Money laundering and illicit financial flows

The industry that facilitates the world's worst crimes

May 20, 2025

I wrote this blog post because I believe that illicit finance is our greatest problem. Everywhere I look on the internet is awareness of climate change, inequality, war, … etc. However, I think, a necessary cause (one of many causes) of these issues is the manipulation of numbers. And we should be paying more attention! While street crime captures headlines, the economic devastation wrought by financial crime is orders of magnitude greater, yet often remains hidden in plain sight.

The scale of the problem is staggering. Estimates suggest that the amount of money laundered globally in one year is between 2% and 5% of global GDP, or 800 billion to 2 trillion USD. 1 Illicit Financial Flows (IFFs) from developing and emerging economies are estimated to be even higher, with some reports suggesting figures upwards of 1 trillion per year siphoned away from countries that can least afford it. 2 To put this in perspective, the annual global cost of money laundering dwarfs the estimated annual cost of all “street crimes” combined. For instance, in the United States alone, white-collar crime is estimated to cost between 300 and 660 billion annually, whereas one study from 1997 estimated the annual economic loss from street crime at 13 billion compared to 415 billion for white-collar crime at that time. This isn’t to minimize the impact of ordinary crime, but to highlight the colossal financial shadow cast by illicit finance.

What is money laundering and how does it do harm?

Money laundering is the criminal offense of processing criminal proceeds to disguise their illegal origin. 3 This process is of critical importance, as it enables the criminal to enjoy these profits without jeopardising their source.

But why is this process necessary? Money is useless if you can’t spend it without raising suspicion. Would you accept a suitcase full of cash from a known drug lord for your house? Probably not? Financial institutions are also (supposed to be) wary of such transactions. This is where money laundering comes in. It’s the process of making “dirty” money – money obtained from criminal activities like drug trafficking, corruption, or fraud – appear “clean” by disguising its illegal origins. The goal is to make these funds look like they came from a legitimate source, allowing criminals to use them without detection.

Balance sheets, principal ownership, international transactions, …, are abstract ideas. How does the manipulation of numbers cause harm in the real world? Illicit financial flows (IFFs) drain resources from economies, worsen inequality, fuel instability, and undermine trust in institutions. 4 They are the facilitator of many of the world’s most devastating problems.

Imagine a vast, invisible plumbing system running beneath the surface of our global society. Instead of water, it carries illicit money – the lifeblood of crime and corruption. This system has countless hidden pipes, secret valves, and opaque reservoirs, all designed by skilled technicians (the enablers) to ensure the dirty money flows smoothly from its criminal source to a seemingly legitimate destination. Every time a kleptocrat loots a nation’s treasury, a drug cartel sells its poison, or a human trafficker exploits a victim, this dark plumbing ensures their profits can be used, reinvested, and enjoyed. The leaks from this system don’t just stain the ground; they poison the wells of public services, erode the foundations of democracy, and irrigate the fields of conflict and suffering. Money laundering isn’t just about numbers; it’s about this system that makes widespread, large-scale criminality viable. The sheer volume of illicit funds flowing through this system means its impact on ordinary people and global stability is far more pervasive and damaging than more visible, conventional crimes.

Let’s look at some examples of the devastation this “dark plumbing” enables:

Kleptocrats

Kleptocrat: “a ruler who uses their power to steal their country’s resources.”

Viktor Yanukovych

Viktor Yanukovych, former President of Ukraine, and his associates, known as ‘the Family’, are believed to have embezzled as much as $37 billion from Ukraine during his time in office. 5 He was convicted in absentia of treason and is currently living in exile in Russia. wiki The methods used included complex offshore company structures and opaque procurement deals, often facilitated by international financial institutions and legal firms.

