與COVID-19相關的洗錢和恐怖主義融資風險和政策對策 - 反洗錢金融行動特別工作組（英文版）.pdf

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1、COVID-19-related Money Laundering and Terrorist Financing Risks and Policy Responses May 2020 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes policies to protect the global financial system against money laundering, terrorist financing and

2、the financing of proliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money laundering (AML) and counter-terrorist financing (CFT) standard. For more information about the FATF, please visit www.fatf-gafi.org This document and/or any map included h

3、erein are without prejudice to the status of or sovereignty over any territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference: FATF (2020), COVID-19-related Money Laundering and Terrorist Financing Risks and Policy Resp

4、onses, FATF, Paris, France, www.fatf-gafi.org/publications/methodandtrends/documents/covid-19-ML-TF.html 2020 FATF/OECD. All rights reserved. No reproduction or translation of this publication may be made without prior written permission. Applications for such permission, for all or part of this pub

5、lication, should be made to the FATF Secretariat, 2 rue Andr Pascal 75775 Paris Cedex 16, France (fax: +33 1 44 30 61 37 or e-mail: contactfatf-gafi.org) Photocredits coverphoto Gettyimages COVID-19-related Money Laundering and Terrorist Financing Risks and Policy Responses 2 | COVID-19-RELATED ML/T

6、F RISKS AND POTENTIAL POLICY RESPONSES | FATF Foreword The COVID-19 pandemic has led to unprecedented global challenges, human suffering and economic disruption. This paper identifies challenges, good practices and policy responses to new money laundering and terrorist financing threats and vulnerab

7、ilities arising from the COVID-19 crisis. It is based on papers shared on 7 and 23 April with the FATF Global Network of FATF Members and FATF-Style Regional Bodies (FSRBs), together making up more than 200 jurisdictions. The authors thank the FATF members, observers, the FSRB Secretariats and their

8、 members for their contribution to the report. This report was written by Kristen Alma, Shana Krishnan, Colby Mangels and Mei-Lin Wang from the FATF Secretariat. This paper is for information and does not constitute the official view of the FATF. It does not imply or constitute any changes to the FA

9、TF Standards. The measures cited, and taken by some FATF members authorities, have not been reviewed or considered by the FATF membership as a whole. | | 3 COVID-19-RELATED ML/TF RISKS AND POTENTIAL POLICY RESPONSES | FATF Table of contents 1. Introduction 5 2. Evolving ML/TF risk picture 5 2.1. Inc

10、reased ML Threats 5 2.2. Other Contextual Factors and ML Vulnerabilities 8 2.3. Financing of Terrorism 10 2.4. Summary of Potential ML/TF Risks 11 3. Current COVID-19 impact on AML/CFT regimes 11 4. Potential AML/CFT Responses for consideration 13 Annex A. Statement by the FATF President 17 Annex B.

11、 Statement or guidance issued by authorities in response to COVID-19 19 References 29 4 | COVID-19-RELATED ML/TF RISKS AND POTENTIAL POLICY RESPONSES | FATF Key findings The increase in COVID-19-related crimes, such as fraud, cybercrime, misdirection or exploitation of government funds or internatio

12、nal financial assistance, is creating new sources of proceeds for illicit actors. Measures to contain COVID-19 are impacting on the criminal economy and changing criminal behaviour so that profit-driven criminals may move to other forms of illegal conduct. The COVID-19 pandemic is also impacting gov

13、ernment and private sectors abilities to implement anti-money laundering and counter terrorist financing (AML/CFT) obligations from supervision, regulation and policy reform to suspicious transaction reporting and international cooperation. These threats and vulnerabilities represent emerging money

14、laundering (ML) and terrorist financing (TF) risks. Such risks could result in: o Criminals finding ways to bypass customer due diligence measures; o Increased misuse of online financial services and virtual assets to move and conceal illicit funds; o Exploiting economic stimulus measures and insolv

15、ency schemes as a means for natural and legal persons to conceal and launder illicit proceeds; o Increased use of the unregulated financial sector, creating additional opportunities for criminals to launder illicit funds; o Misuse and misappropriation of domestic and international financial aid and

