1 Auctions 1 Mr X Agent A Agent B Agent C In person bids Telephone bids Online bids 3 rd Party Purchaser Layering Integration Copyright Lessons Learned Ltd 2016 ID: 724232
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Copyright Lessons Learned Ltd 2016
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Auctions (1)
Mr X
Agent A
Agent B
Agent C
In person bids
Telephone bids
Online bids
3
rd
Party Purchaser
Layering
IntegrationSlide2
Copyright Lessons Learned Ltd 2016
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Auctions (2)
Key facts
Use in money laundering: to introduce criminal cash into the system (placement) or to ‘turn over’ purchase and sale of high value items as part of layeringVulnerable areas: real estate, cars, fine art, antiques
Stolen property: auctions as point of sale for stolen goodsOnline auctions: relatively unregulated, relative anonymity, anyone can buy or sell directly with anyone elseMoney launderers’ perspectiveTransactions can be done ‘in absentia’ – telephone bids, online transactionsNormal to act via an intermediary/agentTransactions are ‘one-offs’Slide3
Copyright Lessons Learned Ltd 2016
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Auctions (3)
Possible ‘red flags’
Successful high value bidders who are unwilling or unable to identify themselvesThird party intermediaries who are unwilling or unable to identify their clientsCash settlement of high value purchases, where use of cash would be unusual
Large-scale purchase of multiple items which cannot be explained and does not match the apparent business of the purchaser (e.g., car dealership, property developer)