ABSTRACT
Money laundering and terrorism financing (ML/TF) are criminalized activities, deemed to cause physical, social, environmental, economic and structural harms at the individual, community and national level (FATF 2010b). Fighting ML/TF, therefore, has become the cornerstone of an international battle against serious and organized crime (FATF 2010a). Governments all over the world have adopted a number of regulatory and procedural initiatives to disrupt the movement of funds originating from, or used to finance, certain criminal activities. The European Commission, for instance, has developed directives that provide a common set of rules to the member states of the European Union (Mohamed 1995), and various countries have created specialized government agencies to gather intelligence related to ML/FT (Egmont Group 2004).
