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  • Journal of Money Laundering ControlInvestigation and prosecution of money laundering cases in MalaysiaZakiah Muhammaddun Mohamed Khalijah Ahmad

    Article information:To cite this document:Zakiah Muhammaddun Mohamed Khalijah Ahmad, (2012),"Investigation and prosecution of moneylaundering cases in Malaysia", Journal of Money Laundering Control, Vol. 15 Iss 4 pp. 421 - 429Permanent link to this document:http://dx.doi.org/10.1108/13685201211266006

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    Users who downloaded this article also downloaded:Bala Shanmugam, Haemala Thanasegaran, (2008),"Combating money laundering in Malaysia", Journal ofMoney Laundering Control, Vol. 11 Iss 4 pp. 331-344 http://dx.doi.org/10.1108/13685200810910402Bala Shanmugam, Mahendhiran Nair, R. Suganthi, (2003),"Money laundering in Malaysia", Journal ofMoney Laundering Control, Vol. 6 Iss 4 pp. 373-378 http://dx.doi.org/10.1108/13685200310809699Guru Dhillon, Rusniah Ahmad, Aspalela Rahman, Ng Yih Miin, (2013),"The viability of enforcementmechanisms under money laundering and anti-terrorism offences in Malaysia: An overview", Journal ofMoney Laundering Control, Vol. 16 Iss 2 pp. 171-192 http://dx.doi.org/10.1108/13685201311318511

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  • Investigation and prosecutionof money laundering cases

    in MalaysiaZakiah Muhammaddun Mohamed and Khalijah Ahmad

    School of Accounting, Faculty of Economics and Management,Universiti Kebangsaan, Bangi, Malaysia

    Abstract

    Purpose The purpose of this paper is to examine money laundering cases investigated bythe Central Bank of Malaysia under the Anti-Money Laundering and Anti-Terrorism FinancingAct 2001.

    Design/methodology/approach This study analyzes the contents of public releases by theenforcement division of the Central Bank for period 2007 to 2011. Analysis of data is carried out basedon three categories: the predicate offence, the perpetrators and current status of the cases.

    Findings Findings reveal that most cases investigated by the Central Bank relate to sec 4(1) ofAMLATFA 2001 and the main predicate offence related to the money laundering charges are on illegaldeposit taking. Further it is found that directors of companies are the leading group of people chargedunder the Act for money laundering. In addition, findings also show that only half of the casesinvestigated have been charged in court.

    Research limitations/implications Data from this research only come from enforcementreleases from the Central Bank of Malaysia. Since AMLATFA2001 is administered by multipleagencies, the research may not provide a comprehensive view of all the cases investigated.Future research should look at other agencies and in particular the Royal Police of Malaysia.

    Practical implications Findings from the study suggest that prosecuting money launderingcases by Bank Negara Malaysia are limited to cases with predicate offence of illegal deposit taking.The agency should explore other predicate offences and the concept of irresistible inference toincrease its effort in prosecuting money laundering activities in the country.

    Originality/value The paper documents and analyzes the actual cases being investigated formoney laundering offences. It provides basis for the standard setters to evaluate their effort to curbmoney laundering activities in Malaysia.

    Keywords Money laundering, Investigation, Prosecution, Bank Negara Malaysia,Anti-Money Laundering Act 2001, Malaysia

    Paper type Research paper

    IntroductionMoney laundering is a financial crime that generates increasing global concerns in thismodern age. The crime, commonly known as a crime of concealment, usually involves largesums of illegal money being mobilized in many economies through the financial system. Upto 2010, there are about 94 money laundering cases prosecuted at various stages involvingproceeds amounting to RM1.2 billion (Malaysian Insider, 2010). The increasing number ofmoney laundering activities in Malaysia was partly contributed by loopholes in the existinglaw and lack of knowledge of the relevant legal institutions in combating money laundering(The Star, 2009)[1]. Developed countries such as the USA and Australia have raised

    The current issue and full text archive of this journal is available at

    www.emeraldinsight.com/1368-5201.htm

    This study has been made possible with funding from UKM grant UKM-DIMP-003-2011.

