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Money laundering and terrorist financing through the real estate sector

The FATF recently issues its typologies report on the real estate sector. This first FATF in-depth study of the sector examines its vulnerabilities to misuse for money laundering and terrorist financing.

The FATF provides an interesting list of red flags (pages 34-37). Unfortunately these experts do not take into consideration red flags relating to the management or the audit firm of a real estate company, that are visible especially in Luxembourg the small country where everydoby knows everyone and that is self regulated:

- Knowingly appointing a dishonest managing director (recent judiciary sources) that definitely do not comply with the requirement of professional standing,
- having a "commissaire" (auditor) that is neither member of the charered accountants nor of the chartered auditors : in Luxembourg anyone may be auditor.
- having a "commissaire" that is audited by an auditor in a far tax haven (for instance a company located in Luxembourg audited by a company located in the BVI...)
- ...

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