<![CDATA[MONEYLAUNDERING.IE - Typologies]]>Wed, 15 Jan 2025 12:14:20 +0000Weebly<![CDATA[20250109 Cohort #1 of Central Bank of Ireland’s Innovation Sandbox Programme: ‘Combatting Financial Crime’]]>Thu, 09 Jan 2025 14:14:32 GMThttp://moneylaundering.ie/typologies/20250109-cohort-1-of-central-bank-of-irelands-innovation-sandbox-programme-combatting-financial-crime
This is not a typology but a relevant piece of news about the fight against financial crime pursued by the Central Bank of Ireland.
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Seven participants of the Central Bank of Ireland’s Innovation Sandbox Programme on ‘Combatting Financial Crime’ are:

1) AMLYZE is building an AML/CFT information-sharing framework that will use structured taxonomies and synthetic data to simplify detecting and preventing fraudulent activities.
2) Expleo Group has developed an anti-SMS fraud solution which installs on mobile phones to combat SMS fraud.
3) Forward Emphasis and Pasabi’s joint innovation will develop and test a Motor Insurance Application Fraud Analytics solution, leveraging AI-driven behavioural analytics, machine learning, and pattern recognition to detect fraud in the pre-sales process.
4) Roseman Labs enables secure, GDPR-compliant collaboration and analysis on sensitive data for regulated industries.
5) Sedicii (hello Rob Leslie) and PTSB Sedicii has partnered with PTSB to create a secure and private collaboration using zero knowledge proofs to verify names and addresses, in real-time, as part of their customer KYC process, using ESB Networks as the authority for address data in Ireland in full compliance with GDPR and which involves no sharing of personal data.
6) TrustElevate.com offers a privacy-preserving solution for verifying parental responsibility and child age.
7) Vidos.Id is developing digital identity verification solutions to help financial institutions verify digital identity documents and wallet-based credentials.
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<![CDATA[20241024 - 26y.o former Bank of Ireland Employee jailed for 3 years.  Several others convicted of laundering]]>Thu, 24 Oct 2024 00:00:00 GMThttp://moneylaundering.ie/typologies/20241024-26yo-former-bank-of-ireland-employee-jailed-for-3-years-10-people-convicted-of-laundering
Funmi Abimbola jailed for three years
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What Happened?

Funmi Abimbola, a 26-year-old bank worker from Ireland, has been sent to prison for three years for aiding the Black Axe organised crime group in money laundering operations. Abimbola was in fact sentenced in the Circuit Criminal Court today to five years in prison with two suspended. 

Black Axe, known as a highly dangerous transnational organisation, is involved in various criminal activities, including fraud, trafficking, and violent crimes. Abimbola, who had a master's degree and a respectable position at the Bank of Ireland, was responsible for managing money mules and handling accounts for the group in Ireland. His criminal activities were uncovered during a broader investigation by the Garda National Economic Crime Bureau (GNECB) and Interpol into the Black Axe organisation.

Abimbola's involvement became apparent after the investigation into a €1 million invoice redirection fraud from a solicitor’s office. Authorities found him using false identities, purchasing items with laundered money, and coordinating through encrypted messaging platforms with other members of the criminal group. Despite being initially released on bail, Abimbola fled to the UK but was later extradited back to Ireland, where he received a five-year sentence, two of which were suspended. Several other individuals associated with the money laundering scheme received suspended sentences.

Of the €1m stolen from the solicitor’s office €700,000 of that money was recovered and ten people were convicted of laundering the money.
Judge Pauline Codd said that he was "effectively oiling the wheels" of this crime.  The judge also noted the irony of Abimbola having worked for Bank of Ireland during the commission of some of the offences. 
Gardaí and Interpol have been focused on the activities of the organised crime group known as Black Axe which originated in West Africa but has a global footprint. Black Axe has been  involved in online fraud, human trafficking, drugs and gun crime as well as murder.
Others convicted include:
  • Cameron Fanning 25 - pleaded guilty to two counts of money laundering from the solicitor's firm on 9 November 2020 and one count of giving false information about his bank account to gardaí. Sentenced to three and half years in prison, suspended in full on strict conditions.
  • Mubarak Salawu, 22 - pleaded guilty to one count of money laundering in relation to the stolen monies which were credited to his account and an unrelated charge of possessing a pair of €600 Balenciaga runners bought from the proceeds of crime. Suspended two-year prison sentence.
  • Olumide Lawal, 27 - admitted two counts of money laundering and possession of a €900 iPhone bought using the proceeds of crime. Given a suspended two-year sentence.
  • Aaron Clancy, 21 - pleaded guilty to possessing €3,020, the proceeds of money laundering, in relation to the solicitor's firm and a further unrelated count of possessing €4,650, the proceeds of crime.  Received a suspended prison sentence of two years.
Lessons for MLROs

