Lokanan, M.E. and Nasimi, N.

(2020), "The effectiveness of Anti-Money

Laundering policies and procedures within the Banking Sector in Bahrain",
Journal of Money Laundering Control, Vol. ahead-of-print No. ahead-of-print.
https://doi.org/10.1108/JMLC-10-2019-0080

1. Introduction

Money laundering is a global phenomenon affecting financial institutions

across the globe. Briefly put, money laundering is considered to be illegal acts

whereby criminal networks disguise their illegal activities with a goal of

generating profit (Ryder, 2012). Recently, in line with Basel III guidelines and

requirements (BIS, 2016), more emphasis has been placed on anti-money

laundering (AML) procedures and the roles of the compliance officers - Money

Laundering Reporting Officer (MLRO). In this paper, we use Bahrain as a

prototypical jurisdiction to evaluate the effectiveness of AML policies in the

financial sector. More specifically, the objective of the paper is to identify the

AML policies and procedures applied by the banks operating in Bahrain and to

assess the effectiveness of their compliance policies. The following questions will

guide the inquiry:

- What are the Anti-Money Laundering policies and procedures applied by

Banks in Bahrain?
- How effective are the AML policies and procedures applied in Bahrain?

1.1 The Case Study of Money Laundering Activities in Bahrain

Bahrain was chosen because of the increased attention placed by the

government on concerns that the financial sector is being used as a conduit to

clean criminal proceeds through laundered activities and poses a threat to the

Kingdom’s wellbeing. Additionally, for such a small area, the total number of

financial institutions licensed in Bahrain is 404 and has contributed significantly to

Bahrain’s Gross Domestic Product (GDP). The Ministry of Industry & Commerce

and the Central Bank of Bahrain (CBB) have both implemented policies to combat

money laundering and financial terrorism (CBB, 2012).

Bahrain is located in the Middle East and is situated in the heart of the

Persian Gulf. Its security and financial terrorism sectors have been a strong

foundation for the evolution of the domestic economy under the supervision of the

CBB. Due to the number of licensed financial institutions, Bahrain now has an

emerging financial sector and is considered a financial hub within the Gulf

Cooperation Council (GCC) region. The research objective is to identify the anti-

money laundering policies and procedures applied by the banks operating in

Bahrain, with an aim of establishing an effective assessment of the procedures.

Bahrain’s financial sector contributes to 17% of the Kingdom’s economy (Bahrain

Economic Development Board, 2016). In 2014, twelve men were accused of

illegally transferring over US $100 million overseas (Trade Arabia, 2016). This

case led to concerns over Bahrain’s ability to detect and prevent money laundering

transactions in the financial sector. It is alleged that more robust processes and

policies could have prevented this case from occurring. Anecdotal evidence

coming out of Bahrain noted that this case highlights the shortfalls of AML

policies to safeguard Bahrain’s financial sector from being infiltrated by criminal

networks.

The rest of the paper is structured according to the following format. The

next section provides a literature review on the consequences of money laundering

activities and the procedures that have been put it place to detect and prevent the

integration of the proceeds of crime. This is followed by a discussion of the

2
research design and an analysis of the findings. The final section provides a

conclusion and highlights areas for further research.

2. Literature Review

2.1 Description of Money Laundering

Money laundering is defined as the act of “hiding, moving, and investing

the proceeds of criminal conduct” (Morris-Cotterill, 2009, p.1). The definition of

money laundering varies depending on the country, and the school of thought

used, to define it (Unger, 2007; Hopton, 2009 ). As noted by Ohanyere (2003),

storing money in an offshore bank account becomes money laundering only once

the act is used for tax evasion. The concept of money laundering was originally

formalized in the US (Financial Services Authority, 2016). Traditionally, money

laundering was related to financial resources; however, over time its definition has

expanded to include any form of property or benefit, either tangible or intangible

(Hopton, 2009). The modern, Western version of money laundering has existed for

at least thousands of years, with examples dating back to Chinese merchants

hiding their wealth from rulers who might confiscate it (Brummer, 2015). In the

U.S, funding terrorist activities is seen as a key driver in the definition of money

laundering (Levi, 2002). Money can be laundered through a variety of means,

including transporting valuables purchased using criminally acquired funds,

international funds transfers and transactions made using cash to avoid detection

(Camp, 2008).

