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Whitewashing

National Risk Assessment 2022 - Money Laundering and Terrorist Financing

Ecocrim believes accountants are at significant risk of being exposed to attempted money laundering

Ecocrim assumes that digitalization in combination with social manipulation seems to be a particularly big threat in today's crime picture.

It is further pointed out that much of the serious financial crime is camouflaged by the offenders conducting transactions and organising ownership in a non-transparent manner. This presents challenges in identifying real rights holders, which is further complicated if the clients are foreign legal entities, shell companies, tax havens and client accounts are used in the transaction chain.

Read about National Risk Assessment 2022

Crime in key sectors

The report provides an overview that is useful for gaining more insight into which transactions are important to pay attention to. Below we provide some key words on sectors and crime that are discussed in more detail.

Chapter 2.2 of the report discusses challenges faced by several sectors. Among the sectors specifically addressed are:

  • oil and gas sector
  • renewables
  • fishery and aquaculture industry
  • real estate development, building and construction
  • service sector
  • trade in goods

The report further discusses different types of crime in Chapter 2.3. Besides money laundering related to traditional crime, there is mention of, among other things:

  • digital fraud
  • ransomware and data breaches
  • cryptocurrency exchangers
  • mixing services
  • digital art
  • Neobanks
  • foreign gaming companies
  • prepaid cards
  • Workplace crime
  • fishing crime
  • corruption
  • Bankruptcy crime
  • Fraud of the public
  • cross-border VAT fraud
  • use of corporate structures
  • trade-based money laundering
  • money laundering via the real estate market

Risks of Reportable Persons

Banks, payment processors and agents of foreign payment companies are considered to be at high risk of being used to launder proceeds of crime.

Payment firms, lawyers and accountants are considered to be at higher risk than in the previous NRA:

The report addresses the threats, vulnerabilities and risks of each of the sectors that are required to report under the Money Laundering Act.

Chartered Accountants

Accountants are particularly susceptible to creating legitimacy for their principals. This can facilitate money laundering through fictitious invoicing, tax and fee evasion, workplace crime as well as the cover-up of real rights holders and the origin of the funds.

Ekokrim also shows that accountants can assist criminals through inadequate follow-up. This involves, among other things, not being critical enough of the documentation handed over by the client.

Advisory services and payment commissions are highlighted as particularly vulnerable services.

According to Ekokrim's new assessment, the risk associated with money laundering has been adjusted from moderate to significant. The justification for this lies mainly on the assessment of the ability to prevent or detect that the client is involved in money laundering. The assessment is not based on a real increased risk, but on a more extensive information basis.

It requires the experience and familiarity of a customer before recognizing a transaction pattern that indicates money laundering. New customer assignments will therefore involve a greater risk of not detecting money laundering.

The full overview of the accounting industry can be found in Chapter 4.10.

Source: Regnskap Norge, written by Knut Høylie, Regnskap Norge

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