16、emergency funding; o Criminals and terrorists exploiting COVID-19 and the associated economic downturn to move into new cash-intensive and high-liquidity lines of business in developing countries. AML/CFT policy responses can help support the swift and effective implementation of measures to respond

17、 to COVID-19, while managing new risks and vulnerabilities. These include: o Domestic coordination to assess the impact of COVID-19 on AML/CFT risks and systems; o Strengthened communication with the private sector; o Encouraging the full use of a risk-based approach to customer due diligence; o Sup

18、porting electronic and digital payment options. | | 5 COVID-19-RELATED ML/TF RISKS AND POTENTIAL POLICY RESPONSES | FATF 1. Introduction This paper is part of a coordinated and timely response to the impact of the COVID-19 crisis on global anti-money laundering (AML) and counter terrorist financing

19、(CFT) efforts and the application of the FATF Standards in this context. This response also includes a Statement from the FATF President, issued on 1 April, on how the risk-based approach of the FATF Standards provides for emerging threats and vulnerabilities to be managed effectively and in support

20、 of COVID-19 aid and containment efforts (see Annex A). A list of statements and guidance issued by authorities in response to COVID-19 is included in Annex B, for reference. This paper was developed in response to the unprecedented and rapidly evolving COVID- 19 public health crisis. The findings c

21、ontained within are likely to evolve as this crisis further develops. This paper is informed by open-source research, and information received from member countries of the FATF and FATF-style regional bodies (FSRBs) and observer organisations such as the International Monetary Fund (IMF), World Bank

22、 and United Nations. The focus of this paper relates to three broad themes: New threats and vulnerabilities stemming from COVID-19-related crime and impacts on ML and TF risks; Current impact on AML/CFT efforts by governments and the private sector due to COVID-19; Suggested AML/CFT policy responses

23、 to support the swift and effective implementation of measures to respond to COVID-19, while managing new risks and vulnerabilities identified, including: charitable activity and economic and fiscal stimulus and financial rescue packages for firms and individuals. 2. Evolving ML/TF risk picture 2.1.

24、 Increased ML Threats The COVID-19 pandemic has generated various government responses, ranging from social assistance and tax relief initiatives, to enforced confinement measures and travel restrictions. While unintended, these measures may provide new opportunities for criminals and terrorists to

25、generate and launder illicit proceeds. While the precise situation and public health responses in each country varies according to the impact of COVID-19, the evolving risk picture detailed in this section is based on the following general assumptions: Governments, businesses and individuals are inc

26、reasingly turning to online systems to enable remote work. Individuals under “lockdown” (or other movement restriction measures) are also increasingly turning to online platforms for social interaction. Businesses that are classified as non-essential have physically closed. Both essential and non-es

27、sential business are seeing increased online sales. 6 | COVID-19-RELATED ML/TF RISKS AND POTENTIAL POLICY RESPONSES | FATF The COVID-19 pandemic has driven significant demand for medical supplies, such as personal protective equipment, ventilators and medicines and there is a global shortage of such

28、 goods due to the overwhelming demand. Banks and financial institutions remain in operation with some offering more limited services and restricting in-person banking. The closure of many businesses due to “lockdown” measures and other restrictions on trade and travel has led to mass unemployment or

29、 the furloughing of workers, loss of government revenue and a general economic recession that will impact the financial and social behaviour of businesses and individuals. Government resources have been reprioritised towards responding to COVID-19, taking resources away from other areas of work. Wit

30、h global trade volumes in decline and individual travel at a near standstill, conventional transnational organised crime schemes that take advantage of global supply chains and the traditional illicit revenue schemes of organised crime groups are impacted by COVID-19. Increased Fraud Reporting from

31、FATF members, observers, and open sources indicates that criminals have attempted to profit from the COVID-19 pandemic through increased fraudulent activities. At the time of writing, the primary fraudulent activities include: Impersonation of officials: In such cases, criminals contact individuals

32、(in person, email or telephone) and impersonate government officials with the intent of obtaining personal banking information or physical cash. In some cases, criminals impersonate hospital officials who claim a relative is sick and require payment for treatment (Interpol, 20201), or government off