The process of money laundering often follows three stages. Placement

refers to the process of placing the proceeds of the crime in the financial system.

It involves “changing the bulk cash derived from criminal actives into a more

3
portable and less suspicious from by depositing those proceeds into the

mainstream financial system” (Buchanan, 2004, p. 5). Layering is the second stage

of the money laundering process and it involves using a complex series of layers to

subvert and anonymize the “audit trail” (Hopton, 2009, p. 2). Finally, there is

integration, which involves reintegrating the proceeds of crime into the financial

system in such a way so as to legitimatize the illicit funds (Reuter and Truman,

2004, pp. 3-4).

2.2 Consequences of Money Laundering

The growth in money laundering activities has led to a number of

consequences. The increased legal complexity to prosecute money laundering

activities along with high transaction costs to ensure legal compliance with the

“plethora of bilateral and multi-lateral rules and agreements” have put added stress

on the regulatory systems to assess and reduce the illicit movement of the proceeds

of crime (Unger, 2007, p.6). The cost of living also increases from money

laundering activities: as criminal networks clean their money in the financial

system through real estate purchase or buying luxury items, this prices out locals

from competing with them for social and public goods (Morris-Cotterill, 2009).

However, it is also possible, considering the example of cash economies used for

tax-evasion, that, in some cases, money laundering lowers costs for everyday

consumers by excluding institutional fees and charges and supporting free market

economics (McDowell and Novis, 2001). Nonetheless, given that tax evasion is a

criminal act on its own, the social consensus to apply money laundering is not

acceptable. Money laundering primarily impacts the economy through its growth

and cost of crime (Unger, 2007). This can lead to declining financial returns and

4
higher costs of investment, as companies charge more to manage their risks

(Morris-Cotterill, 2009). Consumer privacy is another area impacted by money

laundering activities. One area in which this concern manifests itself is in the

banking sector. On the one hand, banks are often perceived to be responsible for

enabling money laundering transactions, while, on the other hand, banks can work

with law enforcement to protect customers from criminal networks (Whisker and

Lokanan, 2019).

2.3 Enhanced Procedures Due to Globalization

Different tax structures or cash / asset economies provide greater

opportunities for money laundering. The opportunities to move proceeds of crime

may also be due to weak and lax law enforcement and financial systems with

inadequate controls (Morris-Cotterill, 2009). Given these concerns, there are

suggestions from countries that are perceived to be havens for laundered

transactions to tighten their regulations in order to comply with international

standards (Whisker and Lokanan, 2019). For example, China has implemented

some structural changes to reduce financial risk and attract foreign investment

(Torrens, 2010). The pressure on financial institutions to prevent money

laundering has resulted in increased levels of consumer data, as well as debates

and changing rules regarding privacy (Romaniuk, Murray and Haber, 2007).

Despite these ongoing debates, it is likely that the increased amount of consumer

information worldwide will contribute to the ability of financial institutions to

monitor consumers and reduce money laundering activities.

The advent of technology and increased globalization has increased the

ability of criminal networks to disguise and move funds through financial systems

5
(Reuter and Truman, 2004). For example, the case of Bank of New York and

Russian Money Laundering is described as being “representative of larger,

interrelated global problems” (Leach, 1999, p. 256) and highlighted that the same

technology that increased the convenience and efficiency of financial transactions

also increased the difficulty of tracing laundered funds (Leach, 1999). Usman-

Kemal (2014) surveyed bank employees to measure the effectiveness of the AML

processes to detect the movement of funds and found that, while valid points are

made regarding training, fair wages and focus on the subject, information is

dependent on employee knowledge, and their willingness to disclose suspicious

transactions. Due to the varied definitions and implications of money laundering,

there is no set of effective measures. Instead, the effectiveness of AML practices

must be measured within the defined contexts, and in relation to specified goals

(Reuter and Truman, 2004).

Money laundering is a growing phenomenon in which funds or assets from

illegal activities are circulated to be untraceable. While money laundering

activities vary in their definitions, and the ability to measure and quantify them

differs, there are certain policies and procedures that can be used to manage and

control such activities, thereby reducing the negative consequences.