Nursultan Nazarbayev

Nursultan Nazarbayev, the former president of Kazakhstan, and his family are alleged to have amassed a multi-billion dollar fortune through corruption and the misappropriation of state assets. 6 Investigations by organizations like the Organized Crime and Corruption Reporting Project (OCCRP) have detailed intricate networks of shell companies and offshore accounts used to channel these illicit funds, often involving luxury real estate in Western countries, including London. 7 (References: OCCRP, The Guardian)

Vladimir Putin

Vladimir Putin and his inner circle have been accused of using state-owned enterprises, like the energy giant Gazprom, to accumulate vast personal wealth and consolidate power. 8 While direct evidence linking Putin to specific accounts is scarce (a hallmark of sophisticated laundering), investigations point to a network of oligarchs and confidants who hold assets on his behalf, often utilizing opaque offshore structures. 9 The company has faced accusations of corruption, cronyism, and being used as a tool for political influence, with Putin’s associates allegedly benefiting from lucrative contracts and kickbacks.

The result of this theft of public resources is that the people of these countries are systematically robbed of their present and future. They are denied access to basic services like healthcare, education, and infrastructure, while their leaders and their enablers live in luxury and opulence. The impact of IFFs on developing countries is particularly severe, exacerbating inequality, undermining democracy, and hindering economic development. 4 It’s not just stealing money; it’s stealing a nation’s potential, converting public hospitals into private mansions, and transforming schools meant for children into instruments of a kleptocrat’s propaganda. This grand larceny starves nations of the very resources needed for progress and stability. The scale of this theft, often running into tens or even hundreds of billions for a single regime, dwarfs the losses from burglaries or street-level fraud in those same nations, affecting the life chances of entire populations.

For each of these Kleptocrats, there is an industry ready to help them move their money, hide their assets, and evade detection.

Illicit Resource Trade

Profiting from the exploitation of natural resources, often in conflict zones or environmentally sensitive areas, is a common tactic used by warlords, corrupt officials, and unscrupulous corporations.

Illegal logging: Khmer Rouge

The Khmer Rouge regime, responsible for the Cambodian genocide, extensively used illegal logging to fund its war efforts. Investigations by Global Witness and others revealed the complicity of corrupt officials and foreign entities in this illicit timber trade, which not only financed atrocities but also caused significant environmental devastation. 10 Global Witness

Blood diamonds

A major source of funding for the Revolutionary United Front (RUF) in Sierra Leone – notorious for its brutality, including the use of child soldiers and mass amputations – was the sale of diamonds. The RUF used the proceeds from these “blood diamonds” to finance its campaign, leading to the deaths of thousands of civilians and the displacement of millions. 11 Companies like De Beers faced accusations of complicity in the trade of conflict diamonds, highlighting how legitimate businesses can become entangled in illicit supply chains. 12 Global Witness

Nigeria’s OPL245 and Shell

Shell, along with Eni, was involved in a controversial deal for Nigeria’s OPL 245 oil block. It’s alleged that a significant portion of the $1.3 billion paid for the license went to a company controlled by a former Nigerian oil minister, Dan Etete, who had awarded himself the block. 13 Global Witness estimates that the deal could deprive the Nigerian people of an estimated $6 billion in future revenue. 14 Global Witness

Similar to Kleptocrats, the illegal exploitation of natural resources (resources owned by the public) for personal gain is a form of grand theft. It deprives the people of these countries of the benefits of their own resources, while enriching a select few. The environmental impact of these activities is also severe, contributing to climate change, deforestation, pollution, and loss of biodiversity. The profits from such operations, often laundered internationally, represent a theft from entire nations that far exceeds the sum of individual property crimes.

The Arms Trade and Conflict Financing

Money laundering is the lifeblood of the illicit arms trade, fueling conflicts and instability around the world. Investigations into arms dealers like Viktor Bout, nicknamed the “Merchant of Death,” revealed complex financial networks used to circumvent international sanctions and supply weapons to war zones across Africa, Asia, and South America. 15 His operations involved shell companies, offshore bank accounts, and a sophisticated transportation network, demonstrating the crucial role of financial secrecy in enabling the arms trade. (References: UN Security Council, The New York Times) The financial scale of this illicit trade, enabling warfare and mass atrocities, is incomparable to the impact of individual violent crimes, yet it is the laundered money that makes it all possible.

