ABA ROLI has a robust and diverse anti-money laundering and countering terrorist financing (AML/CTF) portfolio of programs, which includes programs that aim to disrupt money laundering (ML) though gambling, build capacity of Financial Intelligence Units (FIUs) and investigators to conduct intelligence led financial investigations, analyze open-source data to effectively identify money laundering trends and bolster investigations and prosecutions, improve reporting and compliance. Our AML programming builds on ABA ROLI’s long-standing anti-corruption work and efforts to address the predicate crimes to money laundering, such as wildlife, drug, and human trafficking. ABA ROLI has established relationships with a wide range of stakeholders from both the public and private sector—regulators; legislators; civil society organizations; and professional associations of designated non-financial businesses and professions, (DNFBPs) such as lawyers, real estate agents, accountants and gaming operators—to meet their AML obligations. ABA ROLI has a long-standing presence in multiple countries and extensive, often decades-long, institutional partnerships within various host country governments, including prosecutorial services, anti-corruption agencies, anti-money laundering investigation offices, asset recovery agencies, lawyer networks, legal professional associations, and broader civil society partners.
Addressing Money Laundering and Countering Financial Terrorism
Approaches
- Combination of multilateral and country-level assistance to empower governments with tools and capacity-building to strengthen legal frameworks governing AML in various sectors.
- Build partnerships between public sector supervisors/regulators and private sector financial institutions and designated non-financial businesses and professions (DNFBPs) to implement a risk-based approach, identify emerging money-laundering threats and improve detection and actionable reporting of suspicious activities and transactions thereby denying criminal groups access to the funds they use to carry out and profit from transnational crimes.
- Bring top international, multidisciplinary regulatory, compliance, and AML/CFT expertise through leveraging ABA ROLI’s in-house expertise and partnerships with the leading AML and subject matter expert organizations and individual experts.
- Build the capacity of regulators, investigators, and law enforcement agents to apply analytical frameworks, strategies, and skills in integrated anti-money laundering investigations.
- Build capacity among Non-Profit Organizations (NPOs) and within NPO supervisors to protect NPOs against abuse by illicit actors; support reforms related to supervision of this sector, including commencing risk-based supervision; conduct a sectoral risk assessment; and perform outreach to NPOs regarding their obligations
With funding from the U.S. Department of State’s Bureau of International Narcotics and Law Enforcement Affairs and the U.S. Department of State Bureau of Counterterrorism, ABA ROLI is implementing seven programs related to Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), and Transnational Organized Crime (TOC). The program span across the following regions: Asia and the Pacific, Europe and Eurasia, the Middle East and North Africa, and Latin America and the Caribbean.
Disrupting Money Laundering Through Gambling
Countries of Focus: Lao PDR, Vietnam, Thailand
The Project’s goal is to deny criminal groups, as well as malign state and other non-state actors, access to funds that they use to carry out and profit from transnational crime.
Training to Leverage Big Data Analytics to Identify Money Laundering and Sanctions Evasion
Countries of Focus: Malaysia, Thailand, Tunisia
The Project’s goal is to increase Financial Intelligence Units (FIUs) & investigators’ capacity to use available Open-Source Intelligence (OSINT) data to identify money laundering trends, detect money laundering, and bolster investigations and prosecutions.
South Asia Transnational Partnerships Against Money Laundering
Countries of Focus: Maldives
The Project’s goal is to build partnerships between public sector supervisors/regulators and private sector financial institutions and designated non-financial businesses and professions to implement a risk-based approach, identify emerging money-laundering threats and improve detection and actionable reporting of suspicious activities and transactions, thereby denying criminal groups access to the funds they use to carry out and profit from transnational crimes.
FATF Compliance in Eastern Europe
Countries of Focus: Albania and Serbia
The Project’s goal is to facilitate the development of country specific action plans and implementation efforts in Albania and Serbia to advance national adherence to meet Financial Action Task Force (FATF) recommendations. Program organized training sessions focused on topics associated with efforts to combat, mitigate, and protect against money laundering in Serbia and Albania. ABA ROLI partnered with local organizations the Institute for Democracy and Mediation (IDM) in Albania and "Partners Serbia” in Serbia. The program’s period of performance is from September 2020 to September 2023.