3. Methodology

3.1 Data Collection

The purpose of this research is to evaluate the effectiveness of AML

policies and procedures in the banks of Bahrain through investigating the bankers

and MLROs’ experiences in the workplace. A purposive sampling was used and

data were collected from the following categorized institutions for this study:

6
 1. Bank Officials category (B)
2. Money Laundering Reporting Officers category (ML)
3. Chief Risk Officers category (CR)
The aim of piloting interviews with various categories of people in different banks

is to evaluate a broader range of the effectiveness of AML policies and procedures based

on different levels of experiences, job functions and work backgrounds. Data were

collected until a point of saturation was reached. The participants are considered to be

effective added-value opinions to the research objectives. In total, 22 interviews were

conducted randomly. Data were collected from banks that can be categorized as:

Wholesale, Islamic, and Retail Banks. Table 1 below provides more information about the

interviewees and their population.

Table 1: Interviewee information

Interviewee Years of
Industry Position Reference
number experience

Retail Islamic
1 8 years Senior Relationship Manager B1
Bank
2 Wholesale bank 14 years Assistant Manager Private Banking B2

3 Wholesale bank 8 years Assistant Manager Corporate Banking B3

4 Retail bank 2 years Executive Trainee- Risk Management B4

5 Retail 2 years Relationship Officer B5
6 Retail bank 3 years Wealth Manager B6
7 Islamic bank 8 years Senior Relationship Manager B7
8 Retail bank 6 years Assistant Relationship Manager B8
9 Islamic bank 8.5 years Senior Manager B9
10 Islamic bank 8 years Customer Service Supervisor B10
11 Wholesale bank 4 year Compliance Officer ML1
12 Wholesale bank 9 years Compliance Officer ML2
13 Wholesale bank 9 years Compliance Analyst ML3
14 Wholesale bank 10 years Assistant Manager Compliance ML4
15 Wholesale bank 25 years Senior Compliance Officer ML5
16 Retail bank 4 years Compliance Officer ML6
17 Retail bank 15 years Compliance Senior Manager ML7

7
 18 Regulatory 7 years Senior Compliance Analyst ML8
19 Retail bank 15 years Head of Compliance officer ML9
20 Retail bank 18 years Senior Compliance officer ML10
21 Retail bank 13 year Chief Risk Officer CR1
22 Retail bank 20 years Chief Risk officer CR2
Note: All the financial institutions operate in Bahrain

4. Findings and Discussion

4.1 Central Bank of Bahrain guidelines to Anti-Money Laundering

The CBB (2016) is the governing body in charge of regulating the operations of

financial institutions in Bahrain. In its Rulebook, under Volume 6: Capital Markets, CBB

(2016) issued the requirements of Anti-Money Laundering and Combating of Financial

Crime Module in July 2010. The main purpose of the module (CBB Rulebook, 2010) was

to provide guidelines on implementing the 40 Recommendations on Money Laundering

and nine on terrorist financing issued by the Financial Action Task Force (FATF). The

module (CBB, 2016) is also a supplementary to Decree Law No.4 of 2001 and subsequent

Decree Law No.54 of 2006, collectively referred to as ‘The AML Law’, which was issued

to prevent and criminalize money laundering transactions and to prevent the financing of

terrorism by any resident in Bahrain. The CBB module AML/CFT (CBB, 2016) defines

‘Suspicious or Extraordinary Transactions’ as transactions that contradict with the

commercial or personal activities of the subjects being investigated. The transaction is

viewed as suspicious in terms of the size, frequency of occurrence or the nature of the

transaction.

The module (CBB, 2016) also highlights the guidelines that bankers need to

comply with in terms of conducting their due diligence with their clients in regard to

AML compliance. The procedures of business units and staff include verification of

customer identity and source of income, face-to-face business and enhanced due

8
diligence. The objectives of the procedures are to verify the identity of the clients, whether

individuals or corporate, in addition to their sources of income, provide a checklist of the

required information needed to conduct Know Your Client (KYC) verifications and

procedures that should be performed in the event of clients having higher risk profiles. In

such cases, more information should be obtained to assess their activities, sources and

uses of funds.

The CBB module AML/CFT (CBB, 2016) also discusses the roles and

responsibilities of the Money Laundering Reporting Officer (MLRO), wherein their role

should be independent of positions that would result in a conflict-of-interest or impair

their duties, such as being internal auditors or heads of business units. The appointed

MLRO should be in a high position within the bank in order to have ease of access to the

directors and senior executive management. They also should have sufficient resources

that enable them to conduct their roles and responsibilities, including resources, which

should be limited to staff and time. The MLRO should have unrestricted access to all

transactions in order to do their jobs effectively.