    Moneylaundering cases

    in Malaysia

    421

    Journal of Money Laundering ControlVol. 15 No. 4, 2012

    pp. 421-429q Emerald Group Publishing Limited

    1368-5201DOI 10.1108/13685201211266006

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  • concerns over the failure of some developing countries to introduce good governance onfinancial institutions and such weaknesses allowed launderers to use them as safe haven.Political pressure from developed countries and international bodies to combat launderingactivities had led to the enactment of Anti-Money Laundering Act by Parliament in 2001 inMalaysia. In 2003, the Act was revised and renamed as Anti-Money Laundering andAnti-Terrorism Financing Act 2001. Since the passing of the Act, only a small number ofcases have been successfully convicted. The aim of this research is to analyze moneylaundering cases investigated by the BNM, a leading agency in prosecuting moneylaundering cases in Malaysia for the period of 2007-2011. Findings from this research revealthe details on the cases investigated by enforcement agencies in Malaysia to curb moneylaundering activities in the country.

    What is money launderingThe Financial Action Task Force (FATF) of the Organization for Economic Cooperationand Development (OECD) defines money laundering as [. . .] the processing of criminalproceeds to disguise their illegal origin. The UN described money laundering as:

    [. . .] activities linked with the conversion or transfer of property, or the concealment of thedisguise of the true nature of property, knowing that this property is derived from drugtrafficking.

    In layman words, money laundering refers to the process of legalizing ill-gotten gainwithout jeopardizing or revealing the sources. The process employs various methods,from financial to accounting, legal and other available instruments to clean themoney derived from or associated with unlawful activity.

    Money launderer uses three stages in laundering activities namely, placement,layering and integration. At placement stage, the illegal money will be deposited in thefinancial system. The money will be changed into a less suspicious form. For example, inbanking institution, at the placement stage, the illegal money is deposited in local orinternational financial institution in small amount to avoid from being suspected by thebanks employee. The second stage is the layering stage where the purpose is todisassociate the illegal money from its sources by moving the illicit money in the accountof bearer shell companies operating in countries that had flexible monetary regulations.At the integration stage, the money moved into the financial world and mixed with fundsof legitimate origin (Richards, 1999).

    Money laundering brings many negative impacts on the economic growth of acountry in particular and the global market at large (FATF, 2002). These includedestabilization of the economy and society; integrity of banking institution and diminishthe investment and growth of a country. There are many industries that are exposed tomoney laundering activities such as the banking institution, food industries, trading,insurance, investment, real estate and money changer.

    Review of prior studiesThe seriousness of money laundering crimes spark academic research in this area fromall parts of the globe covering the legal as well as the practical issues surroundingthe crime. Research on money laundering comprise studies on the regulation, offences,cases, preventive actions and recognizing trends of money laundering activities invarious countries. Malaysia has joined other countries in embarking in serious efforts to

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  • combat money laundering activities (Shanmugam et al., 2003). The effort starts with theenactment of AMLATFA 2001 under the purview several agencies and led by CentralBank of Malaysia (BNM). AMLATFA 2001 is the first act with multi agenciesenforcement in Malaysia (Shanmugam, 2004).

    Money laundering is claimed to be one of the biggest obstacles to an effectiveinternational financial system. The activities often involve a series of financialtransactions in various financial institutions across many different jurisdictions makingit difficult to prosecute in the court of law (Buchanan, 2004). The activities are oftenlinked to underground economies and organized crime. FATF estimated the size ofmoney laundering activities to be 2 per cent of global GDP. The percentage is estimatedto be higher for a developed country (Walter, 1990).

    Money laundering activities generate large profits (Walker, 1999) particularly in manycountries that have weak regulatory regimes. Many scholars suggest that the anti-moneylaundering regime in many countries is ineffective in combating organized crime andterrorism. Many claimed that the act is mere cover to achieve ulterior aims (Orlova, 2008).

