, schemes and scams, tax crimes, moneylaundering, and even some aspects of cybercrime((Passas 1999: 399; Pieth 2009).Although there are various ways to launderproceeds of crime, it is often the professionalenablers who wittingly or unwittingly becomeinvolved in the establishment of complexprocesses or transactions that help criminals andthe corrupt to successfully disguise illicit funds5These countries are Angola, Argentina, Brazil, Colombia,Dominican Republic, Ecuador, Guatemala, Mexico,Mozambique, Panama, Peru and Venezuela. 19916/download8Transparency International Anti-Corruption HelpdeskCorruption and economic crime

(FATF 2011:19-21; Duri 2020; Levi 2020). Theseof crime. According to leaked information, the lawprofessional enablers are the gatekeepers of thefirm Mossack Fonseca worked with at least 14,000financial system “through which potential users ofbanks, law firms, company incorporators and otherthe system, including launderers, must pass inintermediaries to establish corporate vehicles fororder to be successful” (FATF 2010: 44).their customers, in many cases without verificationof the client’s identities and systemic failure toCriminals may take advantage of thereport suspicious transactions (Internationalprofessionals’ specialised knowledge andConsortium of Investigative Journalists 2017). Inexpertise to identify and exploit legal loopholes, toaddition to the 140 politicians identified in theidentify new lucrative opportunities, and to assist ininvestigations (International Consortium ofthe creation of corporate structures or offshoreInvestigative Journalists 2017), it was reported thatbank accounts to clean the proceeds of crimeEuropol matched 3,500 names in the files to(FATF 2018: 11; OECD 2021: 13). In otherindividuals linked to terrorism, money launderinginstances, the personal position or reputation ofand organised crime (Pegg 2016).the professional may minimise any suspicion andthereby the risk of detection of the involvedDetails from the recent FinCEN files, the leakedcriminal activities by lending some credibility dueinformation of more than 2,500 suspiciousto presumed ethical standards, or because theirtransaction reports involving US 2 trillion ofprofession permits undertaking of transactions ortransactions, showed that major banks such asarrangements that avoid suspicion (FATF 2010:JPMorgan Chase, HSBC, Standard Chartered,44). They may even falsify documents that furtherDeutsche Bank, and Bank of New York Melloncriminal activities of their clients and assist clientscontinued being used to move money forin committing fraudulent transactions (OECD 2021:suspected criminals despite previously receiving15-17).heavy fines for the similar misconduct (Leopold etal. 2020). Concerning is the fact that banks oftenIn some cases, criminals even make use ofdid not identify and report suspicious transactionsprofessional money launderers - professionalto authorities in a timely manner. They also seemindividuals, organisations and networks that areto have failed to terminate financial relationshipsinvolved in third party laundering for a fee ordespite identifying numerous suspiciouscommission - who provide services to criminalstransactions involving the same client.Forand organised criminal groups by laundering theinstance, Deutsche Bank appear to haveproceeds of their illegal activities (FATF 2018b).continued to facilitate the laundering of US 10Revelations about how professional individualsand firms assist in the commission, or cover up ofcorruption and other forms of economic crimecontinue to emerge regularly. A classic example isbillion of a Ponzi scheme linked to crime bosses,terrorist financiers and drug cartels despite the factthat suspicions had been raised (Warren et al.2020).the Panama Papers, which contained details onThe recent Troika Laundromat investigationshow professional enablers aided both kleptocratsrevealed how IOS Group, a Latvian-Irish companyand organised crime groups to hide the proceedsformation business, created shell companies for its9Transparency International Anti-Corruption HelpdeskCorruption and economic crime

international clients and reportedly played a role inCorruption and organised crime may go hand inmultiple high-profile money laundering cases. Thehand in capture of state institutions. For instance,company set up at least 35 of the 75 offshorePrezelj and Vogrinčič (2020: 549) argue that statecompanies implicated in the Laundromat, andcapture in the Western Balkans include playersprovided nominal shareholders and directors insuch as organised criminal groups, businessmen,order to hide the identities of the true owners.politicians, the judiciary, the security services, and(Stack, Papakheli and Wrate 2017).paramilitary or terrorist groups. The collusionbetween organised criminal groups andDue to the involvement of transnational networksintelligence agencies, military establishments orin corruption and economic crime, internationalpolice services means that organised criminals arecooperation is required for effective detection,untouchable and has reduced the capacity of theprosecution and recovery of proceeds. Forstate to prosecute organised crime and corruptioninstance:(Prezelj and Vogrinčič 2020: 551, 555). In such Recommendations of the Financial ActionTask Force, which require professionalindividuals and entities that act asgatekeepers of the financial system tocarry out anti-money laundering situations, corruption could be the “grease in thewheels” that smoothens interactions betweenorganised criminals and the state, allowingorganised economic crime to go unpunished andinfiltrate state organs.obligations such as customer dueCorruption and capture of state institutions bydiligence.organised criminals can also result in “narco-Principles 7 of the G20 High-Levelstates” (González 2013). For instance, thePrinciples on Beneficial OwnershipMexican President Andrés Manuel-LopézTransparency which provide application ofObrador recently blamed past administrations foranti-money laundering obligations toinstilling a culture of corruption that permittedgatekeepers or professional enablers.notorious drug trafficking organisations to operateCapture of state institutionswith impunity (Neal 2020), with evidence on seniorpublic officials colluding with drug lords (USA trait of modern forms of corruption is theDepartment of Justice 2019). In Italy, capture oftendency to try and co-opt state institutions andlocal government authorities results in organisedpolitical parties to reduce risks that will damagegroups influencing how public resources aretheir interests, in a similar fashion imploredallocated or even who gets political power (Europ

economic crime. In your overview, please include a discussion on what is meant by "modern forms of corruption" Contents 1. Introduction 2. Common characteristics between corruption and economic crime 3. Conclusion 4. References Introduction Corruption sometimes is mistaken as a synonym of economic crime, despite the distinction between

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