The module (CBB, 2016) also highlights the responsibilities carried out by the

MLRO, which include establishing and maintaining AML/CFT policies and procedures,

which should comply with the AML law. The MLRO is also the main contact for the

Financial Intelligence Units, the CBB and other concerned bodies regarding AML/CFT

and ensuring day-to-day compliance with the own internal AML/CFT policies. The

MLROs are also responsible for establishing and maintaining adequate arrangements for

staff awareness, training and producing annual reports on the effectiveness of the

AML/CFT controls. In addition, MLROs should maintain ongoing monitoring

9
constituting of high-risk customer accounts and sustain all necessary customer due

diligence, transactions, and staff training records for the required periods (CBB, 2016).

4.2 Money Laundering Statistics about the Kingdom of Bahrain

Statistics related to suspicious money laundering transactions in Bahrain include

publications from the Financial Intelligence Directory of the Ministry of Interior (2016).

Figure 1 highlights the Suspicious Transaction Reports received from the financial

institutions by month from 2014 to 2016:

Figure 1: Number of STRs from 2014 to 2016

180

160

140

120

100 2014

80 2015
2016
60

40

20

0
Jan Feb Mar Apr May June July Aug Sep Oct Nov Dec

Source: (Ministry of Interior, 2016)

As can be seen in Figure 1, the total number of STRs reported in 2015

increased from 872 in 2014 to 1,044 in 2015, an increase of about 20%. The

growth in the reported STRs may either indicate more rigid AML procedures and

policies to detect STRs, or, alternatively, it may also indicate that Bahrain is a

target for money laundering transaction. The reporting of STRs is crucial in any

country’s AML regime and is supported by the FATF recommendations: “the

10
reporting of suspicious transaction or activity is critical to a country’s ability to

utilize financial information to combat money laundering, terrorist financing and

other financial crimes” (FATF, 2013, p.40).

Moreover, the Ministry of Interior (2016) also highlighted the details of

the type of financial institutions that reported STRs in 2014 and 2015. As can be

seen in Figure 2, the main financial institutions that were targets for money

laundering transactions are related to exchange corporations. The reason for this

may be related to the flexible AML procedures applied in such financial

institutions.

Figure 1: Suspicious Financial Reports 2014 - 2015

800

700

600

500

400
2015
300 2014
200

100

0
Banks Exchange Insurance Ministry of Credit Cards
corporatins corporations Industry & corporations
Commerce

Source: (Ministry of Interior, 2016)

The case study presented above is an example of the limitations of having

weak AML policies and procedures. It is clear that measuring the effectiveness of

AML procedures depends on the number on STRs submitted. This finding

corroborates previous research which states that the most effective measures to

11
combat money laundering are AML regulations specifically related to record

keeping, employee training and STR (Mugarura, 2011).

Table 2 is designed to rank the effectiveness of the AML procedures

applied by taking into consideration the following factors: Money

laundering/terrorist financing risks, international sanctions, corruption risks,

governance related risks, major narcotics list and financial transparency risks;

different weights are given to the above factors. In terms of the rates and studies

conducted, the higher the rate, the lower the effectiveness of the AML procedures

and the less transparent the country would be. As shown in Table 2, compared to

other GCC counties, Bahrain’s rate was the lowest, which indicates that the AML

procedures are the most efficient among the other GCC countries.

Table 2: GCC rating table

Country Rate

Bahrain 64.92

UAE 64.97

Saudi Arabia 68.66

Kuwait 65.41

Qatar 71.11

Oman 75.22

Source: (Know your country, 2016)

4.3 Policies and procedures

The effectiveness of AML policies and procedures is considered to be a

vital issue for banking institutions. Therefore, the research aims to identify how

bankers measure the effectiveness of these procedures in their organizations. There

12
seems to be consideration given to the effectiveness of policies and procedures to

review reports and flag suspicious accounts. This was illustrated by the response

of (B1) who stated that measuring the effectiveness of AML procedures is based

on the observations of the business units on the transactions. Other respondents

noted that they can evaluate the effectiveness of AML policies through the number

of transactions flagged, highlighting that the higher the number of transactions

flagged, irrespective of the quality of responses, the more effective the procedures

are deemed to be. That said, others noted that measuring the effectiveness of the

procedures is so diverse in nature and has proven to be both conceptual and

practically difficult (ML5). These findings confirm Reuter and Truman’s (2004)

work that there is no set measure of effectiveness to detect suspicious transaction;

rather, suspicious transactions should be measured within a defined context

because each act of money laundering attempt is looked at on individual basis.

