Money Laundering in Bangladesh

Table of Contents
Chapter 1...........................................................................................................................................4
Introduction.......................................................................................................................................4
1.1 Origin of the Report:..................................................................................................................5
1.2 Purpose of the Study:................................................................................................................6
1.3 Objectives of the Report:...........................................................................................................7
1.4 Methodology:...........................................................................................................................8
1.5 Limitations of the Report:..........................................................................................................9
Chapter Two....................................................................................................................................10
Theoretical Overview of the Banking Sectors in Bangladesh..............................................................10
2.1 Definition of Bank:...................................................................................................................11
2.2 A Brief History of Gradual Evolution Banking System:................................................................12
2.2.1 The Beginning of Banking System:......................................................................................12
2.2.2 Modern Banking System :..................................................................................................12
2.2.3 Brief history of Bank in Sub-Continent:...............................................................................12
2.2.4 A brief history of banking systemin Bangladesh:.................................................................13
2.3 Banking systemin Bangladesh:.................................................................................................14
Chapter Three..................................................................................................................................23
Theoretical Overview of moneylaundering.......................................................................................23
3.1 What is Money Laundering?.....................................................................................................24
3.2 History of Money Laundering:..................................................................................................27
3.3 Reasons behind money laundering:..........................................................................................28
3.3.1 To show legitimacy of funds..................................................................................................28
3.4 Stages of money laundering:....................................................................................................29
3.5 Money laundering techniques and methods: ............................................................................33
3.5.7 Investing in legitimate business.............................................................................................34
3.6 Classification of offences under Money Laundering:..................................................................35
Chapter 4.........................................................................................................................................38
Relationship between money laundering and banking sector............................................................38

4.1 Money Laundering and Financial Sector:...................................................................................38
4.2 Vulnerability of the Financial System to Money Laundering:.................................................41
Chapter 5.........................................................................................................................................44
Money Laundering Situation in Bangladesh......................................................................................44
& Analysis of riskiness of Money Laundering ....................................................................................44
5.1 Money Laundering and Terrorist Financing RiskAssessment......................................................44
5.2 Position of Bangladesh in Bribery & Corruption Index:...............................................................47
5.3 Basel Anti-Money Laundering Index and Bangladesh’s position:.................................................48
5.3.1 The positions of Bangladesh & SouthAsian countries in Basel AML Index – 2015 & 2014:.....50
5.3.2 Top Ten High Risk Countries in Basel AML Index – 2015 & 2014: ..........................................51
5.3.3 Change in Bangladesh’s positon in Basel AML Index from 2012 to 2015:...............................53
5.4 “goAML” Software and its use by Bangladesh Financial Intelligence Unit : ..................................54
5.5 Recent moneylaundering situation & role of ACC: ....................................................................56
5.5.1 Money Laundering Enquiries conducted by ACC:.................................................................56
5.5.2 Money Laundering Investigation conducted byACC:...........................................................57
5.5.3 Recent Money Laundering Eventsinvestigated by ACC:.......................................................57
Chapter 6.........................................................................................................................................59
The impacts of Money Laundering....................................................................................................59
6.1 Impacts of Money Laundering on Economy of the World...........................................................59
6.2 The Impacts of Money laundering on the Developing Countrylike Bangladesh: ..........................68
Chapter 7.........................................................................................................................................73
Preventions of Money Laundering....................................................................................................73
7.1 Anti moneylaundering: ...........................................................................................................73
7.1.1 Reasons for combating moneylaundering: .........................................................................74
7.1.2 Some international framework and guidelines against moneylaundering:............................75
7.1.3 European Union’s Anti Money Laundering Strategy:............................................................75
7.2 Anti moneylaundering (AML) in Bangladesh:............................................................................75
7.2.2 Legal framework and guideline against moneylaundering in Bangladesh:.............................76
7.3 Guidance notes on the prevention of moneylaundering issued by Bangladesh Bank:..................76
7.3.1 Requirements under money laundering prevention act 2002: ..............................................76
7.3.2 Responsibilities of Bangladesh Bank: ..................................................................................77
7.3.3 Anti moneylaundering policy:............................................................................................77

7.3.4 Organizational structure: ...................................................................................................78
7.4 Anti moneylaundering Processes:............................................................................................81
7.4.1 Know your customer policy:...............................................................................................81
7.4.2 Risk management policy: ...................................................................................................82
7.4.3 Transactions monitoring process:.......................................................................................83
7.4.4 Statutory obligations for reporting of suspicious transactions: .............................................84
7.4.5 Self assessment process:....................................................................................................84
7.4.6 System of independent procedures testing:........................................................................85
7.4.7 Training and awareness: ....................................................................................................85
7.5 Penalties for money laundering offences:.................................................................................85
7.5.1 Penalties for offence committed by a person:.....................................................................85
7.5.2 Penalties for offence committed by a company:..................................................................86
7.5.3 Penaltiesforoffencenottoretaininformationornotto reportsuspiciousactivityornotto
provide information on demand:................................................................................................86
7.5.4 Penalties for offence of violating freezing or attachment order:...........................................86
7.5.5 Penalties for offence of divulging, using or publishing information:......................................86
7.5.6 Penalties for offence of obstructing or refusing to assistinvestigation:.................................86
7.5.7 Penalties for offence of providing false information: ...........................................................86
Chapter 8.........................................................................................................................................87
Case Analysis...................................................................................................................................87
8 .1Case Study on Money Laundering through Financial Sector:......................................................87
8.2 Money Laundering: Some Real Cases........................................................................................89
8.2.1 Cases: World Perspectivee..........................................................................................89
8.2.2 Cases: Bangladesh Perspective...........................................................................................90
8.3 Remarkable Case of Money laundering & Embezzlementinvestigated byACC: ...........................92
8.4 Assessment and Commentary on Real Cases of Money Laundering:...........................................95
Recommendation.............................................................................................................................97
Conclusion.......................................................................................................................................98

1.1 Origin of the Report:
This report has been prepared as a study on “Money Laundering in Bangladesh.” as a part of the
fulfillment of course requirement. The report was prepared under the supervision of Mohammad
Imran Hossain Lecturer of Dept. of Finance, University of Dhaka. We are very much thankful to
him for assigning us with such type of practical issue that has enhanced our knowledge and
experience.

1.2 Purposeof the Study:
The purpose of the report is to have clear and complete overview of the money laundering situation
and its effect on the national and international economy. Here we will analyze the ins and outs of
Money Laundering background, process, channels and its economic loss influencing the whole
economic process of a country as well as the international economy. This report also includes an
aerial view of the money laundering prevention act of our country. This study will provide lots of
collections of information to make the topic understandable and all its goals implement clearly to
the readers.

1.3 Objectives of the Report:
The main objective of the study is to present the outlook of the recent money laundering crimes
that are occurring and influencing the whole economic process. Again some other objectives will
be fulfilled through this study which is given below:
1. To explain the nature, definition and scope of money laundering according to the law.
2. To explain and demonstrate the real scenario of current money laundering crime in
Bangladesh.
3. To explain the purpose and principles underlying in the adoption of various guidelines and
legal rules against money laundering.
4. To help the readers understand the consequences of money laundering crime.
5. To gather knowledge on such an important issue that is essential to be known by all the
conscious citizens.

1.4 Methodology:
For smooth and accurate study everyone needs to follow some rules & regulations. The study
concerned information was collected from two sources:
Primary Sources:
Information was collected from primary sources in these ways:
1. By self-observation of some sites related to money laundering.
2. By talking face to face with some experienced people in this field.
3. By scrutinizing the various laws in this field.
Secondary Sources:
Data were collected from secondary sources by the following ways:
1. Different trustworthy and reliable websites worked as our prime secondary sources of data.
2. The recent articles and news related to this field.
Data analysis and interpretation:
Especially data have been analyzed based on different statistical charts.

1.5 Limitations of the Report:
On the way of our study, we have faced some challenges that have been termed as the limitations
of this study. These are followings:
Budgeted time limitation:
It was one of the main constraints that hindered to cover all aspects of the study.
Validity and Reliability:
Validity and reliability of the obtained information depends on the responses from the respondents.
Data Insufficiency:
Especially there was a little lack of information about money laundering situation in Bangladesh
in any of the journals or reports or websites available.
Inappropriateness and Scarcity of Evidence:
Actually, Inappropriateness and Scarcity of evidence lacked our practical representation of
analysis.
In spite of many limitations, we have become successful in preparing the report with sufficient
adornment of flawlessness.