Albania
IDM convened a multi-stakeholder civic-private forum in November 2022 that brought together civil society, private sector, and government representatives to share perspectives, updates and challenges in the sector while also learning from subject matter experts. To build a sustainable Anti-Money Laundering and Counter Terrorism Financing (AML/CFT) supervisory capacity within the Ministry of Justice, ABA ROLI’s subcontractor K2 Integrity developed and delivered an advanced training course for MOJ staff who serve as supervisors of real estate agents. Topics included money laundering risks in Albania as a whole and in the real estate sector; AML requirements under the FATF standards and Albanian law; applying AML preventive measures to mitigate identified risks; and appropriate supervisory techniques. The course reflected the findings of Albania’s Mutual Evaluation Report and National Risk Assessment; FATF publications; and global experiences related to laundering of real estate sector criminal profits.
Serbia
K2 Integrity delivered the intensive training for NPOs and supervisors on money laundering risks facing the sector and how NPOs can deploy required preventive measures——to protect themselves against abuse by criminals seeking to launder the proceeds of crime. Training materials incorporated Serbia’s current and forthcoming National Risk Assessment and global best practices for NPO protection.
Training on Intelligence-Led Money Laundering Investigations Across the Balkans and Southeast Asia
Countries of Focus: Thailand, Laos, Indonesia, the Philippines Montenegro, North Macedonia, the Pacific Islands
The Project’s goal is to promote the adoption of intelligence-led, network-centered financial investigations to improve prosecutions of money laundering.
The program aims to:
- Improve investigative analysis tools and techniques and investigation planning and casework skills.
- Share successful examples of proactive public-private financial information sharing and methods to create a shared understanding of financial crime risks and typologies between law enforcement agencies and financial institutions.
- Strengthen multi-agency cooperation and coordination within governments, including intelligence-led identification and disruption of the most harmful offenders and facilitators of financially motivated crime, and the implications for AML/CFT regulatory oversight.
- Advance measures to improve the confiscation of criminal funds flowing through the international financial system, including non-conviction-based asset forfeiture.
- Improve the knowledge of financial investigators and law enforcement of virtual asset regulations, trading methods, and how to detect, counter and investigate illegal usage of virtual assets and address the challenges linked with the seizure and confiscation of virtual assets.
Recent Events
Countering the Financing of Terrorism in South America
Countries of Focus: Argentina, Brazil, Paraguay
Funded by the U.S. Department of State Bureau of Counterterrorism, this program provides technical support to the governments, financial sector, and civil society in Argentina, Brazil, and Paraguay with the goal to combat money laundering, terrorism financing, and transnational crime, thereby reducing the capacity of criminals and terrorist organizations to move assets and to conduct terrorist attacks and other illicit activities.
Working closely with central and local government agencies, financial institutions, and civil society, ABA ROLI aims to leverage specialized expertise to support the governments of Argentina, Brazil, and Paraguay in meeting their commitments under the United Nations Convention against TOC, the international standards on AML set by the Financial Action Task Force, and the United Nations Security Council Resolutions on Countering the Financing of Terrorism (CFT).
Raising Public Awareness on Countering the Financing of Terrorism in the Tri-Border Area
Countries of Focus: Argentina, Brazil, Paraguay
Funded by the U.S. Department of State Bureau of Counterterrorism, this program improves the capacity of criminal justice sectorsand financial institutions in Argentina, Brazil, and Paraguay to promote public awareness about the risks and realities of terrorism financing, money laundering, and organized transnational crime in the Tri-Border Area and show how everyday activities may unwittingly contribute to related crimes.
By working closely with the communication departmentsof the criminal justice sectors, financial institutions, and Financial Intelligence Units, this program gathers information from different beneficiaries to provide customized advice to improve their processes. Additionally, the program develops awareness campaignson AML, TOC, and CFT and assists beneficiaries in implementing them, aiming to raise public awareness to help reduce unwitting involvement in these criminal acts.