4.4 The AML procedures applied by the Banks in Bahrain

Figure 3 below shows the procedure applied to many laundering

transactions. While this is a small number of observations, they do give an

indication of the procedures applied to combat money laundering. It is evident that

participants are aware they need to report the transaction to the MLRO after the

initial investigation. As noted by one of the respondents, “Assuming we have a

clear definition of a suspicious transaction; usually any organisation must report

any suspicious act to the compliance officer, and the first thing is to suspend the

transaction and report it to NCA (National Crime Agency)” (ML5). Additionally,

once there is a reasonable ground for suspecting a transaction, the compliance

officers must take immediate action and report the transaction to regulatory

13
authorities and, in some extreme cases, suspend the transaction (CR2). These

findings are analogous with the CBB’s (2016) guidelines with regard to the roles

and responsibilities of the MLROs.

Figure 3: Procedures applied by Banks

9% Report the transaction to the MLRO

9%

Review the sources of information to

the Regulatory bodies
14%
Conduct more enhanced Due diligence

68%

Discuss the transaction with the

Business Unit

Sample (n=22)

4.5 Money laundering investigation in Bahrain

Under CBB Rulebook AML/CFT (CBB, 2016), all investigations are

required to be undertaken by the MLRO or any other relevant delegated official,

and all documents relating to the case need to be stored and maintained for a

minimum of five years, starting from the transaction date. With regards to the

investigation and prosecution of money laundering cases in Bahrain, participants

were asked to highlight what triggers an investigation of a transaction. It is

emphasized that there are automated procedures used to flag accounts

systematically based on the rules related to the different level of transactions. One

respondent emphasized the rules applied by his organization and noted that, if a

customer deposited more than BD 6,000 in his/her personal accounts, he needs to

14
report the source of funds in the deposit slip (B1). In terms of corporate client, any

amount that is not within the 25% level of variance of the expected behavior is

usually flagged to assess whether the transaction is legitimate and the source/

purpose of the transaction is disclosed (CBB, 2012).

Others chose to be conservative in their reporting of suspicious transaction.

Participant ML 9 noted that it is better to be on the safe side with the regulators

and investigate all suspicious cases that are flagged in the initial screening. While

costly, this approach shields compliance officers from missing any suspicious

transaction. Others noted that not all suspicious transactions are proceeds of crime;

but they must report all (CR2). That said, indicators do assist to establish

suspicion that a transaction may be related to the attempted instruction from a

terrorist activity financing offence resembling those relating to money laundering.

As mentioned by one compliance officer, there is usually “no evidence as such

that we could find in other criminal acts except that some transactions involving a

large sum of money through devious channels” (ML10).

4.6 Effective enforcement of AML/CFT by the Central Bank of Bahrain

Being a part of FATF, Bahrain is committed to the implementation of all

international financial standards within the GCC region. The CBB is keen on

extinguishing money laundering and combating all financial acts of terrorism

(CFT), thus meeting all the international standards and setting benchmarks for the

GCC nations. The CBB is also keen on preserving Bahrain’s reputation as a well-

regulated financial center, where they employ a Compliance Directorate tasked

with leading the AML and CFT teams. The Compliance Directorate also acts upon

any complaint received regarding any financial crimes by the CBB licensees on

15
any financial crimes (FATF, 2016). Most of the participants agreed that the

Central Bank of Bahrain has the following roles in enforcing the AML procedures:

Financial institutions must comply with their statutory obligations

The Central Bank conducts on-site inspections

To effectively monitor the compliance activities

To provide guidelines on best practices to be applied by banks

As can be seen in Figure 4, integration was seen as the most critical state of

the money laundering process. The most common reason cited for this outcome is

that integration is the most difficult stage to trace criminal financing. Once the

transaction reaches the integration stage, it is hard to separate the clean money

from the dirty money (B1). In the integration stage, the individual will have

already combined the income generated from legitimate money with revenues

generated from illegal transactions (ML8). Integration is the stage where

“illegitimate transaction becomes legitimate” (B3). These findings corroborate

earlier works by Reuter and Truman (2004) and Hopton (2009) that integration is

the most important stage in the money laundering process because it is the stage

where the criminal proceeds are legitimized into clean money.