Chapter Two
Theoretical Overview of the Banking
Sectors in Bangladesh

2.1 Definition of Bank:
Bank is an organization, usually a corporation, chartered by a state or federal government, which
does most or all of the following: receives demand deposits and time deposits, honors instruments
drawn on them, and pays interest on them; discounts notes, makes loans, and invests in securities;
collects checks, drafts, and notes; certifies depositor's checks; and issues drafts and cashier's
checks.
The term “Bank” has been defined in different ways by different economist. A few definitions are:
Now we can say that, A bank is a financial intermediate or institution which earns profit by doing
business with the money of othes by means of collecting deposits from the surplus units against
giving deposit/borrowing interest rate and lending funds to the deficit units against taking lending
interest rate which is higher than the deposit interest rate and the difference is profit of the bank
after meeting all the required expenditures and other financial obligations.
According to Walter Leaf,“A bank is a person or corporation which holds itself
out to receive from the public, deposits payable on demand by cheque”
According to prof.Kinley, “A bank is an establishment which makes toindividuals
such advances of money as may be required and safely made, and to which individuals
entrust money when not required by them for use ”

Generally, There are two types of bank
Figure 2.1 Types of Bank
2.2 A Brief History of Gradual Evolution Banking System:
2.2.1 The Beginning of Banking System: The name bank derives from the Italian word banco
“desk/bench”, used during the Renaissance by Jewish Florentine bankers, who used to make their
transactions above a desk covered by a green tablecloth. as 1,800 BC in Babylon. In those days
moneylenders made loans to people. In Greece and Rome banks made loans and accepted deposits.
They also changed money. (In the Bible Jesus famously drove the money changers out of the
temple in Jerusalem). However with the collapse of the Roman Empire trade slumped and banks
temporarily vanished. However banking began to revive again in the 12th and 13th centuries in
the Italian towns of Florence and Genoa. At this period Shansi bank, the first bank of world, was
established.
2.2.2 Modern Banking System : Modern banks began with the Bank Charter Act of 1844. The
Act split the Bank of England (which was still legally a private bank) into two departments - a
banking department and an issuing department. From then on the Bank of England could only
issue notes if they were backed up by gold or government securities. The Bank Charter Act also
forbade new banks to issue bank notes. When banks merged they lost the right to issue bank notes.
So gradually the Bank of England became the only bank in England that could issue notes. At the
end of the 19th century and in the 20th century many banks merged until in the late 20th century
banking in Britain was dominated by the 'big four', Barclays, Lloyds, Midland and National
Westminster. At this period The bank of England, the first organized central bank, was established.
Which is also known as mother of central bank.
2.2.3 Brief history of Bank in Sub-Continent:
Bank
Central
Bank
Commercial
Bank

Year Description
1700 The first modern bank of India, The Hindustan Bank Ltd, was established
by businessmen.
1785 The Bengal Bank and The Central Bank of India were established
1840 The Bank of Bombay was established
1843 The Bank of Madras was established
1920 The first central bank of India, Imperial Bank of India, was established
1935 The first organized central bank of India, The Reserve Bank of India, was
established.
Figure 2.2 Brief history of Bank in Sub-Continent
2.2.4 A brief history of banking systemin Bangladesh:
The banking system at independence (1971) consisted of two branch offices of the former State
Bank of Pakistan and seventeen large commercial banks, two of which were controlled by
Bangladeshi interests and three by foreigners other than West Pakistanis. There were fourteen
smaller commercial banks. Virtually all banking services were concentrated in urban areas. The
newly independent government immediately designated the Dhaka branch of the State Bank of
Pakistan as the central bank and renamed it the Bangladesh Bank. The bank was responsible for
regulating currency, controlling credit and monetary policy, and administering exchange control
and the official foreign exchange reserves. In 1972 Under Article 4 of the Nationalising law, six
new banks have been constituted with all the legal characteristics of body corporate. Each of the
new banks has common seal and perpetual succession and subject to the provision of the law each
new bank is empowred to acquire, hold and dispose of the property, to contract, and to sue and be
sued in its own name. The undertakings of existings banks specified below stand transferred to,
and vasted in, the new banks mentioned against them.
SL. No Nationalised Banks Amalgamated and renamed
after nationalisation
1 I. National Bank of Pakistan
II. Bank of Bhawalpur Limited
III. Premier Bank Limited Sonali Bank Limited
2 I. United Bank Limited
II. Union Bank Limited
Janata Bank Limited

3 I. Habib Bank Limited
II. Commerce Bank Limited
Agrani Bank Limited
4 I. Muslim Commercial Bank Limited
II. Standard Bank Limited
III. Australasia Bank Limited
Rupali Bank Limited
5 I. Eastern Mercantile Bank Limited Pubali Bank Limited
6 I. Eastern Banking Corporation Limited Uttara Bank Limited
Figure 2.3 Nationalised Banks of Bangladesh
2.3 Banking system in Bangladesh:
Bangladesh has a mixed banking system comprising nationalised, private and foreign commercial
banks, specialsed banks & financial institutions and co-operative banks.The overview of the
banking system of Bangladesh is given below:
2.3.1 Bangladesh Bank: Bangladesh Bank is the central bank of the country and is in charge of
monetary policies of the Government and controls all commercial banks. Its prime jobs include
issuing of currency, maintaining foreign exchange reserve and providing transaction facilities of
all public monetary matters. BB is also Bangladesh Bank (BB) has been working as the central
bank since the country’s independence. Its prime jobs include issuing of currency, maintaining
foreign exchange reserve and providing transaction facilities of all public monetary matters. BB
is also responsible for planning the government’s monetary policy and implementing it
thereby.The BB has a governing body comprising of nine members with the Governor as its chief.
Apart from the head office in Dhaka, it has ten more branches, of which two in Dhaka and one
each in Chittagong, Rajshahi, Khulna, Bogra, Sylhet, Rangpur and Barisal, Mymenshing.
Functions of Bangladesh Bank:
Bangladesh Bank performs all the core functions of a typical monetary and financial sector
regulator, and a number of other non core functions. The major functional areas include :
 Formulation and implementation of monetary and credit policies.
 Regulation and supervision of banks and non-bank financial institutions, promotion and
development of domestic financial markets.

 Management of the country's international reserves.
 Issuance of currency notes.
 Regulation and supervision of the payment system.
 Acting as banker to the government .
 Money Laundering Prevention.
 Collection and furnishing of credit information.
 Implementation of the Foreign exchange regulation Act.
 Managing a Deposit Insurance Scheme .
2.3.2 Commercial Bank: There are three types of commercial banks in banking system of
bangladesh. These commercial banks are: Nationalised commercial banks, Private commercial
banks, Foreign commercial banks.
At present Bangladesh has 56 scheduled banks in Bangladesh who operate under full control and
supervision of Bangladesh Bank which is empowered to do so through Bangladesh Bank Order,
1972 and Bank Company Act, 1991. Scheduled Banks are classified into following types:
 Nationalised Commercial Banks: there are 6 nationalised commercial banks which
are fully or majorly owned by the Government of Bangladesh.
 Private Commercial Banks : There are 39 private commercial banks which are majorly
owned by the private entities. Private commercial banks can be categorized into two
groups:
 Traditional Banks
 Islamic Banks
Figure 2.4 :Types of commercial
banks in banking systemin
bangladesh
Foreign
Commercial
Banks
Nationalised
Commercial
Banks
Private
Commercial
Banks

 Foreign Commercial Banks: 9 foreing commercial banks are operating in Bangladesh as
the branches of the banks which are incorporated in abroad.
2.3.1 specialized banks & Financial Instiyutions: 7 specialized banks & Financial
Instiyutions are now operating which were established for specific objectives like
agricultural or industrial development. These banks are also fully or majorly owned by
the Government of Bangladesh.
2.3.2 Co-operative Banks & Other Co-operative Societies : There are three types of co-
operative banks & other co-operative socities. These are:
• Bangladesh Samabaya Bank Limited
• Co-operative Bank Limited
• Co-operative Societies

Figure 2.5 Banking system in Bangladesh
Bangladesh Bank (Central
bank of the bangladesh)
Commercial
Banks
Nationalised
Banks
Private Banks
Traditional
Banks
Islamic Banks
Foreign Banks
SpecialsedBanks &
FinancialInstitutions
Bangladesh
Developed Bank
(BDBL)
Bangladesh Krishi
Bank (BKB)
RajshahiKrishi
Unnayan Bank
(RAKUB)
GrameenBank (a
micro finance
institution)
Ansar-VDP Unnayan
Bank
Karmasangsthan
Bank
Investment
Corporationof
Bangladesh (ICB)
Co-operativeBanks
& Other Co-
operative Societies
Bangladesh
Samabaya
Bank Limited
Central Co-
operative Bank
Limited
Primary Co-
operative
Societies

2.4 Contribution of bank to economic development of Bangladesh
Figure 2.6 Contribution of bank to economic development of Bangladesh
Contribution
of bank to
economic
development
of Bangladesh
1. Capital Accumulation
2. Mobilization of savings
3.Provision of Finance&
Credit
4. Attaining Self Sufficiency
5. Implementation of
Modern Technology
6. Development of agri-
cultureSector
7. Development of Industrial
Sector
8. Regional Development
9. Expansion of Market
10. Essential for Foreign
Trade
11. Remove Budget deficit
12. Optimum Utilization of
Resources
13. Creators and Distributors
of Money
14. Monetisation ofEconomy
15. Fulfilmentof Socio-
economic Objectives

Commercial banks play an important role in the process of economic development, which is
clear from the following points:
1. Capital Accumulation or Formation: Capital formation refers to the increase in the
existing stock of capital goods in an economy. Banks remove the capital deficiency by
encouraging saving and investment. The banks can promote capital formation in the
country by moving the resources to the productive uses.
2. Mobilization of Savings: There operates vicious circle of poverty in developing countries
like Bangladesh. So, savings remain at the lowest level. Savings of people are very low
due to international demonstration effect in Bangladesh. Banks are playing important role
in the mobilization of saving by introducing a variety of saving schemes. Banks induce the
people to earn interest through saving and it provides various facilities in a country to create
a will and power to save.
3. Provision of Finance and Credit: Banks are a very important source of finance and credit
for industry and trade. Credit is a pillar of development. Credit lubricates all commerce
and trade. Banks become the nerve centere of all commerce and trade. Banks are
instruments for developing internal as well as external trade.
4. Attaining Self Sufficiency: A major problem faced by the developing countries is burden
of foreign debts and dependence on other countries. Banks provide incentive for the
entrepreneurs to take risks and to use idle resources for more and better production. So,
banks are helpful in attaining self-sufficiency. Banks provide loan to develop the various
economic sectors. It results in reduction in imports and increase in exports. Accordingly,
banks are very important to achieve the self-sufficiency.
5. Implementation of Modern Technology: Economic development without use of
advanced and the most up-to-date technology is impossible. Almost in all the economic
sectors backward techniques of productions are used due to poverty in third world countries
like Bangladesh. Banks provide more funds to people to make it possible to use the modern
techniques of production. Due to implementation of modern technology, there is increase
in production level, decrease in cost and save in time.