This case underscores critical areas of focus for Money Laundering Reporting Officers (MLROs):
  1. Enhanced Employee Monitoring: Abimbola’s role as a bank employee gave him the knowledge to exploit bank systems. MLROs should implement robust internal controls and monitor employees in sensitive roles to detect unusual behavior patterns.
  2. Fraud Detection: The invoice redirection fraud highlights the need for vigilant detection systems around financial transactions, particularly large sums and high-risk entities.
  3. Cross-Border Collaboration: The transnational nature of Black Axe’s operations exemplifies the importance of cross-border cooperation in identifying and curtailing complex money laundering schemes.
  4. Rapid Response to Suspicious Activity: Abimbola’s case illustrates that quick responses to internal and external red flags—such as abnormal bank transactions, unusual cash handling, or interactions with known criminals—can prevent escalation and assist in ongoing investigations.
  5. Adaptation to Evolving Criminal Methods: Criminal tactics constantly shift, as shown by Black Axe’s pre-pandemic strategies compared to their current operations. Continuous learning and adaptation are essential for MLROs to stay ahead of evolving threats.
Sources:
  • https://www.rte.ie/news/courts/2024/1023/1477127-funmi-abimbola-crime-gang-jailed/
  • https://www.breakingnews.ie/ireland/bank-worker-jailed-for-money-laundering-and-assisting-organised-crime-1686765.html
  • https://www.irishtimes.com/crime-law/courts/2024/10/24/bank-worker-jailed-for-laundering-money-for-black-axe-international-crime-gang/ (limited free access)

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<![CDATA[20241013 - Ex-garda warns proposed gambling laws will be hard to police]]>Sun, 13 Oct 2024 00:00:00 GMThttp://moneylaundering.ie/typologies/20241013-ex-garda-warns-proposed-gambling-laws-will-be-hard-to-police
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A former senior garda has warned proposed new gambling laws restricting stakes and winnings will increase black market betting and lead to resource challenges for the force.

Pat Lordan, a former chief superintendent at the Garda National Economic Crime Bureau, said the Government’s new Gambling Regulation Bill poses increased money laundering risks.

He said “over regulating” the gambling industry will encourage criminal networks to facilitate underground markets which are difficult to police.

“It is resource intensive if you have to go to every casino in the country that is legal and not legal, because they are not going to have a sign over the door,” he added.

“It will fall back to Johnny the guard down in Dingle to go out on his pushbike and see if there is any gambling there in the shed of a house.”


Source: 
​https://www.independent.ie/irish-news/ex-garda-warns-proposed-gambling-laws-will-be-hard-to-police/a1806305629.html

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<![CDATA[20241010 - Bitcoin seized by Cab soars in value to more than €350m]]>Thu, 10 Oct 2024 00:00:00 GMThttp://moneylaundering.ie/typologies/20241010-bitcoin-seized-by-cab-soars-in-value-to-more-than-eur350m
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1.  What Happened?
 It seems that the Criminal Assets Bureau (CAB) is facing a significant challenge in accessing €345 million in Bitcoin seized from Crumlin drug dealer Clifton Collins. The Bitcoin, originally valued at €53 million when seized in 2019, is locked away in 12 digital wallets, with the keys to access them reportedly missing.  Collins created 12 wallets for storing the bitcoin and recorded the codes, or digital keys, for each in a document. Collins decided it would be safer to disperse his growing fortune across multiple virtual wallets that hold the cryptocurrency. 

The Bitcoin was uncovered by the Garda after an operation targeting Collins (in 2019) when it was valued at €53 million. Garda has effectively been sitting on the asset, hoping advances in technology will lead to it being unlocked, it has soared in value to €345 million.

Collins – a 53-year-old former beekeeper – grew cannabis crops in rented houses and sold the harvested drug to criminals, including in his native Crumlin. He was apprehended in 2017 after a cannabis growing operation was discovered by chance  after years of operating under the radar. Gardaí on a routine patrol spotted a car parked at Military Road near Sally Gap in Co Wicklow in the early hours of the morning and went to check on it. Cannabis herb valued at €2,000 was found in the car, driven by Collins.