And there are many more…

  • Robert Mugabe and Zimbabwe: Reports suggest that illicit financial flows, particularly from the diamond trade, helped sustain Mugabe’s regime despite international sanctions. These funds were allegedly laundered through complex corporate structures and offshore accounts. 16
  • Bashar al-Assad and Syria: The Assad regime has reportedly used a variety of methods to evade sanctions and fund its war efforts, including front companies, oil smuggling, and illicit trade networks, often involving neighboring countries and opaque financial dealings. 17
  • Pavlo Lazarenko (former Ukrainian PM): Lazarenko was convicted in the United States for money laundering, wire fraud, and extortion, having siphoned off hundreds of millions of dollars from Ukraine through shell companies and offshore bank accounts. 18

Fraud: The Liars and Their Loot

We have covered thieves who steal tangible assets or public funds. Now we turn to liars – those who generate illicit wealth through deception and misrepresentation. Fraud, in its myriad forms, produces colossal sums that require laundering to be enjoyed. The financial fallout from large-scale fraud can impact millions of individuals and destabilize economies, a scale of harm rarely seen in ‘ordinary’ criminal acts.

Enron and Arthur Andersen

The Enron scandal was a landmark case of corporate fraud. Executives used sophisticated accounting tricks, primarily through Special Purpose Entities (SPEs), to hide billions in debt and inflate earnings, deceiving investors and employees. 19 Crucially, their auditor, Arthur Andersen, one of the then “Big Five” accounting firms, was found complicit. Arthur Andersen was convicted of obstruction of justice for shredding documents related to its Enron audits, effectively enabling and covering up the fraud. 20 This destroyed Andersen, highlighting the critical role (and catastrophic failure) of gatekeepers. The laundered proceeds were the inflated stock values cashed out by executives and the massive fees paid to enablers.

Wirecard

The German fintech company Wirecard collapsed in 2020 after admitting that €1.9 billion in cash, supposedly held in trust accounts in Asia, likely never existed. 21 This was a massive accounting fraud that went undetected for years, despite numerous red flags. The company’s auditor, EY (Ernst & Young), faced severe criticism and legal action for failing to uncover the fraud over several years of audits, signing off on its accounts. 22 This case demonstrates how even sophisticated financial players can be deceived, or how auditors can fail in their duties, allowing fraudulent proceeds to appear legitimate for extended periods.

Bernie Madoff’s Ponzi Scheme

Bernie Madoff orchestrated the largest Ponzi scheme in history, defrauding thousands of investors out of tens of billions of dollars over several decades. 23 He created the illusion of consistent, high returns by paying early investors with money from new investors. The “profits” were entirely fictitious. While Madoff himself was the central figure, the scheme relied on an appearance of legitimacy, including falsified trading records and account statements, effectively laundering the stolen funds into seemingly legitimate investment returns for a time. The sheer scale and duration highlight failures in regulatory oversight and due diligence by many.

2008 financial crisis?

The 2008 financial crisis was rooted in widespread fraud and misconduct in the mortgage industry, including predatory lending and the misrepresentation of the risk of mortgage-backed securities. 24 The proceeds of this fraud – billions in bonuses and profits – were often “laundered” through the financial system itself, appearing as legitimate earnings until the house of cards collapsed. The complexity of the financial instruments and the lack of transparency made it difficult to trace the illicitly generated profits. The resulting global recession caused hardship for hundreds of millions, a scale of impact far beyond that of typical criminal enterprises.

Human Trafficking: Laundering Lives and Profits

Human trafficking, a modern form of slavery, is an abhorrent crime that generates an estimated $150 billion in illicit profits annually for traffickers. 25 This “business” relies heavily on money laundering to move, hide, and use the proceeds derived from the exploitation of vulnerable individuals for forced labor, sexual exploitation, and organ trafficking. The immense profits, comparable to the GDP of some nations, are a stark reminder of the scale of human suffering that money laundering enables, far exceeding the direct harm of individual assaults or thefts.

Traffickers use a variety of methods to launder their profits:

  • Cash-Intensive Businesses: Funneling money through legitimate businesses that handle large volumes of cash, such as nail salons, restaurants, massage parlors, or transportation services, is common. These businesses provide a plausible front for illicit earnings. 26
  • Third-Party Launderers: Traffickers often use networks of individuals (sometimes victims themselves, or complicit associates) to make small, structured deposits into multiple bank accounts, a technique known as “smurfing,” to avoid detection thresholds.
  • Informal Value Transfer Systems (IVTS): Systems like Hawala, which operate outside the formal banking sector, are used to move money across borders with minimal paper trails. 27
  • Real Estate and Luxury Goods: Investing in property, expensive cars, or jewelry allows traffickers to convert illicit cash into tangible assets that can hold value or be resold.
  • Cryptocurrencies: The perceived anonymity of some cryptocurrencies and mixing services can be exploited to obscure the source and destination of funds.