6. Development of Agriculture Sector: All the regions and all the sectors of the economy
are not equally efficient and developed in an economy. There is big need to develop the
backward regions and sectors for the economic development. Rural areas and agricultural
sector is still backward in Bangladesh. Banks are playing an important role in the
development of rural and agriculture sector. Two special bank BKBL & RAKUB have a
major role in development of rural and agriculture sector.
7. Development of Industrial Sector: Industrial sector is the backbone of their economies
in rich nations. It is still backward in Bangladesh and other poor countries. Commercial
banks provide different types of loans for the development of industrial sector. A special
industrial development commercial banks i. e., BDBL etc. is provided its remarkable
services for the development of industrial sector. Industrial development leads to
agricultural development and it results in economic development.
8. Regional Development: Banks can also play an important role in achieving balanced
development in different regions of the country. They transfer surplus capital from the
developed regions to the less developed regions, where it is scarce and most needed. This
reallocation of funds between regions will promote economic development in undeveloped
areas of the country.
9. Expansion of Market: Banks help in the expansion of market. They help in the formation
of sound economic infrastructure in order to raise living standards and to expand trade and
commerce of an economy. Banks cause development of industrial as well as agriculture
sector. Accordingly, there is expansion of market that results in economic development.
10. Essential for Foreign Trade: Foreign trade is one of the most important needs of all the
countries of the world. Today international trade, without involving banks, is so difficult.

International trade is necessary for the economic development. Commercials banks are
helpful in increasing international trade through following ways:
a. Provision of credit facilities
b. Low rate of interest for the exporters
c. Opening of letter of credit (L/C)
d. Arrangement of foreign exchange
e. Opening of foreign currency accounts
11. Remove Budget Deficits: The banks are very helpful for the government. Now a day, the
government has to face the budget deficits because of increased expenditures and falling
revenues. In this situation, government has to depend upon deficit financing to meet the
budget deficits. To cover the gap between the expenditures and revenues, government
borrows from the banks. As a result, the development process can be started through
borrowed money from banks.
12. Optimum Utilization of Resources: Banks help in the just and optimum allocation of
resources. Some mega projects cannot be started due to the lack of capital. Banks provide
loans and remove the problem of deficiency of capital. Due to use of resources in an
economy, there is increase in production, income and employment etc. Increase in these
things leads to economic development.
13. Creators and Distributors of Money: Creation of money and distribution of money are
the two main objectives of commercial bank. Commercial banks move the finances toward
productive uses. There are a lot of problems in the way of economic development like
inflation, deflation, low investment and saving etc. All these problems are possible to
remove through creation and distribution of money by commercial banks. So, fluctuation
in the supply of money can attain the economic development.
14. Monetisation of Economy: An underdeveloped economy is characterised by the existence
of a large non-monetised sector. The existence of this non-monetised sector is a hindrance
in the economic development of the country. The banks, by opening branches in rural and
backward areas can promote the process of monetisation in the economy.

15. Fulfillment of Socio-economic Objectives: In recent years, banks, particularly in
developing countries, have been called upon to help achieve certain socio-economic
objectives laid down by the state.
We conclude from above discussion that finance is life-blood of production and the banks are
the departmental stores of finance. Banks enjoy a very typical and dominated position in the
present day economic world. We conclude that economic development, without banking
system, is impossible.

Chapter Three
Theoretical Overview of money laundering

3.1 What is Money Laundering?
Money laundering is the process of transforming the proceeds of crime into ostensibly legitimate
money or other assets. On recent days money laundering has become a sweltering issue in financial
arena nationally and internationally. It is a very sophisticated and dynamic crime in recent times.
3.1.1 Definition of Money laundering according to law:
According to Money Laundering prevention Act-2009, Money Laundering means-
(i) Transfer, conversion, remitting abroad or remitting or bringing from abroad to Bangladesh
proceeds or property acquired through commencement of a particular offence for the purpose of
disguising the illicit origin of the proceed or property or transferring abroad of proceeds or property
acquired through legal or illegal means;
(ii) Conduct or attempt to conduct a financial transaction in a manner that will not be required to
report under the ACT;
(iii) Do such activities so that the illegitimate source of such proceed or property cab be disguised
or attempt to do such activity or knowingly assist or conspire to perform such activities.
3.1.2 Property:
Property has been defined in section 2(Na) of the Act as follows:
Property means-
(i) Any kind of assets, whether tangible, movable or immovable; or
(ii) Cash, legal documents or instruments in any form, including electronic or digital,
evidencing title to, or interest in such assets.
3.1.3 Predicate Offence:
Section 2 (Tha) of the Act also defines predicate offence
“Predicate offence” means the offences from which the proceeds derived from committing or
attempt to commit the following offences:
(1) Corruption and bribery
(2) Counterfeiting currency
(3) Counterfeiting documents
(4) Extortion
(5) Fraud

(6) Forgery
(7) Illicit arm trade
(8) Illicit narcotic drugs and psychotropic substance trade
(9) Trade of stolen goods
(10) Kidnapping, illegal restraint, hostage-taking
(11) Murder, grievous bodily injury
(12) Woman and child trafficking
(13) Smuggling and trafficking of local and foreign currency
(14) Theft or robbery or piracy or sea piracy or air piracy
(15) Human trafficking
(16) Dowry
(17) Illegal trafficking of customs related crime
(18) Tax related crime
(19) Piracy of intellectual property
(20) Terrorism and terrorist financing
(21) Environmental crime
(22) Sexual exploitation
(23) Insider trade and market manipulation
(24) Organized crime
(25) Obtaining money by threatening
(26) Any other offence which Bangladesh bank declares as predicate offence with Govt. approval.
3.1.4 International definition of Money Laundering:
The U.S. Customs service, an arm of the Department of Treasury, provides a lengthy
definition of money laundering as “the process whereby proceeds, reasonably believed to have

been derived from criminal activity, are transported, transferred, transformed, converted or
intermingled with legitimate funds for the purpose of concealing or disguising the true nature,
source disposition, movement or ownership of these proceeds. The goal of the money laundering
process is to make funds derived from, or associated with, illicit activity appear legitimate.”
Another definition of money laundering under U.S law is “… the involvement in any one
transection or series of transection that assists a criminal in keeping, concealing or disposing
of proceeds derived from illegal activities.
The European union defines it as “ the conversion or transfer of property, knowing that such
property is derived from serious crime, for the purpose of concealing or disguising the illicit origin
of the property or of assisting any person who is involved in committing such an offence or
offences to evade the legal consequences of his action, the concealment or disguise of the true
nature, source, location, disposition, movement, rights with respect to, or ownership of
property, knowing that such property is derived from serious crime”
The joint Money Laundering Sterling Group (JMLSG) of the U.K defines it as “the process
whereby criminals attempts to hide and disguise the true origin and ownership of the proceeds of
their criminal activities, thereby avoiding prosecutions, conviction and confiscation of their
criminal funds”
In lay terms, money laundering is most often describes as” turning of dirty or black money into
clean or white money”. If undertaken successfully, money laundering allows criminals to
legitimize “dirty” money by mingling it with “clean” money, ultimately providing a legitimate
cover for the source of their income. Generally, the act of conversion and concealment is
considered crucial to the laundering process.

3.2 History of Money Laundering:
The history of money laundering is, primarily, that of hiding money or assets from the state either
from blatant confiscation or from taxation- and, from a combination of both. And, of course from
those seeking to enforce judgment in civil cases or to follow the money that results from other
crime. It is interwoven with the history of trade and of banking.
No one can be really sure when money laundering first began. However, we can be confident that
it has been going on for several thousand years, In “Lords of the Rim” Sterling Seagrave explains
how, in China, merchants some 2000 years before Christ would hide their wealth from rulers who
would simply take it off them and banish them. In addition to hiding it, they would move it and
invest it in business in remote provinces or even outside China.
In this way the offshore industry was born, and –depending on your point of view- so was tax
evasion. And so were the principles of money laundering- to hide, move and invest wealth to which
someone else has a claim.
Over the next four millennia, the principles of money laundering have not changed. But the
mechanisms have. Parallel Banking is one of the most durable techniques, or to be more precise
suites of techniques.
Over a period of thousands of years, people have used money laundering techniques to move
money resulting from crime- but also often to hide and move it out of reach of governments-
including oppressive regimes and despotic leaders. Many minorities in countries down the ages
and around the world have taken steps to preserve wealth from rulers, both unelected and elected,
who have targeted them simply because of their beliefs or colors. It is happening even today.
Whilst it is true that, in the USA, prohibition and a restriction on gambling made large amount of
cash for those prepared to break the embargoes the most important fact about that time was that it
is caused a dramatic increase in financial crime- in this definition, financial crime is a crime that
gives direct access to the proceeds of the offence. Sanctions busting was a financial crime because
for every offence committed, the criminal immediately received cash in his hand. Thus it created
an immediate problem over what to do with that money. Opening a cash business was the obvious

thing to do. Laundries were a suitable business, and so- goes rumor- the term “money laundering”
was invented. This may or may not be true.
Whatever the origins of the term, criminals moved into business where the cash crop was higher –
including drugs. They formed law firms, accountancy practices, bought banks, film studios,
engineering concerns, even governments. When this was originally written, in 2002, one person
was trying to buy control of a central bank.
But money laundering also was developed in order to facilitate trade. It is often said that Nigeria
is the money laundering centre of Africa and that Nigerians around the world are engaged in large
scale crime and laundering. In so far as that true, the reason for it is because the networks that are
now dominated by criminals were set up within the past twenty or so years by international traders
who were unable to operate due to exchange control measures and a system of custom inspection
that resulted in traders based in Nigeria operating their business entirely offshore. Other countries
have had- and in the case of some which have strict currency transaction requirements still have a
similar development of laundering. Money laundering techniques are restricted only by the
imagination of the criminals and there are a lot of criminals trying to find ways to launder.
3.3 Reasons behind money laundering:
Criminals mainly engage in money laundering for three reasons:
(1) To show Legitimacy of Fun
(2) Hide Sources of illicit proceeds
(3) Shield against investigation and capture
3.3.1 To show legitimacy of funds:
Money is lifeblood of any organization that engages in criminal conduct for financial gain because:
It covers operating expenses
Replenishes inventories
Purchase the service of corrupt officials to escape detection
Promotes the interests of illegal enterprise and
Pays for extravagant life style