A subsequent investigation discovered he had been using three rented houses – in Galway, Meath and Longford – to grow cannabis. In the property in Galway, gardaí discovered a crop valued at €400,000 and Collins was later jailed for five years.

Eventually the Irish 
High Court ruled that the Bitcoin was derived from criminal activity. While Collins had handed over some Bitcoin and a code to a portion of his stash, the bulk remains inaccessible due to the lost key, which was hidden in a fishing rod that has since gone missing.  

Collins invested some of the proceeds of his drugs business in bitcoin, when it was worth only a fraction of its current value, in 2011 and 2012. As the virtual currency increased in value, Collins decided it would be safer to disperse his growing fortune across multiple virtual wallets that hold the cryptocurrency. The keys for the 12 wallets were written on documents and then hidden in a fishing rod case at one of his rented properties, in Co Galway. In interviews with gardaí he claimed he never saw the case again after a break-in at his home. However, a clear-out of the property after his arrest may also have resulted in the loss of the document.

In late 2020, Collins surrendered assets worth €1.2 million to the State as they were the proceeds of crime. They included €1 million in bitcoin, which he had the key codes for, as well as a two-seater Gyro aircraft, a camper van and a fishing boat.

Despite the value of the Bitcoin skyrocketing, CAB is hopeful that advances in technology will eventually allow them to unlock the wallets. In the meantime, they have liquidated other assets and sold accessible Bitcoin to benefit the state. Collins remains a significant case for the CAB, marking him as their largest financial loss to date. The outcome of this situation will depend on future technological developments or the recovery of the missing key.

Pursuing Bitcoin as the Proceeds of Crime is not new

The Chief Bureau Officer of CAB informed Irish media way back in October 2021 that CAB is targeting the seizure of cryptocurrencies, however, the value of cryptoassets can be difficult to realise.  Back then Detective Chief Superintendent Michael Gubbins said cryptocurrency plays a part in some of the assets that CAB has seized and while there is a substantial value to the cryptocurrency, "we just don't have the keys to get that".

2.  What’s interesting?
  • For AML professionals, cryptocurrency is becoming a regulated 'asset class' under MiCAR, just like 'financial instruments' are under MiFID.  This means is will be more and more common for regulated firms to be doing business with crypto firms.  Firstly,  banning 'crypto' outright in a world where it is regulated will no longer an option. Secondly, care will need to be taken as part of the CDD to ensure that the source of the crypto is legitimate and that the counterparty/introducer is regulated in a trustworthy jurisdiction.
  • It highlights the fact that despite access to high levels of resources and technology, law enforcement are not necessarily unable to break cryptography security measures of cold wallets.
Source:
  • https://www.sundayworld.com/crime/irish-crime/cab-still-unable-to-access-350-million-in-bitcoin-seized-from-crumlin-dealer/a128832277.html
  • ​https://www.irishtimes.com/crime-law/2024/10/09/bitcoin-seized-by-cab-soars-in-value-to-more-than-350m/
  • https://www.rte.ie/news/business/2021/1015/1253984-value-of-seized-cryptocurrencies-difficult-to-realise/
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<![CDATA[20241004 - Man accused of having €335k in crime proceeds after 'romance fraud' investigation]]>Fri, 04 Oct 2024 00:00:00 GMThttp://moneylaundering.ie/typologies/20241004-man-accused-of-having-eur335k-in-crime-proceeds-after-romance-fraud-investigationWritten by a www.MoneyLaundering.ie Guest Contributor
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1.  Summary
  • A suspect was charged in connection with possessing €335,000 in alleged crime proceeds after a Garda investigation into a "romance fraud" scheme.
  • The investigation by the Garda National Economic Crime Bureau (GNECB) revealed that the funds were suspected to be proceeds of crime obtained from victims through romance scams.
  • The offenses allegedly took place between February 2017 and February 2020, with additional charges linked to transactions in 2021.
  • The suspect has been prohibited from using dating websites as part of bail conditions and will face trial at a later date.
  • The case involves international victims, including a person from Finland.