I list these examples, not because I am not particularly interested in Kleptocrats, the arms trade, illegal logging, or Russian oligarchs… Though we can probably agree they are bad. Rather, I am interested in the industry that facilitates them. How does it work? Who makes money? How do they do it?

Who are the people helping;

  • a dictator profit from genocide?
  • warlords purchase a mega-yacht with money earned through enslaving children?
  • a corporation profit from the illegal destruction of the environment?
  • financial fraudsters hide billions stolen from ordinary investors?
  • human traffickers expand their networks of exploitation?

These are not rhetorical questions. There is an entire global industry of enablers – lawyers, accountants, bankers, real estate agents, and company formation agents – who, wittingly or unwittingly, help move, hide, and legitimize illicit funds. 28

How does it work? The Enablers

Money laundering relies on a network of professional enablers, many of whom are ‘ordinary’ people, who provide the expertise and services needed to disguise the illicit origins of funds. These are not always shadowy figures in back alleys; they are often highly paid professionals in gleaming city towers, individuals who may see their work as a technical service, a way to secure a comfortable life for their families, or a path to career advancement. Yet, the collective impact of their work facilitates devastation on a global scale.

Players:

  • The “Big Four” Accounting Consultancies (EY, PwC, Deloitte, KPMG) and other major financial institutions: While these firms provide essential legitimate services, their expertise in financial structuring, auditing, and tax advisory can be, and has been, exploited or misused.
    • PwC: Implicated in the “LuxLeaks” scandal, which revealed how PwC helped multinational corporations obtain secret tax rulings in Luxembourg to drastically reduce their tax bills. 29 Also faced scrutiny for its role in advising Isabel dos Santos’s companies, as revealed in the “Luanda Leaks.” 30
    • KPMG: Fined heavily for its audit failures in relation to the collapse of Carillion in the UK 31 and the HBOS scandal. 32 In the US, KPMG paid a $456 million fine in 2005 for selling fraudulent tax shelters. 33
    • EY: As mentioned, faced severe criticism and legal challenges for its failure to uncover the massive fraud at Wirecard in Germany over several years of audits. 22
    • Deloitte: Fined in the UK for misconduct in its audit of software company Autonomy. 34 Globally, like other large firms, it has faced various regulatory actions related to audit quality and independence.
  • Mossack Fonseca: This Panamanian law firm, brought to global attention by the Panama Papers leak in 2016, specialized in creating offshore shell companies and financial structures that were used by a global elite to evade taxes, circumvent sanctions, and launder money. 35 The sheer scale of its operations, involving hundreds of thousands of anonymous companies, highlighted the critical role of such specialist firms in the global IFF architecture.
  • Other Law Firms and Company Formation Agents: Beyond Mossack Fonseca, numerous other legal and corporate service providers globally offer similar services, creating the anonymous shell companies and complex legal structures that are the building blocks of most money laundering schemes.
  • Banks and Financial Institutions: Banks are on the frontline of anti-money laundering efforts, yet they are also frequently exploited or found complicit.
    • Credit Suisse: Faced numerous scandals. In 2022, it was criminally convicted in Switzerland in relation to allowing a Bulgarian cocaine trafficking ring to launder millions of euros. 36 It also paid nearly $500 million in fines related to the “tuna bonds” scandal in Mozambique, where loans were arranged for state-owned companies that were fronts for kickbacks. 37
    • HSBC: Paid a $1.9 billion fine in the US in 2012 for allowing itself to be used by drug cartels and states under sanction to launder hundreds of millions of dollars. 38
    • Danske Bank: Implicated in one of the largest money laundering scandals ever, with an estimated €200 billion in suspicious transactions flowing through its Estonian branch. 39 Weaknesses in due diligence, compliance failures, and, in some cases, outright complicity have led to numerous banks being fined billions of dollars for money laundering violations. 40
  • Real Estate Agents: High-value real estate is a common vehicle for laundering money, as it allows for the investment of large sums of illicit cash into a relatively stable asset that can then be sold, appearing as legitimate profit. Real estate agents, particularly in luxury markets, can be gatekeepers, and some have been found to turn a blind eye to suspicious sources of funds. 41
  • Cryptocurrency Exchanges and Services: While cryptocurrencies offer innovative potential, their pseudo-anonymous nature and the global, often unregulated, reach of exchanges and mixing services have made them attractive tools for money launderers. 42 Criminals exploit these features to obscure the source and destination of illicit funds, convert dirty money into crypto, move it across borders with ease, and then cash out into fiat currency. Regulatory efforts are increasing, but the fast-evolving nature of the crypto space presents ongoing challenges for AML/CFT (Anti-Money Laundering/Countering the Financing of Terrorism) regimes. 43