To spend money in this ways, criminals must make the money they derived illegally appear
legitimate.
3.3.2 Hide sources of illegal proceeds:
Criminals mainly hide the source of their money to ensure that illicit proceeds are not used to
prosecute them.
3.3.3 Shield against investigation and capture:
The proceeds from crime often become the target of investigation and seizure. To shield unfair
gains from suspicion and protect them from seizure, criminal must make them look legitimate.
3.4 Stages of money laundering:
There is no single method of laundering money. In most of the criminal cases, the initial proceeds
usually take the form of cash. For example, bribery, extortion and street level trade of drugs are
almost always made with cash. This cash need to enter into financial system by some means so
that it can be converted into a form which can be more easily transformed, concealed or
transported.
Despite of variety of methods employed, the laundering is not a single act but a process
accomplished in 3 basic stages-
Placement
Layering and
Integration
In the following there is an overview of the whole money laundering process showing the complex
scenario of this process formed by various techniques:

Figure 3.1: Money laundering; a three stage process.
3.4.1 Placement:
The physical disposal of the initial proceeds derived from illegal activity. This means the
movement of cash from its source. . On occasion the source can be easily disguised or
misrepresented. This is followed by placing it into circulation through financial institutions,
casinos, shops, bureau de change and other businesses, both local and abroad. The process of
placement can be carried out through many processes including:
1. Currency Smuggling: This is the physical illegal movement of currency and monetary
instruments out of a country. The various methods of transport do not leave a discernible audit
trail.
2. Bank Complicity: This is when a financial institution, such as banks, is owned or controlled by
unscrupulous individuals suspected of conniving with drug dealers and other organized crime
groups. This makes the process easy for launderers. The complete liberalization of the financial
sector without adequate checks also provides leeway for laundering.
3. Currency Exchanges: In a number of transitional economies the liberalization of foreign
exchange markets provides room for currency movements and as such laundering schemes can
benefit from such policies.
4. Securities Brokers: Brokers can facilitate the process of money laundering through structuring
large deposits of cash in a way that disguises the original source of the funds.
Placement
•Currency
smuggling
•Bank complicity
•Currency
exchanges
•Securities
brokers
•Blending of
funds
•Asset purchase
Layering
•Cash converted
into monetary
instruments
•Material assets
bought with cash
then sold
Integration
•Property dealing
•Front companies
and false loans
•Foreign bank
complicity
•False
import/Export
invoices

5. Blending of Funds: The best place to hide cash is with a lot of other cash. Therefore, financial
institutions may be vehicles for laundering. The alternative is to use the money from illicit
activities to set up front companies. This enables the funds from illicit activities to be obscured in
legal transactions.
6. Asset Purchase: The purchase of assets with cash is a classic money laundering method. The
major purpose is to change the form of the proceeds from conspicuous bulk cash to some equally
valuable but less conspicuous form.
3.4.2 Layering:
Separating illicit proceeds from their source by creating complex layers of financial transactions
designed to disguise the audit trial and provide anonymity. The purpose of this stage is to make it
more difficult to detect and uncover a laundering activity. The known methods are:
1. Cash converted into Monetary Instruments: Once the placement is successful within the
financial system by way of a bank or financial institution, the proceeds can then be converted into
monetary instruments. This involves the use of banker’s drafts and money orders.
2. Material assets bought with cash then sold: Assets that are bought through illicit funds can be
resold locally or abroad and in such a case the assets become more difficult to trace and thus seize
3.4.3 Integration:
This is the movement of previously laundered money into the economy mainly through the
banking system and thus such monies appear to be normal business earnings. This is dissimilar to
layering, for in the integration process detection and identification of laundered funds is provided
through informants. The known methods used are:
1. Property Dealing: The sale of property to integrate laundered money back into the economy is
a common practice amongst criminals. For instance, many criminal groups use shell companies to
buy property; hence proceeds from the sale would be considered legitimate.
2. Front Companies and False Loans : Front companies that are incorporated in countries with
corporate secrecy laws, in which criminals lend themselves their own laundered proceeds in an
apparently legitimate transaction.
3. Foreign Bank Complicity: Money laundering using known foreign banks represents a higher
order of sophistication and presents a very difficult target for law enforcement. The willing
assistance of the foreign banks is frequently protected against law enforcement scrutiny. This is
not only through criminals, but also by banking laws and regulations of other sovereign countries.

4. False Import/Export Invoices: The use of false invoices by import/export companies has proven
to be a very effective way of integrating illicit proceeds back into the economy. This involves the
overvaluation of entry documents to justify the funds later deposited in domestic banks and/or the
value of funds received from exports.
These three steps can be illustrated in to the following figure:
Figure 3.2: Steps of money laundering.
The table below provides some typical example of the stages of money laundering:
Placement stage Layering stage Integration stage
Cash paid into bank
(sometimes with staff
complicity or mixed with
proceeds of legitimate
business)
Sale or switch to other forms
of investments.
Transfer of contract or switch
to other forms of investments
Cash exported Money transferred to assets of
legitimate financial
institutions.
False loan repayments or
forged invoices used as cover
for laundered money.

Cash used to buy high value
goods, property or business
assets.
Telegraphic transfers (often
using fictitious names or
funds as proceeds of
legitimate business)
Complex web of transfers
(both domestic and
international) makes tracing
original source if funds
virtually impossible.
Figure 3.3: Example of stages of money laundering
3.5 Money laundering techniques and methods:
The money laundering techniques are complex and a salient feature of money laundering is the
number of different methods used. Some of the commonly used measures are discussed below and
are related with the three stages of money laundering that is placement, layering and integration.
3.5.1 Structuring/ Smurfing:
Smurfing or structuring is one of the techniques of recycling easier. This is a method of placement
whereby cash is broken into smaller deposits of money, used to defeat suspicion of money
laundering and to avoid anti-money laundering reporting requirements. A sub-component of this
is to use smaller amounts of cash to purchase bearer instruments, such as money orders, and then
ultimately deposit those, again in small amounts.
3.5.2 Cash smuggling:
Cash smuggling is one of the oldest methods used for general smuggling of currency. This involves
physically smuggling cash to another jurisdiction and depositing it in a financial institution, such
as an offshore bank, with greater bank secrecy or less rigorous money laundering enforcement.
The bulk shipments of cash hidden in cargo are driven across the border, though it is illegal to
export a bulk amount of cash. Every country has its limit of carrying cash legally across the border
like United States restricts the currency to $10,000 without filing a report under International
Transportation of Currency or other Monetary Instruments (CMIR). However the criminals have
been known to purchase of shipping business to transfer the cash hidden in the goods.
3.5.3 Offshore accounts (Shell banks):
Offshore accounts are often used by criminals to obscure the audit trail as many different countries
in the world offers strictly law for bank secrecy to attract money in their countries. In respect of
this law, the country can also refuse to assist international authorities in revealing the information
of customer. Many of these countries also attracts clients by selling Shell banks which means a
bank which is incorporated in jurisdiction in which the bank has no physical presence and also
unaffiliated with the regulated financial institution. These kinds of banks, Shell banks are generally
developed in a financial haven country for providing the appearance of legitimacy. A customer
only needs a false name to open an account in these kinds of bank which provides the customer
complete secrecy and protects the customer from investigation and possible prosecution and after

