NCJ Number
205657
Date Published
2004
Length
359 pages
Annotation
This study examined how money-laundering legislation in the Netherlands has been implemented by financial institutions, as well as how compliance with legislative mandates has impacted investigations of money laundering.
Abstract
Beginning February 1, 1994, financial institutions in the Netherlands are required by law to report "unusual" transactions to the Office for the Disclosure of Unusual Transactions (MOT). This is a report on research that examined which "bottlenecks" have impaired the processing of information on unusual and suspicious transactions, as well as the "bottlenecks" that have occurred in the investigation and prosecution of money laundering by the organizations of the MOT-chain. The research also developed recommendations for improving the effectiveness of the organizations within the MOT-chain and the MOT-chain as a whole. This research found that over the 10 years that the law has been in effect, very few investigations of money laundering have originated from the reports by financial institutions of unusual transactions. The large volume of reports that provide information on money flows and money laundering are not sufficiently analyzed for the purpose of launching investigations. Although there are criteria for determining when a financial transaction is "unusual," it is not clear when a transaction is "suspicious," so priorities have not been set for various types of investigative action. The various agencies in the MOT-chain have no central coordinating agency that supervises the analysis and response to reports of unusual transactions. This study proposes a conceptual model for improving the organizational and functional structure for analyzing and responding to reports of unusual financial transactions. The model provides for the centralized management of information processing and screening, as well as decisionmaking regarding investigations based on the analyses of transaction reports. 42 tables and 21 references