Global Investments
International Limited

There was an interesting article in the local press on March the 9th, 2004, written by PRICEWATERHOUSECOOPERS, regarding amongst other things debit cards tied to offshore bank accounts. Below please see their article "Leading the Way":

Lax controls. Ease of access. Virtual anonymity. Difficulty in monitoring a vast number of daily transactions. It is for these reasons that the use of automated teller machines (ATMs) has gained popularity as one of many steps involved in complex, sophisticated money laundering and terrorist financing schemes. Such illicit activities are an international illness, and Thailand is not immune. With an estimated 10,000 ATMs, Thailand would do well to not only keep up-to-date on the latest trends and patterns, but also to implement anti-money laundering (AML) software and other controls wherever possible.

Offshore cards
These make hiding ATM transactions easy, because they leave a minimal trail of financial breadcrumbs to follow.

Debit cards tied to bank accounts that are covered by strict banking secrecy laws help keep transactions concealed. An anonymous Plus, Cirrus or Maestro debit card can be used globally at ATMs as well as to facilitate purchases.

ATMs are also a popular means of accessing illicit funds hidden away in an offshore credit card account, which could be front-end loaded. While the decline in banking secrecy linked to such cards is happening in many offshore jurisdictions, inaccurate maintenance of account opening records remains problematic. Despite hefty withdrawal charges, criminals prefer using such credit cards exclusively at ATMs. As minimal information is exchanged, the identification of the person performing the transaction is near impossible.

Prepaid bearer debit cards and bearer smart cards can also be used to access funds globally via ATMs, albeit with withdrawal limits. However, given the small amount of funding needed for terrorist financing, this is a relatively safe way to access cash.

Money laundering patterns
In the United States there is a currency transaction reporting threshold of US$10,000 (Baht 394,642), which many launderers try to evade by structuring US and linked foreign transactions just below this limit. The Suspicious Activity Reports (SARs) filed in the US indicate three common patterns of cash transaction structuring:

• First, customers in the US make multiple cash deposits and withdrawals on the same day. These transactions will sometimes take place at a single ATM or at multiple locations.
  
  
• Second, daily withdrawals are made using a combination of transactions, each less than $10,000, but aggregating to more than $10,000. For example, a cheque worth $9,500 is cashed and then $500 is withdrawn from an ATM.
  
  
• Third, more than 30% of SARs involve international activity. Funds are deposited as cash or wired into accounts in the US from other countries. Over a short period, they are subsequently withdrawn from ATMs in different countries - usually those with a high risk for money laundering or drug trafficking. The size and number of withdrawals in short time frames are indicative of potential laundering. This method also allows an individual to gain access to assets ostensibly held by offshore trusts, but actually controlled by the individual.