establishing the shell bank the customer may gain advantage of “payable though” or “pass
through” accounts.
3.5.4 Shell companies and trusts:
A practice quite common among criminal organizations around the world is the establishment of
companies which have as their object the trade of antiques. These are fake companies and trusts
that exist for no other reason than to launder money. They take in dirty money as "payment" for
supposed goods or services but actually provide no goods or services; they simply create the
appearance of legitimate transactions through fake invoices and balance sheets. Trusts and shell
companies disguise the true owner of money. Trusts and corporate vehicles, depending on the
jurisdiction, need not disclose their true, beneficial, owner.
3.5.5 Underground banking:
Some countries in Asia have well-established, legal alternative banking systems that allow for
undocumented deposits, withdrawals and transfers. These are trust-based systems, often with
ancient roots, that leave no paper trail and operate outside of government control. The Criminals
considers this as the safest way of laundering money and also one of the most common method
used for the purpose. Basically there are two types of underground banking systems which are
known as Hawala/Hundi and Chitti/Chop banking. The use of underground banking has been
recognized in many countries and the reason behind the success of this technique was that this
banking was based on trust and virtually there is no paper trail involved in that.
3.5.6 Gambling:
Often the activities of money laundering linked to games of chance. In most cases criminal
organizations clean up the money using casinos and casinos, buying chips in large quantities in
order to play, but use only a small part of them or not use them at all. The purpose of these
operations is to convert the chips in money and simultaneously be issued by the gambling house a
document that certifies the win. However, a more effective method consists in capture by organized
control of a gambling house. In this case you just have to do is declare the dirty money as income
from gaming activity
3.5.7 Investing in legitimate business:
Launderers sometimes place dirty money in otherwise legitimate businesses to clean it. They may
use large businesses like brokerage firms or casinos that deal in so much money it's easy for the
dirty stuff to blend in, or they may use small, cash-intensive businesses like bars, car washes, strip
clubs or check-cashing stores. These businesses may be "front companies" that actually do provide
a good or service but whose real purpose is to clean the launderer's money. This method typically
works in one of two ways: The launderer can combine his dirty money with the company's clean
revenues. In this case, the company reports higher revenues from its legitimate business than it's

really earning; or the launderer can simply hide his dirty money in the company's legitimate bank
accounts in the hopes that authorities won't compare the bank balance to the company's financial
statements. Examples are parking buildings, strip clubs, tanning beds, car washes and casinos.
3.5.8 Round- tripping:
Here, money is deposited in a controlled foreign corporation offshore, preferably in a tax haven
where minimal records are kept, and then shipped back as a foreign direct investment, exempt
from taxation. A variant on this is to transfer money to a law firm or similar organization as funds
on account of fees, then to cancel the retainer and, when the money is remitted, represent the sums
received from the lawyers as a legacy under a will or proceeds of litigation.
3.5.9 Bank capture:
In this case, money launderers or criminals buy a controlling interest in a bank, preferably in a
jurisdiction with weak money laundering controls, and then move money through the bank without
scrutiny.
3.5.10 Black salaries:
A company may have unregistered employees without a written contract and pay them cash
salaries. Dirty money might be used to pay them.
3.6 Classification of offences under Money Laundering:
The Offences under the money laundering controls has been classified into five categories that is
drug distribution, white collar crimes, blue collar crimes, corruption and bribery and terrorism.
These categories differ in their dimensions and are more uniformed in relation with the distribution
and seriousness of the harm caused by these specific offenses to the society.
3.6.1 Drug distribution:
Most of the drug dealers deal with the common problem of regularly and frequently managing the
large amount of cash. Initially the current anti-money laundering regime was developed primarily
to put a control on drug trafficking.
3.6.2 White collar crimes:
This category of crime consists of various ranges of activities such as tax evasion. The different
feature of these crimes is the laundering of money which is usually an integrated part of the crime
itself. The case of Enron presents a more composite scheme in which the Shell corporations in the
Cayman Islands served as a laundering tool to vague the trail of fraudulent behavior and also acted
as a questionable tax shelter.

3.6.3 Blue collar crimes:
The other large scale market other than the drugs for generating large amount of money which in
turn generates the demand for money laundering consists of gambling and smuggling of people.
However the scale of money generated by any individual operation in these areas tends to be much
smaller than the drugs trafficking.
3.6.4 Corruption and Bribery:
Corruption and Bribery can be considered as a white collar crime but they are different in respect
of the place of occurring, in terms of who benefits and the nature of the harm done by them which
may lead to affect the quality of government services and also the credibility of the government.
3.6.5 Terrorism:
The different characteristic of terrorism is that it involves money from both, legitimately and the
money generated from the criminal activities and then it converts the money into criminal use. The
amount of money involved in this activities are not involved in millions but hundreds of thousands
of dollar therefore the harm in enormous and unique.
Chart of FinancialAbuses:
Poorregulatory and supervisory framework
(e.g., excessive banksecrecy,lackof disclosure
rules and effective fiduciary rules for investors and their
Factors Contributing to Financial Abuses

Chapter 4
Relationship between money laundering and
banking sector
4.1 Money Laundering and Financial Sector:

As we have seen that transaction to avoid reporting requirements has been defined as money
laundering. Let us now see who are to reports, that is, which are reporting agencies:
(a) Bank/Financial Institutions;
(b) Insurance Companies;
(c) Money changers;
(d) Companies remitting money;
(e) Any such organization declared by Bangladesh Bank.
Throughout the world, banks have become a major target of ML operations and financial crimes
because they provide a variety of financial services and instruments that can be used to conceal
the actual source of money. Money Launderers attempt to conceal their real identity to the bankers
with their polished, articulate and disarming behaviour, convert their dirty money into white
money.
Llaunderers generally use the financial system in two stages to disguise the origin of the funds.
First, they place their ill-gotten money into financial system to legitimize the funds and introduce
these funds in the financial system and second, after injecting the dirty money into the financial
system, through a series of transactions, they distance the funds from illegal source. Therefore, the
financial institutions through whom the dirty money is laundered become unwitting victims of this
crime.
Money Laundering may hamper the reputation of the financial institution and may increase the
operational risk of the banking firm when banking firm itself involved with the launderer or in
criminal activities. Thus, without even involvement in any criminal offence, money laundering
may be a cause of failure of banking (financial) sector of an economy. People may lose their
confidence on the banking system. Such confidence failure towards the formal sector may increase
the activities of informal financial firm. The growth of activities of the informal sector might again
increase the possibility of money laundering such as credit union, hawala remittance systems etc.
Money laundering shifts the economic power to the criminals. In such a situation, criminals may
use their economic power to undertake the operation of the financial firm of the country and may
use the fund of the depositors to do more criminal activities. Therefore, the scarce financial
resources of the developing country may be used for the criminal activates of few launderers,
instead of productive investment of the economy. Such criminal activities can lead to more
terrorism against humanity. Even, money laundering and terrorist financing can threaten financial
stability and economic prosperity, adding to the gravity of the underlying crimes. In the extreme
scenario, money-laundering activity undermines capital formation within developing economies.

The increased use of online banking reduces the cost and time of the customers and increases the
profitability of banking firm with faster banking service to the customers. The money launderers
use the online transaction as a method of money laundering and therefore, reduce the confidence
of the customers and the profitability of the banking firm. To combat cyber crimes regulations and
technologies related to online banking needs to keep updated by the regulators and the FI’s. As a
result the, both the users and the service providers might face additional cost for online
transactions.
The following things in our country have made a relationship between financial institutions and
money laundering. In fact, these are the following reasons for which we can blame banking sector
for money laundering.
a) Modern financial systems:
Modern financial systems, in addition to facilitating legitimate commerce, also allow criminals to
order the transfer of millions of dollars instantly using personal computers and satellite dishes.
Because Money Laundering relies to some extent on existing financial systems and operations, the
criminal’s choice of Money Laundering vehicles is limited only by his or her creativity. Money is
laundered through currency exchange houses, stock brokerage houses, gold dealers, casinos,
automobile dealerships, insurance companies, and trading companies. Private banking facilities,
offshore banking, shell corporations, free trade zones, wire systems, and trade financing all can
mask illegal activities.
b) Cash Cultures:
Bangladesh being a third world country comparatively takes a longer time to accept technological
advancement. This is especially true in the case of financial sector.
Although there has been much development in the financial sector (Cheques, ATM cards, Credit
cards, online banking) but still the majority of our population believe in the cash transaction when
it comes to business dealings. People in Bangladesh take banking transactions as a hassle. This is
due to the poor customer service, long queue, and lack of banking knowledge. In addition to that
there is the fear of the given cheque being bounced back due to insufficient balance. Now if the
beneficiary maintains account in a different clearing region, it might take as long as one to two
weeks for the fund to be received at the designated account after going through different Clearing
houses.
Hence to avoid this lengthy and complicated process (as perceived by the majority) Bangladeshis
prefer business transactions to be in cash and discard paper transactions as much as possible. This
so-called cash culture is acting as a great advantage to the money launderers. As most of the
business people are placing cash money over the counter from their business earnings, it is very
convenient for the money launderers to mingle their dirty earnings with their legitimate funds to
be put across the bank counter.

c) Private Banking Relationship:
The term private banking generally means the personal or discreet offering of a wide variety of
financial services and products to the affluent market. In Bangladesh few of the multinational
banks like HSBC, Standard Chartered Bank these customers are referred to as Priority Customers.
These operations typically offer individual, commercial business, law firms, investment advisors,
trusts, and also personal investment companies may open private banking accounts. Due diligence
for private banking customers usually includes a more extensive process than retail customers. It
is critical to understand the client’s source of wealth, needs, and expected transactions.
d) Electronic Banking:
This is also known as E-banking. The term possesses a wide area of operation. This could include
delivery of information, products, and services by electronic means (such as telephone lines,
personal computer, automated teller machine, and automated clearinghouse). Although in
Bangladesh we still have a long way to go in this field, but some of the multinational banks and
private local banks have already started e-banking and has a good prospect of expanding in this
segment of the market and the product offers will continue to grow at a rapid pace. Few of the e-
banking services include credit cards, loans, deposits, wire transfer, and bill paying services. This
medium of banking is vulnerable to money laundering and terrorist financing because of its user
anonymity, rapid transaction speed, and its wide geographic availability.
4.2Vulnerability of the Financial System to Money Laundering:
1) Money laundering is often thought to be associated solely with banks and moneychangers.
All financial institutions, both banks and non-banks, are susceptible to money laundering
activities. Whilst the traditional banking processes of deposit taking, money transfer
systems and lending do offer a vital laundering mechanism, particularly in the initial
conversion from cash, it should be recognised that products and services offered by other
types of financial and non-financial sector businesses are also attractive to the launderer.
The sophisticated launderer often involves many other unwitting accomplices such as
currency exchange houses, stock brokerage houses, gold dealers, real estate dealers,
insurance companies, trading companies and others selling high value commodities and
luxury goods.
2) Certain points of vulnerability have been identified in the laundering process, which the
money launderer finds difficult to avoid, and where his activities are therefore more
susceptible to being recognized. These are:
 Entry of cash into the financial system;
 Cross-border flows of cash; and
 Transfers within and from the financial system.