2.  What’s interesting
  • For AML professionals, this case is notable due to its connection to a "romance fraud" typology, where significant crime proceeds were funneled through personal relationships.
  • It highlights the importance of monitoring unusual financial transactions linked to personal accounts, as romance scams often involve victims unknowingly laundering funds. 
Source:
  • https://www.breakingnews.ie/ireland/cocaine-worth-e6m-seized-as-garda-investigation-targets-major-irish-crime-cartel-1672903.html
  • https://www.rte.ie/news/crime/2024/0917/1470476-drug-seizsure/
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<![CDATA[20240930 - Man in court charged over €1.4m gold bullion discovery]]>Mon, 30 Sep 2024 00:00:00 GMThttp://moneylaundering.ie/typologies/20240930-man-in-court-charged-over-eur14m-gold-bullion-discovery
Written by a www.MoneyLaundering.ie Guest Contributor
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Summary
  • A suspect appeared in Blanchardstown District Court charged with offenses related to the discovery of €1.4 million worth of gold bullion in Dublin.
  • The Gardaí seized €460,000 in cash and €210,000 in suspected cocaine and ecstasy during the operation.
  • The suspect faces multiple charges, including money laundering, theft, fraud involving false documents, possession of drugs, and supply of drugs.
  • Two women were also arrested in connection with the case and can be held for up to seven days for questioning.
  • The suspect has been remanded in custody and will appear via video link from Cloverhill prison.

What’s interesting
  • For AML professionals, this case is notable due to the significant amount of cash and drugs involved, which suggest potential money laundering activities.
  • The operation's complexity—linking gold bullion, cash, and narcotics—highlights the need for robust compliance measures to detect and prevent financial crime.
  • Additionally, the involvement of false documents emphasizes the importance of thorough due diligence and monitoring of transactions to combat fraud and illicit activities within financial systems.

Source:
  • https://www.breakingnews.ie/ireland/man-in-court-charged-over-1-4-million-euro-gold-bullion-discovery-1677860.html
  • https://www.bbc.com/news/articles/c3e9zkpd0nxo
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<![CDATA[20240917 - Cocaine worth €6m seized as Garda investigation targets major Irish crime cartel]]>Tue, 17 Sep 2024 00:00:00 GMThttp://moneylaundering.ie/typologies/20240917-cocaine-worth-eur6m-seized-as-garda-investigation-targets-major-irish-crime-cartel
Written by a www.MoneyLaundering.ie Guest Contributor
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1.  Summary
  • Gardaí seized approximately €6 million worth of cocaine in an international crackdown targeting a major Irish crime cartel.
  • The operation, involving Europol, the FBI, and other international agencies, targeted a drugs gang based in west Dublin and other criminal figures.
  • The investigation disrupted an encrypted communication platform used for drug trafficking, homicides, and money laundering.
  • Raids were conducted in Co Wexford and Dublin, leading to several arrests.
  • The cartel, though smaller than the Kinahan group, has been a Garda target for decades due to its significant criminal operations.

2.  What’s interesting
  • For AML professionals, the most notable aspect of this case is the collaboration between multiple international law enforcement agencies, including Europol and the FBI, to dismantle a communication network used for drug trafficking, homicides, and money laundering.
  • It underscores the need for organizations to monitor the use of encrypted platforms and conduct robust due diligence on communication methods that could be exploited by criminal enterprises.
  • Additionally, it highlights the value of cross-border cooperation in combatting sophisticated crime cartels with a long history of illicit activity.
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<![CDATA[20240912 - Man charged over money laundering offences in Finglas]]>Thu, 12 Sep 2024 00:00:00 GMThttp://moneylaundering.ie/typologies/20240912-man-charged-over-money-laundering-offences-in-finglas
Written by a www.MoneyLaundering.ie Guest Contributor
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1.  Summary
  • i. A man was formally charged in relation to multiple money laundering offenses in the Finglas area of Dublin. He was brought before the Criminal Courts of Justice, where he faced the charges.
  • ii. The arrest followed an ongoing investigation by law enforcement targeting financial crimes linked to the area.
  • iii.A woman, also arrested as part of the same operation, was questioned and subsequently released without charge.
  • iv. The authorities are continuing their inquiries, and a file will be submitted to the Director of Public Prosecutions (DPP) for further action.
  • v. The case highlights the increased focus on tackling money laundering and financial crime in Dublin.