    The typical methods of money laundering that have been discussed in the literatureinclude cash smuggling (Dupuis-Danon, 2006), money laundering through bankinginstitutions, insurance institutions, realty and lottery business, underground banks,international trade-based, through shell or front company, professionals such aslawyers or accountants, or through electronic money transfer. Money laundering casescan also be linked to fraud. For example, an insurance fraud may be linked to a moneylaundering scheme in which the criminal launder proceeds of crime in a life insurancepolicy with a single lump sum payment and subsequently redeemed the money(Thanasegaran and Shanmugam, 2008).

    Money laundering is a predicate based or derivative crime (Shehu, 2004). A predicateoffence is defined by UN Convention (2000) Art.6.2 (c) subsection (b) as:

    [. . .] offence committed both within and outside the jurisdiction of the state party in question.However, the offences committed outside the jurisdiction of a state party shall constitutepredicate offences only when the relevant conduct is a criminal offence under the domestic law ofthe state party implementing or applying this article had it been committed there (Shehu, 2004).

    Recent article by Murray (2011) suggests that the use of predicate offence as a means ofproving money laundering may not be adequate to combat money laundering activitiesconnected with organized crimes. He promotes the concept of irresistible inference fromcase law in the UK as an alternative means to prosecute the crime. The application of thisconcept however may require changes in legislations in many countries including Malaysia.

    The lawAMLATFA 2001 comes into force on March 6, 1997. The act consists of seven parts,namely, the offences of money laundering, investigation on money laundering activitiesand seizures and forfeitures of money laundering money. The preamble of the act statedthe purpose of the act was to provide for the offence of money laundering, measurement toprevent money laundering and terrorism financing offences and forfeiture of property.The act was designed to be in conformity with international treaties on money launderingparticularly the FATF 40 recommendations on money laundering and Ninth SpecialRecommendations on terrorism financing (Norhashimah, 2004). FATF is recognized asthe international setter for anti-money laundering activities.

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  • The government has set-up the National Coordination Committee (NCC) in its effort tobattle against money launderer. NCC consists of 13 ministries and government agencieswill become the platform for national anti-money laundering strategy and policies inMalaysia (Shanmugam et al., 2003). These agencies have locus standi to enforce criminallaws against money laundering and terrorism financing. The agency includes BankNegara Malaysia; Anti-Corruption Commission (MACC), Ministry of Domestic Trade,Cooperatives and Consumer Affairs (the ministry); Royal Malaysia Police (PDRM);Royal Customs Malaysia; Local Authority Ministry of Finance Malaysia;Communications and Multimedia Commission (MCMC) and various other agencies.Through NCC, these agencies with different jurisdictions will co-ordinate to ensure itseffectiveness in combating money launderer.

    AMLATF 2001 covers a wide scope on the offence of money laundering by referringto the act of:

    the act of a person who (a) engages, directly or indirectly, in a transaction that involves proceeds of any unlawful

    activity;(b) acquires, receives, possesses, disguises, transfers, converts, exchanges,

    carries, disposes, uses, removes from or brings into Malaysia proceeds of any unlawful activity; or(c) conceals, disguises or impedes the establishment of the true nature, origin, location,

    movement, disposition, title of, rights with respect to, or ownership of, proceeds of any unlawfulactivity,

    where (aa) as may be inferred from objective factual circumstance, the person knows or has reason to

    believe, that the property is proceeds from any unlawful activity; or(bb) in respect of the conduct of a natural person, the person without reasonable excuse fails to

    take reasonable steps to ascertain whether or not the property is proceeds from any unlawfulactivity (S. 3 Interpretation AMLATFA 2001).

    Unlawful activity means any activity which relates, directly or indirectly, to any seriousoffence or any foreign serious offence (S. 3 Interpretation AMLATFA 2001).

    Proceeds of unlawful activity means any property derived or obtained, directly orindirectly, by any person as a result of any lawful activity (S. 3 InterpretationAMLATFA 2001).