3) Financial institutions should consider the money laundering risks posed by the products
and services they offer, particularly where there is no face-to-face contact with the
customer, and devise their procedures with due regard to that risk.
4) Although it may not appear obvious that the products might be used for money laundering
purposes, vigilance is necessary throughout the financial system to ensure that weaknesses
cannot be exploited.
5) Banks and other Financial Institutions conducting relevant financial business in liquid
products are clearly most vulnerable to use by money launderers, particularly where they
are of high value. The liquidity of some products may attract money launderers since it
allows them quickly and easily to move their money from one product to another, mixing
lawful and illicit proceeds and integrating them into the legitimate economy.
6) All banks and non-banking financial institutions, as providers of a wide range of money
transmission and lending services, are vulnerable to being used in the layering and
integration stages of money laundering as well as the placement stage.
7) Electronic funds transfer systems increase the vulnerability by enabling the cash deposits
to be switched rapidly between accounts in different names and different jurisdictions.
8) However, in addition, banks and non-banking financial institutions, as providers of a wide
range of services, are vulnerable to being used in the layering and integration stages. Other
loan accounts may be used as part of this process to create complex layers of transactions.
9) Some banks and non-banking financial institutions may additionally be susceptible to the
attention of the more sophisticated criminal organizations and their “professional money
launderers”. Such organizations, possibly under the disguise of front companies and
nominees, may create large scale but false international trading activities in order to move
their illicit monies from one country to another. They may create the illusion of
international trade using false/inflated invoices to generate apparently legitimate
international wire transfers, and may use falsified/bogus letters of credit to confuse the trail
further. Many of the front companies may even approach their bankers for credit to fund
the business activity. Banks and nonbanking financial institutions offering international
trade services should be on their guard for laundering by these means.
10) Investment and merchant banking businesses are less likely than banks and money
changers to be at risk during the initial placement stage.
The following figure describes the money laundering and banking sector relationship:

Fig:4.1 Money Laundering through Banking Sector
From this figure, we can find that banking companies act as a catalyst in money laundering process.

Chapter 5
Money Laundering Situation in Bangladesh
& Analysis of riskiness of Money
Laundering
5.1 Money Laundering and Terrorist Financing Risk Assessment
Bangladesh is a founding member of the Asia Pacific Group on Money Laundering (APGML)
constituted in the form of the Financial Action Task Force (FATF) for the Asia Pacific region to
prevent money laundering and terrorist financing on a global perspective.

As a result, MLPA, 2002 was enacted in Bangladesh in 2002 as the first South Asian country. A
report prepared in compliance with international standards of preventing money laundering and
terrorist financing and on the progress of its implementation and evaluated mutually by member
countries of APGML was presented in the central conference of APGML.
According to recommendations of the mutual evaluation report, National Coordination
Committee (NCC) led by Finance Minister, was formed by the Government of Bangladesh in 2010
to provide instructions and policies on anti-money laundering and counter-terrorist financing
measures.
The ACC was entrusted with the main responsibility of identifying risks for anti-money laundering
and counter-terrorist financing measures and providing recommendations to combat risk.
Bangladesh Financial Intelligence Unit (BFIU) of Bangladesh Bank and Criminal Investigation
Department (CID) of Bangladesh Police were assigned as its assisting bodies. In the light of the
report prepared by the ACC and its two assisting bodies and the report made by International
Cooperation Review Group (ICRG) after on-site-visit, Bangladesh was recognized as Compliance
Country unanimously in a FATF-meeting held in Paris in February 2014 and Bangladesh was
excluded from the Gray List. As a process of continuing the trend of following and implementing
international standards on anti-money laundering and counter-terrorist financing measures, the
next Mutual Evaluation will be held in October 2015. Since the report on Money Laundering and
Terrorist Financing Risk Assessment is the pre-requisite of Mutual Evaluation, the ACC, BFIU
and CID as assisting bodies are entrusted with the main responsibilities by the NCC.
A working committee led by Director General of the ACC Brigadier General (Retd.) M H
Salahuddin, was formed to serve the purpose. The working committee for conducting Money
Laundering and Terrorist Financing Risk Assessment collects offence related data and information
for last five years from various government offices, autonomous organizations and regulatory
authorities, law-enforcement agencies and intelligence agencies. These databases are coordinated
with the databases of international organizations, media, research papers and websites of several
organizations. Site visit, group discussion and stakeholder consultation are held with the
participation of people from different walks of life such as administration, law-enforcement
agencies, border guard, coast guard, public representatives, journalists, civil society, and
businessmen to prepare the report. It is noted that Bangladesh will not remain under the observation

of FATF if it becomes able to fulfil all the conditions of the Mutual Evaluation to be held in
October 2015, although Bangladesh has achieved the status of United Nations Convention and
FATF standard observing country in prevention of money laundering and terrorist financing.
Bangladesh will be financially benefited in international trade if it can fulfill the conditions of
Mutual Evaluation by providing a risk assessment report and implementing the recommendations
from FATF and APG. Then the LC confirmation charge for Bangladesh will be 0.25- 0.05 percent
in place of 1 percent against export. It would be a great reduction in the costs and time line of
financial transactions and investments with the rest of the world. As a result, Bangladesh will be
benefited financially with the flourishing of trade and commerce side by side with this, the
opportunities for foreign investment will be widened. The draft Money Laundering and Terrorist
Financing Risk Assessment was prepared in 2014. It will be reviewed and finalized after the
approval of the Commission.
 Financial Action Task Force Status
Bangladesh is no longer on the FATF List of Countries that has been identified as having strategic
AML deficiencies.
 Latest Financial Action Task Force Statement: 14 February 2014
The FATF welcomes Bangladesh’s significant progress in improving its AML/CFT regime and
notes that Bangladesh has established the legal and regulatory framework to meet its
commitments in its action plan regarding the strategic deficiencies that the FATF had identified
in October 2010. Bangladesh is therefore no longer subject to FATF’s monitoring process under
its on-going global AML/CFT compliance process. Bangladesh will work with APG as it
continues to address the full range of AML/CFT issues identified in its mutual evaluation
report.
 Compliance with Financial Action Task Force Recommendations
The last Mutual Evaluation Report relating to the implementation of anti-Money Laundering
and counter-terrorist financing standards in Bangladesh was undertaken by the Financial Action
Task Force (FATF) in 2009. According to that Evaluation, Bangladesh was deemed Compliant
for 1 and Largely Compliant for 5 of the FATF 40 + 9 Recommendations. It was partially
compliant or Non-Compliant for 5 of the 6 Core Recommendations.

 US Department of State Money Laundering assessment regarding Bangladesh
Bangladesh was deemed a Jurisdiction of Concern by the US Department of State 2014
International Narcotics Control Strategy Report (INCSR).
Key Findings from the report are as follows: -
 Perceived Risks
While Bangladesh is not a regional financial center, its geographic location, seaports, and long
porous borders with India and Burma make it a transhipment point for drugs produced in both
the “golden triangle” of Southeast Asia and “golden crescent” of Central Asia. Drug trafficking,
corruption, fraud, counterfeit money, and trafficking in persons are the principal sources of illicit
proceeds. Bangladesh is also vulnerable to terrorism financing, including funding that flows
through the Hawala/hundi system and by cash courier. The Bangladesh-based terrorist
organization Jamaat ul-Mujahideen Bangladesh has publicly claimed to receive funding from
Saudi Arabia. Although more work remains, Bangladesh has made important strides in
preventing the potential use of its financial system to finance terrorism.
The Bangladeshi economy relies heavily on remittances, with remittances of $15316.91 million
in FY-2014-15. According to the central bank, a larger share of remittances is now transmitted
through the formal sector, although there remains widespread use of the underground and illegal
Hawala/hundi alternative remittance system. Black market money exchanges remain popular
because of the non-convertibility of the local currency and scrutiny of foreign currency
transactions made through official channels. Alternative remittance systems are also used to
avoid taxes and customs duties. Additional terrorism financing vulnerabilities exist, especially
the use of non-governmental organizations (NGOs), charities, counterfeiting, and loosely-
regulated private banks.
 Sanctions: There are no international sanctions currently in force against Bangladesh.
5.2 Position of Bangladesh in Bribery & Corruption Index:
The Corruption Perceptions Index ranks countries/territories based on how corrupt a country’s
public sector is perceived to be. It is a composite index, drawing on corruption-related data from
expert and business surveys carried out by a variety of independent and reputable institutions.