The Enablers: Incentives and Psychology

Why do highly educated, well-compensated professionals get involved in facilitating these devastating crimes? The motivations are complex, blending financial incentives with psychological mechanisms. It’s important to remember the nature of their clientele: these are not petty criminals, but often sophisticated actors involved in large-scale theft, systemic fraud, human exploitation, and acts that destabilize nations or fuel conflict. The sheer scale of the illicit funds involved—whether from a dictator looting a treasury or a global trafficking ring—creates a powerful lure.

Many of these enablers are, in their daily lives, ordinary people. They may be driven by ambitions common to many: providing a better life for their families, achieving professional recognition, or simply excelling in a high-pressure career. However, these understandable human desires can become entangled with a system that normalizes unethical behavior in the pursuit of profit and client satisfaction.

  • Financial Incentives: The most obvious driver is money. Enablers earn substantial fees, commissions, and bonuses for their services. In a competitive environment, the pressure to bring in business and meet revenue targets can be immense. A single wealthy, albeit corrupt, client can be incredibly lucrative. For an individual, this might translate into the ability to afford a mortgage in an expensive city, pay for their children’s education, or secure a comfortable retirement – goals that are, in themselves, perfectly ordinary.
  • Willful Blindness: Many enablers may not ask too many questions, preferring plausible deniability. They might consciously avoid information that would confirm their clients’ illicit activities. “Don’t ask, don’t tell” can become an unspoken motto. This is less about ignorance and more about a deliberate choice not to know, perhaps to protect those ordinary life goals.
  • Normalization of Deviance: In some corporate cultures or professional circles, certain questionable practices can become normalized. If “everyone is doing it” or if bending the rules is seen as standard practice to serve important clients, ethical lines can become blurred over time. What starts as a small compromise can escalate.
  • Diffusion of Responsibility: In large, complex transactions involving multiple parties and departments, individuals may feel less personal responsibility. “I was just doing my part,” or “The compliance department signed off on it,” can be common refrains. The responsibility becomes so diffused that no single person, often just trying to do their job well, feels culpable for the larger picture.
  • Cognitive Dissonance and Rationalization: To reconcile their actions with their self-image as ethical professionals and good family providers, enablers may engage in rationalization. They might tell themselves they are “just providing a technical service,” that “if I don’t do it, someone else will,” or that their clients are “innocent until proven guilty.” They might focus on the technical legality of their actions, ignoring the ethical implications or the ultimate harm caused, perhaps because the direct consequences are not visible in their everyday lives.
  • Client Capture and Fear of Losing Business: Once a firm or individual becomes reliant on fees from certain high-net-worth individuals or corporations (who may be engaged in illicit activities), it becomes harder to disengage or raise red flags for fear of losing that lucrative business, which in turn supports their personal financial stability.
  • Hubris and a Sense of Impunity: Some professionals, particularly at senior levels, may believe they are too smart or too well-connected to get caught, or that the rules don’t fully apply to them or their elite clientele.