2.  What’s interesting
  • i. The most notable aspect of this case for AML professionals is the involvement of multiple individuals and the use of coordinated arrests in targeting a money laundering scheme.
  • ii. It shows the importance of collaboration between law enforcement agencies in detecting suspicious financial activities and their ability to track down and charge individuals involved.
  • iii. Additionally, the case highlights the necessity of monitoring regional financial crime trends, particularly in areas like Finglas, which might be emerging hotspots for such illicit activities.
Source: 
  • ​https://www.breakingnews.ie/ireland/man-charged-over-money-laundering-offences-in-finglas-1671309.html
  • https://www.garda.ie/en/about-us/our-departments/office-of-corporate-communications/press-releases/2024/september/arrests-gnecb-money-laundering-investigations-finglas-dublin-9th-september-2024.html
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<![CDATA[20240909 - Land seized in Clare after investigation into organised criminal gang]]>Mon, 09 Sep 2024 00:00:00 GMThttp://moneylaundering.ie/typologies/20240909-land-seized-in-clare-after-investigation-into-organised-criminal-gang
Written by a www.MoneyLaundering.ie Guest Contributor
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​Land seized in Clare after investigation into organised criminal gang - Agriland.ie

1.  Summary
  • The Criminal Assets Bureau (CAB) seized a house, 20-stable livery yard, and 18.35 acres of land in Clare as part of an investigation into an organized criminal gang in the Munster region.
  • The assets were linked to a suspect whose criminal activities funded the property purchase.
  • Court orders under the Proceeds of Crime Act were issued in 2016 and later in 2024.
  • Evidence revealed €223,500 in criminal funds was used to buy the property in 2012.
  • A money laundering scheme involving Irish and Spanish bank accounts was dismantled during the investigation.

2.  What’s interesting
  • The most notable aspect of this case for AML professionals is the effective use of the Proceeds of Crime Act and the Criminal Assets Bureau’s approach to tracing criminal funds used to purchase property.
  • The investigation revealed a complex money laundering scheme involving cross-border transactions through Irish and Spanish bank accounts.
  • This demonstrates the importance of monitoring property acquisitions and bank account movements, as well as the effectiveness of leveraging legal frameworks to disrupt organized crime operations and recover assets
Source:
https://www.agriland.ie/farming-news/land-seized-in-clare-after-investigation-into-organised-criminal-gang/
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<![CDATA[20240815 - Man arrested in Dublin after being identified as suspected money mule herder]]>Thu, 15 Aug 2024 00:00:00 GMThttp://moneylaundering.ie/typologies/20240815-man-arrested-in-dublin-after-being-identified-as-suspected-money-mule-herder
Written by a www.MoneyLaundering.ie Guest Contributor
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What happened?

What happened?

A man has been arrested after being identified as a suspected money mule herder following the search of a residence in West Tallaght, Dublin.

Gardaí from the Garda National Economic Crime Bureau (GNECB) carried out a search at the property as part of a larger investigation into incidents of fraud in Norway, Germany, the US, Hawaii and Ireland.

The investigation also looked into the subsequent laundering of money through money mule accounts, businesses, and trade-based money laundering operations.

"Up to 50 different money mules have been identified as having laundered over €196,000 through his bank accounts in Ireland, Germany and Belgium," a Garda spokesperson said.

"This money came from victims of mainly smishing frauds in Ireland, was initially laundered through these 50 money mule accounts and then forwarded by the money mules to the suspects' three bank accounts."

During the course of the search, a number of items, including a "high value" Range Rover, which was suspected to have been purchased with the proceeds of crime, were seized.
The following items were also seized:
  • A number of passports;
  • Bank cards in family names and names of suspected money mules;
  • Bank account details;
  • Details of registered companies and businesses;
  • Cash in euros and dollars;
  • A note teller (cash counting machine);
  • 30 mobile phones;
  • A desktop computer and laptop.
Picture
Range Rover seized by Gardai

What’s interesting?

What’s interesting?
  • Recruitment and Management of Money Mules: The suspect was involved in recruiting and managing up to 50 money mules, which indicates a well-organized operation aimed at facilitating large-scale money laundering.
  • International Fraud Connections: The investigation linked fraud incidents across multiple countries, including Norway, Germany, the US, and Ireland, suggesting a sophisticated and transnational criminal network.
  • Suspicious Possessions and Transactions: The seizure of high-value items like a Range Rover, multiple passports, and large amounts of cash, along with the use of numerous bank accounts and mobile devices, all point to significant money laundering activities.
Source: ​https://www.irishexaminer.com/news/courtandcrime/arid-41205400.html
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