Index Rank Score (0[highly
corrupt] to 100
[clean])
Transparency International Corruption
Perception Index
145 / 175 25
Control of corruption reflects perceptions of the extent to which public power is exercised for
private gain. This includes both petty and grand forms of corruption, as well as "capture" of the
state by elites and private interests. Control of corruption is one of the six dimensions of the
Worldwide Governance Indicators.
Index Percentile Rank
World Governance Indicator – Control of Corruption 21 %
This line graph shows the country's percentile rank on governance indicator: control of corruption.
Percentile rank indicates the percentage of countries worldwide that rank lower than the indicated
country, so that higher values indicate better governance score.
5.3 Basel Anti-Money Laundering Index and Bangladesh’s position:
The Basel AML Index is an annual ranking assessing country risk regarding Money
Laundering/terrorism financing. It focuses on Anti-Money Laundering and counter terrorist
financing (AML/CTF) frameworks and other related factors such as financial/public
transparency and judicial strength. This annual ranking is started to be published from 2012

and continues to be the only rating of country Money Laundering / terrorist financing risk by
an independent non-profit institution.
The Basel AML Index measures the risk of money laundering and terrorist financing of
countries based on publicly available sources. A total of 14 indicators that deal with AML/CFT
regulations, corruption, financial standards, political disclosure and rule of law are aggregated
into one overall risk score. By combining these various data sources, the overall risk score
represents a holistic assessment addressing structural as well as functional elements in the
AML/CFT framework. As there are no quantitative data available, the Basel AML Index does
not measure the actual existence of money laundering activity or amount of illicit financial money
within a country but is designed to indicate the risk level, i.e. the vulnerabilities of money
laundering and terrorist financing within a country.
The Basel AML Index ranks countries based on the overall score and provides data that is useful
for comparative purposes. However it should be stressed that the primary objective is not to rank
countries in comparison to each other. Rather, the Basel AML Index seeks to provide an overall
picture of a country’s risk level and to serve as a solid starting point for examining progress over
time.
 Country Map Based on Their Risk Categories on Basel Anti-Money Laundering
Index - 2015
Source - index.baselgovernance.org

On the basis of survey done by Basel AML-2015, this map shows the worldwide survey
countries (total 152) that are surveyed and ranked based on their scoring. Higher points indicate
the top ranks and the high risk countries, which are shown with red color in the map. And
lower points indicate low risk countries shown with green color. Which are in low risk or high
risk that is done on the basis of point that starts from 0 to 10. The higher points indicate the
higher risk and the lower points indicate the lower risk. The map provides a bird’s eye view of
the whole world.
5.3.1 The positions of Bangladesh & South Asian countries in Basel AML Index – 2015 &
2014:
 Basel AML Index -2015:
The positions of South Asian countries in Basel Anti-Money Laundering Index 2015 and the
position of Bangladesh is shown below table:
From the above table it is clear that Bangladesh is at relatively better position than most of the
South Asian countries. According to Basel AML Index 2015, Bangladesh is at 52th position with
overall risk of 6.43 which means Bangladesh lies neither in high risk nor in low risk. Only India
with 79th position is at more better condition than Bangladesh. Among South-Asian countries,
Afganistan is at the worst condition with 2nd position.
 Basel AML Index -2014:
The positions of South Asian countries in Basel Anti-Money Laundering Index 2014 and the
position of Bangladesh is shown below table:

From the above table it is clear that Bangladesh is not at relatively better position than most of the
South Asian countries. According to Basel AML Index 2014, Bangladesh is at 57th position with
overall risk of 6.43 which means Bangladesh lies neither in high risk nor in low risk. But most of
the South-Asian countries like Pakistan, Sri Lanka and India are at more lower risk zone than
Bangladesh. Though looking at the whole world’s scenario Bangladesh is neither in high risk nor
in low risk, most of the South Asian zones are at more fair condition than Bangladesh. Among
South-Asian countries, Afganistan is at the worst condition with 2nd position with overall risk of
8.53 out of 10.
5.3.2 Top Ten High Risk Countries in Basel AML Index – 2015 & 2014:
According to the Basel AML Index of 2015 and 2014, the top high risk countries are listed in the
below tables.
Basel AML Index -2015:

Basel AML Index -2014:
In both 2015 and 2014, Myanmar is marked as a high risk zone. It conveys a bad indication for
Bangladesh. Because, Bangladesh has border areas with Myanmar. As Myanmar is at high risk of
money laundering and terrorist financing, it’s impact will must fall in Bangladesh.
Besides, Afghanistan is at the high risk of money laundering with overall scores of 8.48 and 8.53
in 2015 and 2014 consequently. Among the South Asian countries, Afghanistan is at the top risk.
It will have an negative impact on other countries of this same zone.

5.3.3 Change in Bangladesh’s positon in Basel AML Index from 2012 to 2015:
In the below graph, the position of Bangladesh in Basel AML Index from 2012 to 2015 is shown:
The above graphs show that in 2012 Bangladesh was in 47th position scoring 6.28 and the next
year in 2013 Bangladesh achieved 54th position scoring 6.34 and in 2014 Bangladesh has taken
57th position scoring 6.38 and in the at 52th position scoring 6.45 in 2015. The score of Bangladesh
is increasing gradually which is not a good sign but the ranking is better. Though it is not for the
score that Bangladesh achieved but for the increased number of survey countries. It seems that the
score is increasing a bit in every year.
47th
54th 57th
52th
2012 2013 2014 2015
Rank
Year
Position of Bangladesh in Basel AML
Index from 2012-2015
6.28
6.34
6.38
6.43
6.2 6.25 6.3 6.35 6.4 6.45
2012
2013
2014
2015
Overall Scores
Year
Position of Bangladesh in Basel AML
Index from 2012 -2015

5.4 “goAML” Software and its use by Bangladesh Financial Intelligence Unit :
 ‘goAML Software:
The United Nations Office on Drugs and Crime (UNODC) standard software system available
for Financial Intelligence Units to counter Terrorist Financing and Money Laundering.
The Information Technology Service (ITS) of the United Nations Office on Drugs and Crime
(UNODC) specializes in the development; deployment and support of software applications for
use by Member States in a range of UNODC's focus areas.
goAML is a UNODC response to combat money-laundering. It is an intelligence analysis
system intended to be used by the FIU (Financial Intelligence Unit). FIUs have a big role to
play as they have access to financially related information that provides a base for financial
investigations. An FIU is responsible for receiving, analysing and processing reports required
from financial institutions or person referred to in national anti-money-laundering legislation.
 Key Features of “goAML” : The key features of goAML is givne listed below:
 Bangladesh Financial Intelligent Unit:
Bangladesh Financial Intelligence Unit (BFIU) is the central agency of Bangladesh responsible
for analysing Suspicious Transaction Reports (STRs), Cash Transaction Reports (CTRs) &
information related to money laundering (ML) /financing of terrorism (TF) received from
reporting agencies & other sources and disseminating information/intelligence thereon to
relevant law enforcement agencies. BFIU has been entrusted with the responsibility of
exchanging information related to money laundering and terrorist financing with its foreign
counterparts. The main objective of the BFIU is to establish an effective system for prevention
Data
Collection
Workflow
system
Data Clean up
Task
Assignment
and Tracking
Ad-hoc queries
and matching
Document
Management
Statistical
reports
Intelligence file
management
system
Structured
analysis
Integration
and/or data
acquisition
Profiling
Charting and
diagramming
Rule based
analysis
Intelligence
report writer

of money laundering, combating financing of terrorism and proliferation of weapons of mass
destruction.
BFIU was established in June 2002, in Bangladesh Bank (Central bank of Bangladesh) named as
'Anti Money Laundering Department'. To enforce and ensure the operational independence of FIU,
Anti Money Laundering Department has been transformed as the Bangladesh Financial
Intelligence Unit (BFIU) in 25 January, 2012 under the provision of Money Laundering Prevention
Act, 2012 and has been bestowed with operational independence.
 Use of ‘goAML’:
In Bangladesh BFIU controls the use goAML software. Three types of organization can use this
software who are subject to report to BFIU or correspond / exchange their information with BFIU.
They are-
Organization
Type
Description Examples
Reporting
Entity
The organization which is subject to report to the
BFIU.
Bank, Insurance Company
etc
Stakeholder The organization which correspond/exchange
information with BFIU
Police, CID, Election
Commission, customs,
passport office etc
Supervisory
Body
A group of companies or organization controlled
by a supervisory body which is subject to report
to the BFIU
Car Dealer Association,
Audit Firm, Security
Exchange Commission etc
 Bangladesh and “goAML” :
The flow char mentioned below show how the goAML software is deployed in Bangladesh.