Others noted that placement is also a critical stage in the laundering

process. According to one compliance officer, “illegal funds are initially placed

into the financial system by separating its identity from the original illegal source”

(ML9). For others, placement is a critical stage because it is the easiest to detect

laundered funds (ML6). This is particularly important for retail banks that have to

16
ensure that the funds are coming from legitimate sources (B10). These findings

corroborate Renner’s (2013) work that placement is an important stage in the

cleaning of criminal proceeds because it is the stage where dirty funds are

comingled with clean funds to create an aura of legitimacy.

Figure 4: Criticality of Money Laundering Stages in Bahrain

16
Integration
14

12

10
Participants

8
Placement
6
Layering
4

0
Placement 5
Layering 3
Integration 14
Sample (n=22)

17
4.7 Resources and Training: Ranking Anti-Money Laundering costs of procedures
in Bahrain

Figure 5: AML costs of procedures in Bahrain

7%
KYC
26%
19% Training

Reporting
Requirements
Transaction
11% Monitoring
Technology
37%

Sample (n=22)

Figure 5 shows the costs associated with different processes applied by

banks to curb the threat from money laundering activities. Accordingly, the

responses ranked technology to be the costliest procedure followed by transaction

monitoring, training, reporting requirements and, finally, Know Your Client

procedures. The responses indicated that the most expensive cost associated with

the processes and procedures to prevent money laundering activities is the

investments in transaction monitoring. The same technology that increases the

convenience and efficiency of financial transactions also enhances the difficulty of

tracing laundered funds. Technological costs are ongoing due to the advances in

the technologies and the efficiency and the irregularity of the criminal transactions

through the financial system.

Figure 6 provides an illustration of the type of policies needed to mitigate

the threat of money laundering activities in Bahrain’s financial sector. There is

always room for improvement and development in AML procedures; however, to

18
ensure the continuous enhancement of the organization’s systems and, to keep

abreast with the evolution of criminal means to launder money through the

financial system, AML policies need to be more robust and effectively enforced.

Given the increase in regulatory technology, a key aspect in the fight against

money laundering is how to deal with large and unstructured data (see Lokanan,

2020). The manner in which data are analyzed to provide insights into suspicious

transaction will be one of the key pillars in money laundering detection and

prevention strategies.

Figure 6: AML recommended policies

Know your Reporting Transaction

Training Technology
Client Requirements Monitoring

Customer Regularly Investigation Rule-based

Identification online of predicate Upgrading
products
courses activities

Enhanced Face-to-Face
Due Diligence Regular Intelligent
Screen Saver
Training systems

Risk Rating

Monitor &
Report

5. Conclusion

The research findings indicate that the banks in Bahrain apply international

standards and practices in combating money laundering transactions. More

specifically, the following procedures are implemented as highlighted in the

findings and aptly supported by secondary data obtained from the CBB (2016)

19
module: Due diligence, KYC, record keeping system, suspicious transactions

reporting, and staff training. The findings also indicate that there are clear

procedures in place to address suspicious transactions. Moreover, the roles and

responsibilities of the MLRO are well-identified, while the CBB acts as a regulator

that frequently evaluates banks’ procedures in complying with the international

standards. The findings also highlighted that the Banks in Bahrain invest

significantly in the resources required to implement AML procedures. The two

most expensive resources are the costs associated with transactions monitoring and

technology.

With regard to the effectiveness of the AML procedures, the results

suggest that Bahrain has a coherent AML regime. This is supported by the

secondary data that prove Bahrain is ranked amongst the GCC as having a robust

system to tackle money laundering activities with a rating of 64.92/100. One of the

measures used to evaluate the efficiency of the procedures is the number of STRs

reported. The secondary data obtained from the Ministry of Interior (2016)

indicate that the number of STRs increased in 2015, as compared to 2014, by

almost 90%. These findings indicate that the guidelines and procedures enforced

by the Central Bank of Bahrain are efficient to flag suspicious transactions.

Business transactions and the complications of such transactions are an

ongoing process and new methods of laundering transactions emerge. Further

studies can be applied to the new means of transactions used to launder money.

Further research should focus on the effectiveness of the procedures implemented

to detect suspicious transaction from these new methods and how such

20
transactions are enforced by regulators responsible for safeguarding the financial

markets.

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