Money laundering involves the deliberate cleaning up of the proceeds of crime. Increasingly this area has seen major developments in recent years in the terrorist financing and cyber space. Terrorist financing is now included in this overall area but has a different approach, as it relates to the use of legitimate and illicit funds to finance terrorist activity.

Cyber-related tactics are relevant to this whole area and relate to the use of new technologies to achieve similar illicit objectives. The use of new technologies to conduct illicit activities requires a very different practical toolkit for counter-measures, with surveillance, detection and data protection expertise core assets. But this does not change the fundamental approach to illicit activities as their scope spreads into innovative media and spheres of influence.

The effectiveness of the response to money laundering is currently at a crossroads – despite huge amounts invested in anti-money laundering programs, the level of effectiveness is relatively underwhelming. Europol Chief, Wainwright, noted in 2018 that a mere 1% of all illicit activity was being countered despite the multi-million dollar anti-money laundering programs implemented.

A proactive, pre-emptive, pragmatic and results-oriented approach to Money Laundering sanctions is therefore essential.