    The unlawful activities that fell within the scope of money laundering act are listed inthe Second Schedule of the act. The act has listed 121 money laundering offences whichinclude human trafficking, betting, drugs, terrorism, anti-corruption and copyrightinfringement. Section 4 of AMLATFA give the court power to imposed fine not exceedingRM 5 million or imprisonment not exceeding five years or both to those who found guiltyof committing money laundering offences. The Second Schedule list is not meant to beexhaustive and will be revised from time to time. This latest amendment made to SecondSchedule is on May 3, 2011 where the government has gazette Anti-Money Launderingand Anti-Terrorism Financing (Amendment of Second Schedule) Order 2011 to includeKootu Funds (Prohibited) Act 1971 in the list.

    AMLATFA 2001 also covers those who, directly or indirectly, assist or knows to be aparty in a transaction that involves proceeds of unlawful activities. The act covers notonly the wrongdoer but also their associates, advisers, accomplices and anyone who isinvolved in the activities. These associates may include bankers, brokers, real estateagent, chartered accountant, etc. What need to be proved, the associate or the advisor

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  • in question knowingly assisted or involved in the process. The term knowinglyconnotes that the accused must have knowledge of the fact that the money derived fromunlawful activity. In any criminal cases the existence of mens rea (criminal intention) hasto be proven before the accused is found guilty[2]. The needs to prove mens rea in moneylaundering cases have been a challenging factor to the prosecution officer in Malaysia[3].AMLATFA 2001 gives the power to the prosecutor to charge launderer under bothcriminal actions and civil actions.

    The investigationSection 44 of the act gives the enforcement agency the power to apply to the court to issuea freeze order against a financial institution if there is reasonable ground to believe thatmoney laundering offences has been committed. The purpose is to facilitate investigationand to secure and preserve the evidence in relation to the commission of the offence.The court refused to accept the argument that section 44 of AMLATFA violated Article 8(1)of the Federal Constitution. In the case of Khor Peng Chai And 12 Ors v. Bank NegaraMalaysia And Anor [2010], 11 of the applicants were involved in trading business betweenMalaysia and China. The first respondent has reasonable ground to believe that applicantshave committed an offence under subsection 4(1) of AMLA, issued an order to freezethe applicants banks account pursuant to section 44 of AMLA. The applicants claimed thesaid act was unconstitutional as it allowed freezing orders to be issued without noticeto the persons concerned and thereby violated the provision of the Federal Constitution thatall persons are equal before the law. The appellants sought leave for judicial review onsection 44 but were rejected by the court. Judge Mohd Zawawi held that the order was not anadministrative decision which could be reviewed within the ambit of a judicial review[4]. Hefurther stated that the purpose of section 44 is to provide avenue for the prosecution to secureand to preserve the evidence in relation to the commission of money laundering offences.The court refused to revoke the order for fear of dissipation of the money in the bank.

    The act allows seizure of money laundering asset by virtue of section 45-50 ofAMLATFA 2001. Seizure of illicit property includes property held by financialinstitutions. Section 50(2) protects the financial institution and its employee against anycriminal or civil action as a result of complying with the seizure order.

    Forfeiture of money laundering property is discussed under section 56-64 ofAMLATFA forfeiture of property under the act can be divided into two namelyforfeiture of property upon prosecution and forfeiture of properties where there is noprosecution. The section allows the prosecution to forfeit the illegal property althoughno criminal charges had been made against the accused within 12 months of the date ofthe freeze or seizure order for a forfeiture order, even if the accused was not prosecuted.Since drugs offence is one of the predicate offences in Second Schedule, cases discussedunder the Dangerous Drugs (Special Preventive Measures) Act 1988 can be apply andused as an analogy when discussing the issue of forfeiture under AMLATFA 2011.(Norhashimah, 2002). In the case of Kanagasavey a/l Sinayah v. Public Prosecutor[1995] 2 MLJ 239, the appellant was arrested under the Drugs (Special PreventiveMeasures) Act 1988. He was then released without charge. The appellant applied forthe return of RM7, 500 in two account which has been forfeited under section 32 of thesaid act. The court uphold the forfeited on the ground that the appellant failed to provethat the fund was not proceed of illegal drug activities. Over who has the onus of proof,it is illustrated in the case of PP v. Tan Lee Kok [1988] 2 MLJ 65:

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  • [. . .] the law does not place the burden on the Public Prosecutor to satisfy the court that theseizure was proper, or that the property ought to be forfeited; on the contrary the law placesthe burden on the person who made the claim to answer the summons. Section 32(3) placesthe burden upon the person making claim upon proof that he is lawfully entitled thereto.Section 32, therefore, places no burden on the Public Prosecutor to prove anything.

    The provision of AMLATFA allows the public prosecutor to apply to the court for anorder of forfeiture of property which they are satisfied has been obtained under subsection4(1) or terrorism financing offence although there is no prosecution or conviction underthat said subsection 4(1). The court in deciding the case will apply the standard of proof incivil proceeding (section 56(4) AMLATFA). The process of forfeited illegal proceeds fornon conviction cases were brought under the civil action. The civil forfeiture has beenintroduced in many countries such as the USA, UK, South Africa and Australia. In civilforfeiture, the action is brought against the property (in rem) and not against a person(in personam). In civil forfeiture, it allows the government to recover the proceeds of crimewhether there is a criminal prosecution against the wrongdoer or not (section 56AMLATFA). The onus of proof in civil law action is not as high as the criminal standard.The test of balance of probabilities needs to be established before the court ordered theproperty be forfeited to the Federal Government. (section 58 AMLATFA). Civil forfeitureis necessary in cases, inter alia, where the wrongdoer has died, where the forfeiture isuncontested by the accused or a third party and where the property belongs to a thirdparty (Cassella, 2007). In its annual report in 2009, the Attorney Generals Chambers ofMalaysia has successfully completed 15 cases including civil forfeiture cases where theamount of monies forfeited was RM 14.5 millions.

    Research methodologyThis study analyzes BNM public releases for period 2007-2011. The data relate to casesinvestigated for commercial fraud obtained from the BNM web site under the enforcementsection. Analysis of data is carried out on the four sections of enforcement releasedocuments namely the criminal prosecution, civil actions, administrative actions and acescompounded. Descriptive statistics for each section are prepared as follows:

    . The predicate offence for cases investigated.

    . The perpetrators this analysis is on the characteristic of perpetrators that isthe person/people or organization that has been charged.

    . Current status of the cases.

    Cases investigated by BNMThis study analyses cases investigated by BNM under AMLATFA 2001. A total of26 cases were listed on BNMs web site. All of the cases are local companies whereindividuals linked to the companies are charged with the money laundering activities.The investigation of these cases commenced in the period of between 2007-2011.The statistics of these cases are given below.

    Predicate offencesThe list of predicate offences prosecuted in money laundering cases investigated byBNM is given in Table I. As shown in the table, almost all of the cases investigated byBNM have section 25(1) of BAFIA as their predicate offence and are charged under

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  • section 4(1) of AMLATFA 2001. Some cases have more than one other offence under adifferent Act. The other Acts that are relevant in money laundering cases handled byBNM include Capital Market and Services Act 2007, Companies Act 1965, ExchangeControl Act 1953 and the Penal Code. The cases with a Penal Code involving theftor cheating as a predicate offence are passed over to the PDRM before they broughtto court. Out of the total 26 cases investigated, only one case is reported to be onsection 61(2) of AMLATFA 2001 which is related to third party claim on forfeited assets.

    Individuals or entities chargedThe analysis reveals that company directors represent the most number of individuals(28 individuals) charged followed by employees (five individuals) includingsenior officers and partners or shareholders (two individuals). In total, together withindividuals, six companies and one non profit organizations were charged for moneylaundering crimes (Table II).

