金融行动特别工作组-环境犯罪洗钱（英）-2021.6-72页_1mb

Summary of FATF Report: Money Laundering from Environmental Crime

Core Content

The Financial Action Task Force (FATF) report titled Money Laundering from Environmental Crime (July 2021) explores the financial implications and laundering techniques associated with environmental crimes, such as illegal logging, illegal mining, and waste trafficking. It highlights the significant scale of these crimes and their impact on the global financial system, emphasizing the need for enhanced cooperation and regulatory measures to combat them.

Main Points

Environmental Crime Overview

• Environmental crime includes illegal extraction and trade of forestry and minerals, illegal land clearance, and waste trafficking.
• These crimes generate substantial illicit financial flows, with illegal logging, mining, and waste trafficking accounting for two-thirds of all environmental crime proceeds.
• Environmental crime not only has financial implications but also affects public health, safety, and the environment, while fueling corruption and converging with other serious crimes like drug trafficking and forced labor.

Money Laundering Techniques

• Criminals use front companies and shell companies to mix illegal and legal proceeds and conceal their sources.
• Trade-based fraud is a common method used to launder proceeds from illegal activities.
• Offshore jurisdictions are often exploited to facilitate the placement and layering of funds, making it crucial to identify beneficial owners.

Challenges in Combating Money Laundering

• There is limited awareness and understanding of the money laundering risks associated with environmental crime among national authorities and the private sector.
• Legal frameworks are often narrowly drafted and do not fully address transnational aspects of these crimes.
• Coordination between AML/CFT authorities and environmental crime investigators is weak.
• Law enforcement lacks sufficient powers and resources to trace and investigate proceeds from environmental crime.
• Societal awareness and political will are insufficient in some countries to address the issue effectively.

FATF's Role and Priorities

• The FATF has recognized environmental crime as a priority since 2019, building on previous reports on the gold and diamond trades.
• This report is based on case studies and good practices from over 40 countries, as well as input from civil society and the private sector.
• Key priorities include:
  • Ensuring all FATF members assess the risk of criminals misusing financial and non-financial sectors.
  • Strengthening operational capacity for detecting and pursuing financial investigations.
  • Fully implementing FATF standards to address money laundering from environmental crime.
  • Enhancing AML outreach to relevant intermediaries, such as precious metals and stones dealers, and trust and company service providers (TCSPs).

Key Information

Global Estimates

• Environmental crime generates USD 110 to 281 billion annually in criminal proceeds.
• Forestry crime accounts for the largest share, estimated at USD 51 to 152 billion.
• Illegal mining generates USD 12 to 48 billion annually, with gold and diamonds being the most significant sources.
• Waste trafficking is estimated to generate USD 10 to 12 billion annually.

Regional Trends

• Forestry crime is concentrated in Central and South America, Central and Southern Africa, Southeast Asia, and Eastern Europe.
• Illegal mining is primarily sourced from South America and Africa, with materials often destined for global markets.
• Waste trafficking involves the illegal export and disposal of e-waste, plastics, and hazardous substances, often affecting developing countries.

Convergence with Other Crimes

• Environmental crime frequently converges with drug trafficking, forced labor, and corruption.
• The cash-intensive nature of the mining industry allows for the laundering of proceeds from other crimes.
• International cooperation is essential to trace and recover illicit assets that are moved and held abroad.

Recommendations and Priority Actions

• AML authorities should establish working relationships with environmental crime investigators and protection agencies.
• National and international coordination must be strengthened to address the cross-border nature of these crimes.
• Legal frameworks should be updated to cover transnational aspects of environmental crime.
• Private sector engagement is critical for identifying and reporting suspicious financial activity.
• Enhanced data collection and cross-border information sharing are necessary to improve the detection and investigation of illicit financial flows.

Conclusion

The report underscores the lucrative and safe nature of environmental crime for criminals, due to the low risk and high reward aspect. It highlights the importance of multi-stakeholder dialogues, regulatory improvements, and international cooperation to disrupt the financial flows and reduce the profitability of environmental crimes. The FATF calls for a comprehensive and coordinated approach to tackle the complex and evolving money laundering risks associated with these activities.

Annexes

• Annex A provides risk indicators for detecting money laundering from environmental crimes.
• Annex B discusses the convergence of environmental crime with other crimes.
• Annex C includes additional case studies and examples.

References

• UNEP (2016)
• Uhm (2020)
• FATF (2020)
• FATF (2015)
• FATF (2013)
• GIABA (2019)
• United Nations (2019)

Figures

• Figure 1.1 illustrates the relevance of FATF standards for combating environmental crimes.
• Figure 2.1 shows illegally cleared rainforests.
• Figure 2.2 and Figure 2.3 provide country profiles for forestry crime and illegal mining.
• Figure 2.4 and Figure 2.5 depict criminal supply chains and illegal tyre dumping.
• Figure 4.1 shows the coverage of ML for environmental crimes.

This report serves as a critical reference for understanding the financial dimensions of environmental crime and provides actionable insights for both governments and the private sector to strengthen their AML/CFT measures and international collaboration.