The Financial Intelligence Analysis Unit has given a small insight into the sort of financial crimes it analysed last year and handed to the police for further investigation.

It said in its annual report that the biggest number of cases forwarded to the police involved the setting up of companies in Malta by foreigners and the use of banks as a vehicle to launder the proceeds of criminal funds generated outside Malta.

In some cases, the subjects used the services of Maltese professionals and service providers who did not know they were being used to launder
criminal funds.

There were also cases where subjects used remote gaming companies to disguise the origin of criminal proceeds.

Eight of the cases referred to the police in 2013 followed a specific sequence - one or more non-resident foreigner would set up Maltese
companies, open a bank account with a Maltese credit institution in the name of the companies, receive substantial funds from bank accounts abroad, and transfer these funds to other foreign bank accounts.

In these scenarios, it was noted that the Maltese companies would form part of a larger multi-national company structure intentionally set up to layer the
proceeds of crime generated abroad.

Some cases also featured the use of trustees and fiduciaries

The FIAU analyses in these cases was initiated either upon receipt of intelligence from foreign investigators or reports by the banks or financial institutions.

Suspicions were raised by:

• the pattern of the transactions taking place through the accounts, appearing to be incongruent with the declared intended purpose and activity of the company;
• information through open sources, including media articles and public warnings, on the subjects involved in the companies and/or one of the beneficiaries or remitters, being revealed during the customer due diligence or ongoing monitoring processes;
• transfers of funds to or from companies registered in offshore jurisdictions that appeared to be shell companies;
• discrepancies between the bank account transactions and the contents of supporting documentation presented to the bank;
• the presentation of invoices or other supporting documentation that appeared to be false;
• the forgery of signatures on contracts; and
• the failure to provide explanations and general lack of co-operation by the customers.

In one case, a Maltese bank received claims from foreign banks to return the funds remitted since fraudulent activity had been identified. The analysis of the Maltese companies’ bank accounts revealed that the transactions that were being carried out were in fact inconsistent with the declared intended activities of the companies.

There were also cases where Maltese bank accounts by Maltese nationals to launder profits of illegal gambling through cash deposits in a bank account followed by substantial wire transfers to online gaming companies.

The FIAU also referred cases to the police involving the deposit of large numbers of cheques in bank accounts over a protracted period of time which were incompatible with the type of business or occupation of the person making the deposits.

The FIAU detected cases involving the use of substantial sums of money
in cash for the purchase of luxury items by individuals having a history of proceeds-generating convictions, the use of potentially forged withdrawal vouchers to substantiate cash deposits, multiple deposits on the same day at different banks and unreasonable explanations on the source of the funds upon deposits being made.