    Current status of reported casesThe reported cases are in various stages of investigations. Investigations by BNMstarted with raids to companies suspected of the engaging in illegal activities followingcomplaints from the public. At this stage, the relevant assets and documents are seizedto facilitate investigations. Of the cases listed, three cases found in 2010 are still underinvestigation. 15 cases have been charged with 12 cases in pending hearing bythe court. One case results in discharge not amounting to acquittal on the ground thatall the accused have absconded. In one case the company has pleaded guilty whileanother case was closed when the accused paid compound. Suspects went missing hasmade one case not brought to court. No charges were made to the case involvingsection 61(2) AMLATFA for third party claims on seized assets before being forfeited.The criminal sessions court in Seremban Negeri Sembilan has agreed to hear this case(Table III).

    Predicate offence AMLATFA 2001 Number of companies

    Section 25(1) Banking and Financial InstitutionAct 1989

    Section 4 (1) 21

    Section 212(2) Capital Market and Services Act 2007 Section 4 (1) 1Section 366(3) Companies Act 1965 Section 4 (1) 1Section 4 Exchange Control Act 1953 Section 4 (1) 6Penal code Section 4 (1) 3Not applicable Section 61 (2) 1

    Table I.Statistics on predicateoffence charged with

    AMLATFA 2001

    Director of companies 28Employee 5Partner/shareholder 2Operator 1Company 6Non profit organization 1Total 43

    Table II.Number of charges made

    on the cases

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  • ConclusionMoney laundering is a serious offence as it is often linked to underground economy andorganized crime. Malaysia has taken a major step in curbing the activity by enactingAMLATFA 2001. Since money laundering involves the transfer of money and financialinstitutions are the main channel for money transfer, BNM has a major role to ensure thatAMLATFA 2001 is effective to curb these illegal activities. This paper analyzes thecases reported in BNM web site as cases investigated to gain understanding on trends inmoney laundering investigations. Findings reveal that most cases investigated by BNMare related to section 4(1) of AMLATFA 2001 and the predicate offence related to themoney laundering charges relate to illegal deposit taking. Further it is found thatdirectors of companies are the leading group of people charged under the act for moneylaundering. It appears that BNM is facing problems in getting evidence to chargelaunderers because only half of the reported cases have been charged in court.

    Notes

    1. The Star, April 25, 2009.

    2. Public Prosecutor v. Lim Ah Kew (unreported). The court has acquitted the accused sincethe Public Prosecution had failed to establish the mens rae.

    3. Extract from an interview with Tuan Zulkifli Ahmad, Ketua Unit Pendakwaan,AG, Putrajaya, on May 18, 2009.

    4. See Gilligan v. Criminal Assets Bureau.

    References

    Buchanan, B. (2004), Money laundering a global obstacle, Research in International Businessand Finance, Vol. 18 No. 1, pp. 115-27.

    Cassella, S.D. (2007), The case for civil forfeiture: why in rem proceedings are an essential tool forrecovering the proceeds of crime, paper presented at the 25th Cambridge InternationalSymposium on Economic Crime, available at: http://works.bepress.com/stefan_cassella/20.pdf

    Dupuis-Danon, M.-C. (2006), Finance Criminelle: Comment Le Crime Organise Blanchit lArgentSale, China Encyclopedia Publishing House, Beijing.

    Financial Action Task Force on Money Laundering (2002), 2001-2002 Report on MoneyLaundering Typologies, AFT Secretariat, OECD, Paris.

    Malaysian Insider (2010), Almost 100 money laundering cases being prosecuted, Kuala Lumpur,July 19, available at: www.themalaysianinsider.com/malaysia (accessed July 2011).

    Seized of relevant assets and documents 3

    Charged in court 12

    Discharged not amounting to acquittal 1

    Pleaded guilty 1

    Case closed compound 1

    Suspects missing 1

    Cases handed over to PDRM 2

    Ongoing court case for third party claim 1

    No status update after investigation started 4

    Total 26

    Table III.Statistics on currentstatus of cases

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  • Murray, K. (2011), The use of irresistible inference, Journal of Money laundering Control, Vol. 14No. 1, pp. 7-15.

