The “Follow the Money” approach

March 14, 2024

The Follow the Money approach

Money laundering – Germany's declaration of war

Germany has had enough – enough of being considered a "money laundering haven". Therefore, there is currently a great deal of urgency to combat money laundering and terrorist financing.

The last major victory: The successful bid to host the new European AMLA regulatory authorityThis article explains how Germany plans to use the "Follow the Money" approach to combat money laundering more effectively in the future.

Money laundering reduction as a sustainability goal

In 2023, the German Federal Ministry of Finance presented the idea of ​​establishing a task force to combat money laundering. This task force would be the first at the federal level to operate according to the "Follow the Money" investigative approach. This approach has been established worldwide for some time. It represents, for example, the "basic concept" of the activities of FinCEN, the US agency for combating financial crime and money laundering.[2]

The "follow-the-money" approach is a method for uncovering financial irregularities and illegal activities. This approach is based on the premise that money flows, especially those of criminal origin, leave traces that can be followed.

By analyzing financial flows from their source to their endpoint, investigators can gain valuable insights into the structure and methods of criminal networks.

Who benefits financially?

The reason for choosing this approach is obvious. A driving motive behind (economic) crime is usually to gain a financial advantage.

To exploit the illegally obtained advantage, money laundering is carried out – either by the person(s) themselves, for reasons of opportunity, or as a service (Money Laundering as a Service).[3].[4]

The goal is to obscure the trail of dirty money and be able to use it later in the economic cycle.

Track down the criminals with "Follow the Money".

The issue is gaining increasing importance. Money laundering not only burdens the economy; a significant reduction in money laundering can also be seen as a necessary component of the United Nations' Sustainable Development Goals.

According to sub-goal 16.4, by 2030 the illegal flows of finance and weapons should be significantly reduced, the recovery and return of stolen assets should be strengthened, and all forms of organized crime should be combated.[1]

This is how money laundering works

The money laundering process is usually divided into three steps.

  1. placement
  2. Layering (concealment)
  3. Integration

Step 1: Placement

First, the illegal money is introduced into the legal economic cycle. This is often the riskiest part of the money laundering cycle, as the money comes directly from criminal activities and is therefore easiest to identify.

ExampleA drug dealer has a large amount of cash earned from selling drugs. To invest this money, he could use it in a cash-intensive business, such as a laundromat, a bar, or a casino.

For example, he could pretend that this cash is actual income from operating these businesses and then deposit it into the business account.

Step 2: Layering (concealment)

The second phase is stratification, in which the money is further obscured through a complex series of financial transactions to conceal its illegal origin. Multiple transfers, the buying and selling of investment products, and the crossing of international borders make tracing the funds more difficult.

ExampleAfter the placement, the drug dealer could use the money to buy several high-end watches and cars, then quickly resell them and transfer the money via various international accounts.

He could also set up shell companies that conduct legal business on paper, and use these companies to create invoices and contracts that justify further movements of the money.

Step 3: Integration

The final phase is integration, in which the money is finally reintegrated into the economy as legal assets. The money now appears as legal income and can be used for investments, purchasing real estate, or other legal financial activities without arousing suspicion.

ExampleAfter the money has flowed through various international accounts and transactions, it could be used to buy real estate or to invest in legitimate businesses.

The drug dealer could, for example, buy a property or invest in a legitimate retail business, with the money now appearing as legal investment capital. He could then declare the income from these investments as legitimate income.

The money trail – simply follow it?

These three steps suggest that the processes of a money laundering system are clearly structured, but should only be understood as a model.[5]

In fact, it is becoming increasingly complex to identify a money laundering network and to track down the masterminds, the "big fish".[6], to achieve this. The fact that German investigative authorities have not yet effectively succeeded in doing so was also noted critically in the FATF report 2022.[7]

Follow the Money – A successful concept?

Success stories demonstrate how this approach has led to significant progress in the fight against the financing of crime.

A prominent example is the uncovering of the Panama Papers scandal, in which the analysis of financial documents revealed a worldwide network of tax evasion and money laundering.

In summary, the "follow-the-money" approach is a powerful tool in the fight against financial crime.

Through the systematic analysis of money flows, this approach enables an in-depth investigation of illegal activities, supports the enforcement of laws, and promotes a more transparent and fairer financial world.

Roczniewski