Understanding these incentives and psychological factors is crucial. It’s not always a case of mustache-twirling villains, but often a gradual erosion of ethical judgment driven by powerful systemic pressures and human frailties. These are often ordinary people, making choices within systems that incentivize or obscure the devastating downstream consequences of their work – consequences that range from grand corruption to crimes against humanity. The tragedy is that the pursuit of a better life for oneself and one’s family can, in this context, contribute to so much suffering elsewhere.

The Ultimate Purchasing Power: What Illicit Money Buys

What Money Can’t Buy: The Moral Limits of Markets by Michael Sandel explores the idea that some things should not be commodified. However, the vast sums generated and laundered through illicit financial flows often seek to purchase precisely those things that fundamentally undermine fairness, justice, and societal well-being. When enablers successfully disguise the origins of dirty money, they don’t just allow criminals to buy yachts; they empower them to corrupt the very fabric of society:

  • Diplomatic Immunity/Passports: So-called “golden passport” schemes in some countries allow individuals to effectively purchase citizenship or diplomatic status, potentially providing a shield for illicit actors to travel freely and evade justice. 44
  • Citizenship: As mentioned above, citizenship-by-investment programs can be exploited by those seeking to launder money or escape scrutiny in their home countries.
  • Legal Impunity (or at least, Obstruction): Wealthy individuals and corporations can use expensive legal teams to intimidate critics with SLAPP suits (Strategic Lawsuits Against Public Participation), bog down investigations, and exploit legal loopholes to avoid accountability for wrongdoing.
  • Political Influence: Illicit money can be channeled into lobbying, campaign donations (often opaquely), and outright bribery to shape laws, regulations, and government contracts in favour of the corrupt.
  • More Money (through impunity): The ability to successfully launder money allows criminals to reinvest their profits into further illicit activities or to “safely” enjoy their wealth, often at the direct expense of others (e.g., through tax evasion starving public services, or through predatory business practices funded by laundered capital).

This demonstrates that the “service” provided by money launderers and their enablers extends far beyond financial cleansing; it is a key that unlocks the power to erode democratic institutions, evade justice, and perpetuate harm on a grand scale. The sheer scale of this laundered money means it can outbid, outmaneuver, and outlast the forces of justice and accountability in many instances.

The Unseen Foundation of Global Crises

When we talk about climate change exacerbated by illegal logging, wars funded by blood diamonds, societies crippled by kleptocracy, or economies destabilized by massive fraud, we are often looking at the symptoms. Money laundering, and the sophisticated global industry that enables it, is the underlying disease. It is the critical infrastructure that allows these harms to persist and flourish at a scale that dwarfs conventional criminality. Without the ability to legitimize and move illicit funds, the business models of terrorists, dictators, traffickers, and fraudsters would collapse.

Tackling money laundering isn’t just a technical financial issue; it’s a fundamental fight for justice, equality, environmental protection, and global security. It requires not only robust laws and enforcement but also a profound shift in the culture of the financial and professional services industries. We must hold enablers accountable – even those who see themselves as ordinary people just doing a job – and dismantle the systems of secrecy that allow these crimes to thrive in the shadows. Until we do, the manipulation of numbers will continue to inflict very real, very devastating harm on us all, on a scale that eclipses the combined impact of all the world’s ‘ordinary’ crimes.

References

While I had lots of help from LLMs writing this, I have read the following (which have guided my views);

  1. UNODC, Estimating illicit financial flows (This is a general estimate often cited, specific figures vary by year and source) ↩

  2. Global Financial Integrity, Illicit Financial Flows to and from Developing Countries: 2005-2014 (Note: GFI provides regular reports, this is an example. Look for their latest.) ↩

  3. FATF, What is money laundering? ↩

  4. IMF, Illicit Financial Flows ↩ ↩2

  5. The Guardian, Ukraine’s ‘family’ of oligarchs who benefited from Yanukovych’s rule (Note: $37 billion is one estimate, figures vary) ↩

  6. OCCRP, The Kazakh Laundromat Revisited (And various other OCCRP investigations on Nazarbayev family assets) ↩

  7. The Guardian, Kazakhstan’s Nazarbayev family bought $100m of London property via offshore firms ↩

  8. The Guardian, Putin’s palace: a mystery solved? (And numerous other reports on Putin’s wealth held by proxies) ↩

  9. Atlantic Council, Putin’s Kleptocracy: A System of Power and Wealth (Conceptual, based on various investigations) ↩

  10. Global Witness, The Khmer Rouge and the Illegal Timber Trade ↩

  11. Global Witness, A Rough Trade: The Role of Companies and Governments in the Angolan Conflict (While about Angola, the dynamics of blood diamonds are similar to Sierra Leone) ↩