    Norhashimah, M.Y. (2002), An examination of the Malaysia Anti-Money Laundering Act 2001,Current Law Journal, Vol. 6, pp. i-xxv.

    Norhashimah, M.Y. (2004), Precedents relating to money laundering, Current Law Journal,Vol. 3, pp. i-xiv.

    Orlova, A.V. (2008), Russias anti-money laundering regime: law enforcement tool or instrumentof domestic control?, Journal of Money laundering Control, Vol. 11 No. 3, pp. 210-33.

    Richards, J.R. (1999), Transnational Criminal Organization, Cybercrime and Money Laundering: AHandbook for Law Enforcement Officers, Auditors and Financial Investigation, Boca Raton, FL.

    Shanmugam, B. (2004), Hawala and money laundering: a Malaysian perspective, Journal ofMoney Laundering Control, Vol. 8 No. 1, pp. 37-47.

    Shanmugam, B., Nair, M. and Suganthi, R. (2003), Money laundering in Malaysia, Journal ofMoney Laundering Control, Vol. 6 No. 4, pp. 373-8.

    Shehu, A.Y. (2004), Should gambling be a predicate for money laundering?, Journal of MoneyLaundering Control, Vol. 7 No. 3, pp. 254-60.

    Thanasegaran, H. and Shanmugam, B. (2008), Exploitation of the insurance industry for moneylaundering: the Malaysian perspective, Journal of Money Laundering Control, Vol. 11No. 2, pp. 135-45.

    Walker, J. (1999), How big is global money laundering?, Journal of Money Laundering Control,Vol. 3 No. 1, pp. 25-37.

    Walter, I. (1990), The Secret Money Market: Inside the Dark World of Tax Evasion, Financial Fraud,Insider Trading, Money Laundering and Capital Flight, Harper Business, New York, NY.

    Further reading

    Bell, R.E. (2002), Abolishing the concept of predicate offence, Journal of Money LaunderingControl, Vol. 6 No. 2, pp. 137-40.

    Ferwerda, J. (2009), The economics of crime and money laundering: does anti money launderingreduce crime?, Review of Law & Economics, Vol. 5 No. 2 (Article 5).

    Gill, M. and Taylor, G. (2004), Preventing money laundering or obstructing business?, BritishJournal of Criminology, Vol. 44, pp. 582-94.

    He, P. (2010), A typological study on money laundering, Journal of Money Laundering Control,Vol. 13 No. 1, pp. 15-32.

    Liao, J. and Acharya, A. (2011), Transshipment and trade-based money laundering, Journal ofMoney Laundering Control, Vol. 14 No. 1, pp. 79-92.

    Silverstone, H. and Sheetz, M. (2007), Forensic Accounting and Fraud Investigation for NonExperts, 2nd ed., Wiley, Hoboken, NJ.

    Sproat, P. (2009), To what extent is the UKs anti money laundering and asset recovery regime usedagainst organised crime, Journal of Money Laundering Control, Vol. 12 No. 2, pp. 134-50.

    Corresponding authorZakiah Muhammaddun Mohamed can be contacted at: [email protected]

    To purchase reprints of this article please e-mail: [email protected] visit our web site for further details: www.emeraldinsight.com/reprints

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  • This article has been cited by:

    1. Wee Ching Pok, Normah Omar, Milind Sathye. 2014. An Evaluation of the Effectiveness of Anti-money Laundering and Anti-terrorism Financing Legislation: Perceptions of Bank Compliance Officersin Malaysia. Australian Accounting Review 24:10.1111/auar.2014.24.issue-4, 394-401. [CrossRef]

    2. Zaiton Hamin, Wan Rosalili Wan Rosli, Normah Omar, Awang Armadajaya Pengiran Awang Mahmud.2014. Configuring criminal proceeds in money laundering cases in the UK. Journal of Money LaunderingControl 17:4, 374-384. [Abstract] [Full Text] [PDF]

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