5.5 Recent money laundering situation & role of ACC:
The money laundering inquiries and investigation conducted by Anti Corruption Commission is
discussed below:
5.5.1 Money Laundering Enquiries conducted by ACC:
In 2014, the Commission gave emphasis on money laundering enquiries. A total of 226 enquires
were undertaken in the year which was almost 6 and 1.5 times respectively more than those of
2012 (39 enquiries) and 2013 (180 enquiries). The table shown below gives an idea about ACC's
performance in case of resolving money laundering enquiries and outcomes of these enquiries.
Description Number
Unresolved enquiries from the previous year 137
No. of enquiries undertaken in the year 89
Total no. of enquiries 226
No. of enquiries resolved 60
No. of cases (FIR) lodged based on enquiries 20
No. of enquiries filed for record 40
Figure: ACC’s performance of money laundering inquires in 2014
30 July2012
• Bangladesh signs goAML
agreement
20 September
2012
• goAML version 3.4 deployed in
Bangladesh
6 September
2013
• goAML upgraded to version 4.0 in
Bangladesh

5.5.2 Money Laundering Investigation conducted by ACC:
There were 171 investigations in 2014 of which 37 were newly undertaken and the remaining 134
from the previous year. The Commission completed investigations in 63 money laundering cases
and submitted 50 charge-sheets on the basis of these investigations in 2014. The table shown below
gives an idea about ACC's performance in case of resolving money laundering investigations and
outcomes of these investigations.
Description Number
Unresolved investigations from the previous year 134
No. of investigation undertaken in the year 37
Total no. of investigations 171
No. of investigations resolved 63
No. of charge-sheets submitted 50
No. of final reports submitted 13
5.5.3 Recent Money Laundering Events investigated by ACC:
 Corruption of the Bismillah Group:
The Commission took decision to enquire into the matter of corruption of Bismillah Group on the
basis of allegation. During the enquiry, the ACC formed a five-member team led by Commission's
Deputy Director, Syed Iqbal Hossain to enquire into the matter on the basis of news published in
several national dailies in this regard. After analysis of the allegation, it is found that the alleged
persons submitted forged export contract/documents for embezzlement of huge amount of money
from Bhaban Corporate Branch, Moghbazar Branch and Elephant Road Branch of Janata Bank
Limited, Dilkusha Branch of Jamuna Bank Ltd., Motijheel Branch of Premier Bank Ltd., Motijheel
Branch of Prime Bank Ltd. and from Eskaton Branch of Shahjalal Islami Bank Ltd., through
Bismillah Group and its associated companies. The concerned bank managers including officials
by violating Guidelines for Foreign Exchange Transaction 2009, being profited or hoping to be
profited, adjusted the fake/forged accommodation bills to the effect that goods had been exported
by the companies though it was not done. Later on, without showing any objection against 'Back
to Back Letter of Credit (LC)' of Bismillah Group, they assisted directly the alleged Khaza
Solaiman Anwar Chowdhury with others to misappropriate money through corruption, fraud and
forgery. The bank officials committed offences under MLPA, 2012 by issuing FDBP against fake
export bill, opening 'Back to Back LC' against Sales Contract and disbursing 'Forced Loans' from
the banks. Twelve cases (FIR) were lodged against the alleged persons under Section 4 (2), (3) of

MLPA, 2012 with several police stations after the approval of the Commission on the basis of the
enquiry report.
Amount of money embezzled and laundered:
Serial
no.
Bank’s name Branch name Funded Taka
(Crore)
Non-funded
taka (Crore)
1.
Janata Bank Ltd.
Bhaban Corporate Branch 307.38 25.53
Moghbazar Branch 177.10 1.60
Elephant Road Branch 15.34 0.00
2. Prime Bank Ltd. Motijheel Branch 265.20 61.08
3. Premier Bank Ltd. Motijheel Branch 23.22 39.31
4. Jamuna Bank Ltd. Dilkusha Branch 108.64 46.02
5. Shajalal Islami Bank Eskaton Branch 93.15 10.89
Total 990.03 184.43
In the 12 cases, total alleged persons are 53 and amount of embezzled and laundered money is
BDT 1174.46 crore. Four investigation officers of the Commission already submitted investigation
reports of the cases. Further lawful measures will be taken according to the decision of the
Commission.

Chapter 6
The impacts of Money Laundering
6.1 Impacts of Money Laundering on Economy of the World:
The money laundering impact on the economy is highly staggering in the whole world. The
situations are highly noticeable. The conditions will be better understandable if we see from the
core of the concern. We will summarize the classification of the different such types of effects that
are done on the economy by none other than money laundering:
Impacts on
Economic
Development
Financial Sector

Figure 6.1: Effects on Economic Development
6.1.1 Brief Statistics and Core RelatedWays of Money Laundering:
Depending on which international agency you ask, criminals launder anywhere between $500
billion and $1 trillion worldwide every year. The global effect is staggering in social, economic
and security terms. In 1996, the aggregate size of money laundering in the world may be between
2% and 5% of the world’s gross domestic product.
On the socio-cultural end of the spectrum, successfully laundering money means that criminal
activity actually does pay off. This success encourages criminals to continue their illicit schemes
because they get to spend the profit with no repercussions. This means more fraud, more corporate
embezzling (which means more workers losing their pensions when the corporation collapses),
more drugs on the streets, more drug-related crime, law-enforcement resources stretched beyond
their means and a general loss of morale on the part of legitimate business people who don't break
the law and don't make nearly the profits that the criminals
The economic effects are on a broader scale. Developing countries often bear the brunt of modern
money laundering because the governments are still in the process of establishing regulations for
their newly privatized financial sectors. This makes them a prime target. In the 1990s, numerous
banks in the developing Baltic States ended up with huge, widely rumored deposits of dirty money.
Bank patrons proceeded to withdraw their own clean money for fear of losing it if the banks came
under investigation and lost their insurance. The banks collapsed as a result. Other major issues
facing the world's economies include errors in economic policy resulting from artificially inflated
financial sectors. Massive influxes of dirty cash into particular areas of the economy that are
desirable to money launderers create false demand, and officials act on this new demand by
adjusting economic policy. When the laundering process reaches a certain point or if law-
enforcement officials start to show interest, all of that money that will suddenly disappears without
any predictable economic cause and that financial sector falls apart.
Real Sector
External Sector

Some problems on a more local scale relate to taxation and small-business competition. in tax
revenue. Also, legitimate small businesses can't compete with money-laundering front businesses
that can afford to sell a product for cheaper because their primary purpose is to clean money, not
turn a profit. They have so much cash coming in that they might even sell a product or service
below cost.
The majority of global investigations focus on two prime money-laundering industries:
 Drug trafficking
 Terrorist organizations.
The effect of successfully cleaning drug money is clear: More drugs, more crime, and more
violence. The connection between money laundering and terrorism may be a bit more complex,
but it plays a crucial role in the sustainability of terrorist organizations. Most people who
financially support terrorist organizations do not simply write a personal check and hand it over to
a member of the terrorist group. They send the money in roundabout ways that allow them to fund
terrorism while maintaining anonymity. And on the other end, terrorists do not use credit cards
and checks to purchase the weapons, plane tickets and civilian assistance they need to carry out a
plot. They launder the money so authorities can't trace it back to them and foil their planned attack.
Interrupting the laundering process can cut off funding and resources to terrorist groups.
6.1.2 Impacts on Financial Sector:
1. Increased Crime and Corruption:
Successful money laundering helps make criminal activities profitable. Thus, to the extent that a
country is viewed as a haven for money laundering, it is likely to attract criminals and promote
corruption. Havens for money laundering and terrorist financing have:
a weak AML/CFT regime;
some or many types of financial institutions that are not covered by the AML/CFT
framework;
little, weak or selective enforcement of AML/CFT;
ineffective penalties, including difficult confiscation provisions; and
a limited number of predicate crimes for money laundering.
2. Undermining the Integrity of Financial Institutions and Markets:

The success of money laundering exploits has far reaching impact on the whole financial
systems of many developing countries. Laundered money eventually flows into the international
financial system and in the course of this process; countries that integrate into the global financial
systems are exposed to the phenomenon of money laundering. Elaborating on the fact, the one-
time chairman of the EFCC Nigeria, Nuhu Ridadu, stated that the amount involved in various
forms of transnational economic and financial crimes especially corruption, are often so large that
it affects both the integrity of domestic economies and the global financial systems40. For
instance, an estimated amount of $100 billion was corruptly exported from Nigeria between mid
1980s and 1999 while more than $ 1 trillion illicit funds flowed into the United States annually
through the international financial systems and this includes the proceeds from drug trafficking
and other forms of economic and financial crimes. In further reference to the Nigeria financial
system, between the 80s and 90s, the reputation of the financial system in the country was at its
lowest at this period. This was primarily down to the damaging status of the nation’s financial
system attributed to the negative impact of economic and financial crimes that were rampant at the
time. During this period, most potential foreign investors were reluctant to extend their
commercial ventures to the Nigeria primarily because of the aforementioned reason.
Consequently, the financial institutions in the country relied overwhelmingly on the ill-gotten
capital drained off by corrupt political office holders. Hence, these financial institutions were
unable to endure the tests of market competition. As a result, many of these financial
institutions disintegrated42, thus, exposing the instability of the country’s financial system
and deemed not to investment friendly. The situation amounted to hindrance that hampered the
surge of investments and economic development in the country, even to this moment.
3. Loss of Control of the National Economic Policy:
One time director of the International Monetary Fund (IMF), Michael Camdessus, once
estimated the scale of money laundering as between 2% to 5% of world Gross Domestic Product
(GPD)43. In his this perspective, developing countries are poised to losing control of their
domestic economic policies as illicit capital accrued from money laundering activities and other
economic and financial crimes are capable of dwarfing government budgets and destabilize
domestic markets44. Furthermore, an IMF working paper concludes that money laundering
impacts financial behavior and macro-economic performance in different forms such as
policy mistakes, due to measurement errors in national account statistics, volatility in exchange
and interest rates due to unanticipated cross border transfers of funds; the threat of monetary
instability due to unsound asset structures; effects on tax collection and public expenditure
allocation due to misreporting of income; misallocation of resources due to distortions in asset
and commodity prices; and contamination effects on legal transactions due to the perceived
possibility of being associated with crime45. Thus, in some developing countries, the illicit
proceeds from criminal ventures dwarf government budgets, thereby, leading to a loss of control
of their economic policies. Furthermore, the exploits of money laundering and currency

Money Laundering in Bangladesh

Money Laundering in Bangladesh

Recommended

Recommended

More Related Content

What's hot

What's hot (20)

Similar to Money Laundering in Bangladesh

Similar to Money Laundering in Bangladesh (20)

More from Pantho Sarker

More from Pantho Sarker (20)

Recently uploaded

Recently uploaded (20)

Money Laundering in Bangladesh