33、icials requesting personal banking information for tax relief purposes (US Treasury, 20202). Cases involving government impersonation are likely to increase as governments around the world disburse grants and tax relief payments to their citizens, with criminals attempting to profit from these payme

34、nts. Counterfeiting, including of essential goods (such as medical supplies and medicines): Given the high demand, there is a significant increase in online scams involving certain medical supplies, personal protective equipment and pharmaceutical products. In such cases, the suspects claim to be em

35、ployees of businesses, charities, and international organisations offering masks, testing kits and other products, and request credit card information for payment or a shipping fee but never deliver the goods. (US FDA, 20203) In some scenarios, victims were asked to make payment in advance via bank

36、transfers and then directed to collect goods from various locations, but were then subsequently informed that there were no such arrangements. (Singapore Police Force, 20204) In similar scams, the goods are delivered to the consumer but are counterfeit or ineffective.1 Such scams target both individ

37、ual consumers and businesses. FATF members are also seeing an increase in false and misleading COVID-19 treatment claims and vendors selling illegal products marketed as “miracle” cures.2 Fundraising for fake charities: FATF members highlight an increase in fundraising scams. In such cases, criminal

38、s posing as international organisations or charities circulate emails requesting donations for COVID-19-related 1 (European Commission, 202028) (Cellule de Renseignement Financier Luxembourg, 20206) (Interpol, 20207) (Europol, 20208) 2 (US Justice Department, 20209) (US ICE, 202010) | | 7 COVID-19-R

39、ELATED ML/TF RISKS AND POTENTIAL POLICY RESPONSES | FATF fundraising campaigns (purportedly for research, victims and/or products). Recipients of these emails are then directed to provide credit card information or make payments through the suspects secure digital wallet. Fraudulent investment scams

40、: The economic crisis resulting from COVID-19 has led to an increase in investment scams, such as promotions falsely claiming that products or services of publicly traded companies can prevent, detect or cure COVID-19. (Europol, 20205) Reporting by FATF members highlighted that microcap stocks, typi

41、cally issued by the smallest companies, may be particularly vulnerable to fraudulent investment schemes as they are low-priced stocks with often limited publicly-available information. This facilitates the spread of false information about the company. (US Securities and Exchange Commission, 20206)

42、Cyber Crime There has been a sharp rise in social engineering attacks, specifically phishing email and mobile messages through spam campaigns. These attacks use links to fraudulent websites or malicious attachments to obtain personal payment information. Email and SMS phishing attacks: Criminals are

43、 exploiting concerns about COVID-19 to insert malware on personal computers or mobile devices. In one example, cybercriminals posed as the World Health Organization (WHO) and sent email and mobile messages to lure individuals into clicking malicious links or opening attachments, which subsequently r

44、eveal the individuals user name and password. (WHO, 20207) Various versions of these phishing attacks are currently being reported. Other examples include government impersonation via SMS to lure individuals to fraudulent government websites to obtain personal account information and/or sensitive us

45、ernames and passwords. (CISA, 20208) Business email compromise scams: Amid a sharp rise in global remote- working, cybercriminals are also exploiting weaknesses in businesses network security to gain access to customer contact and transaction information. This information is then used in targeted ph

46、ishing emails whereby the criminals pose as the compromised business and request payment for legitimate goods and/or services but instead direct this payment into their illicit accounts. (FBI, 20209) In another example, a company received spoofed emails similar to those sent by their business partne

47、r to redirect payment transfers to scammers controlled bank accounts, under the pretext of paying for large supplies of surgical masks and hand sanitiser. Ransomware attacks: Reports also indicate that cybercriminals are using different methods to insert ransomware on personal computers and mobile d

48、evices. For example, some FATF members report that cybercriminals are using malicious websites and mobile applications that appear to share COVID-19- related information to gain and lock access to victims devices until payment is received. Organisations at the forefront of the COVID-19 response can

49、be heightened targets for cybercriminals. Specifically, hospitals and other medical institutions have increasingly become targets of cybercriminals for ransomware attacks. (Interpol, 202010) 8 | COVID-19-RELATED ML/TF RISKS AND POTENTIAL POLICY RESPONSES | FATF Impact on Other Predicate Crimes Human Trafficking3 and Exploitation of Workers: Criminals may take ad