  12. Partnership Africa Canada, The Heart of the Matter: Sierra Leone, Diamonds and Human Security (De Beers’ role and industry changes) ↩

  13. Reuters, Nigeria files $1.1 billion London lawsuit against Shell, Eni over oil deal ↩

  14. Global Witness, OPL 245: Shell and Eni’s Nigeria deal ↩

  15. The New York Times, ‘Merchant of Death’ Viktor Bout Is Freed in Swap for Brittney Griner ↩

  16. Global Witness, Financing a Parallel Government? (Reports on Zimbabwe’s diamond trade and opacity) ↩

  17. Center for Strategic and International Studies (CSIS), Assad’s Money Man: The Networks Helping Syria Evade Sanctions ↩

  18. U.S. Department of Justice, Former Ukrainian Prime Minister Pavlo Lazarenko Sentenced to 97 Months in Prison for Money Laundering, Wire Fraud and Extortion ↩

  19. Financial Crisis Inquiry Commission, The Financial Crisis Inquiry Report (Details on Enron’s accounting) ↩

  20. The New York Times, Andersen Guilty in Effort to Block Inquiry on Enron ↩

  21. Financial Times, Wirecard: the timeline of a financial scandal ↩

  22. Reuters, German audit watchdog files complaint against EY’s Wirecard auditors ↩ ↩2

  23. U.S. Securities and Exchange Commission, SEC Charges Bernard L. Madoff and Bernard L. Madoff Investment Securities LLC with Multi-Billion Dollar Ponzi Scheme ↩

  24. Financial Crisis Inquiry Commission, The Financial Crisis Inquiry Report (Widespread findings on mortgage fraud) ↩

  25. International Labour Organization, Profits and Poverty: The Economics of Forced Labour (2014) ↩

  26. FATF, Money Laundering Risks Arising from Trafficking in Human Beings and Smuggling of Migrants (2018) ↩

  27. UNODC, Financial Flows Linked to Human Trafficking ↩

  28. Transparency International, Gatekeepers: The Professionals Enabling Economic Crime (Conceptual, specific reports vary) ↩

  29. ICIJ, Luxembourg Leaks: Global Companies’ Secrets Exposed ↩

  30. ICIJ, Luanda Leaks ↩

  31. Financial Reporting Council, FRC Sanctions KPMG and former Partner over Carillion Audits ↩

  32. Financial Reporting Council, FRC fines KPMG £14.4m over HBOS audit failings ↩

  33. U.S. Department of Justice, KPMG to Pay $456 Million for Criminal Violations in Relation to Largest-Ever Tax Shelter Fraud Case ↩

  34. Financial Reporting Council, Deloitte fined record £15m over Autonomy audit ↩

  35. ICIJ, The Panama Papers: Exposing the Rogue Offshore Finance Industry ↩

  36. Reuters, Credit Suisse convicted in historic Swiss money laundering case ↩

  37. U.S. Department of Justice, Credit Suisse Resolves Fraudulent Mozambique Loan Case in $547 Million Coordinated Global Resolution ↩

  38. U.S. Department of Justice, HSBC Holdings Plc. and HSBC Bank USA N.A. Admit to Anti-Money Laundering and Sanctions Violations, Forfeit $1.256 Billion in Deferred Prosecution Agreement ↩

  39. The Guardian, Danske Bank money laundering scandal: a timeline ↩

  40. Reuters, Factbox: Major banks hit by money laundering, sanctions busting fines (Examples of bank fines) ↩

  41. Transparency International, Dark Catalogs: How The Real Estate Sector Is A Conduit For Illicit Funds ↩

  42. FATF, Updated Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers (2021) ↩

  43. Europol, Cryptocurrencies: tracing the profits of organised crime ↩

  44. Transparency International, Golden Visas: A Gateway to Europe for Corrupt Capital ↩