Corruption Investigations: Strategy, Stakeholders, and Evidence

This report provides a comprehensive analysis of a corruption investigation case, focusing on a mafia syndicate involved in drug trafficking and corruption. The report outlines a detailed strategy for advancing the investigation, including identifying the core issues and the complex nature of the syndicate's network, which spans across national borders. The report emphasizes the importance of identifying key stakeholders, including international investigation agencies, certified public accountants, and the UNODC. It also details the investigative strategy to be employed, including financial investigation and profiling techniques, such as analyzing customer identification and non-recurring economic transactions. Furthermore, the report stresses the critical importance of securing evidence, particularly through the analysis of financial trails and collaboration with financial institutions to detect suspicious transactions and money laundering activities. The report highlights the need for comprehensive, international cooperation and a multi-faceted approach to effectively combat the syndicate's illegal activities.

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Student’s Name
Professor’s Name
Course Name
Date

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Introduction
The case clearly reveals that the mafia group have formed drug and corruption syndicate
whereby it is easier for them to evade the law and carry out their illegal activities unsuspectedly.
Syndicate is often very complex. It means that the mafia group has wide network that spans to
other countries. This means that the investigation strategies should be very comprehensive and
should cut across national borders. In this paper, I will describe how I will advance the
investigation strategy. Among the things I will cover include identification of issue,
identification of important stakeholders to cooperate with, identification of the investigation
strategy, financial investigation and profiling and securing evidence.
Identifying the issue
In any investigative project of the syndicate nature, the success depends on how well the
issue is identified. From the case, it is clear that the mafia has formed a strong syndicate
involving even professionals and former police officers. This means that the syndicate is
supported by quality information on how to escape the law without being noticed. Issues such as
these are aggravated by the fact that dominated positions in drug trafficking are acquired by
organized criminal groups, the level of professionalism and unity of which is increasing every
year. Historically, this activity related to drug trafficking has always been organized: one group
of people sowed poppy seeds, the other harvested, the third processed, the fourth transported, and
the fifth sold drugs. However, in our opinion, it is impossible to identify such functionally
organized activities and organized crime in the drug business today. As revealed from the case,
organized crime is characterized by a complex management mechanism, universal specialization,
and the international scale of activity. There are many examples, it is enough to recall the largest
Colombian drug cartels6- Cali and Medellinsky. It is becoming increasingly difficult to single

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out certain areas in the structure of organized crime: organized crime in the economic sphere
associated with the illicit trafficking of drugs, weapons, etc. Nevertheless, drug trafficking
remains one of its most dangerous manifestations. Furthermore, as the case revealed, the
activities of criminal groups involved in the drug business are not limited to drug manipulations.
Including corruption, violence, money laundering, arms trafficking, and more, it goes beyond the
borders of one state. Criminal communities of various countries integrate with international drug
cartels.
Identifying important stakeholders to involves
Although the case shows that the country has Anti-Corruption Agency (ACA), there is
need to find out other stakeholders, which may include the investigation agencies from other
states. This is exactly what America, Italy, Russia, China and Columbia did in 1992. According
to the American Senator D. Kerry, along with the Italian mafia, Japanese yakuza, Chinese triads
and Colombian drug cartels, Russian groups are already part of the core of the new global
criminal organization formed by the five most powerful criminal communities in the world. And
the result of several meetings of leaders of Russian and Italian groups in the summer of 1992 was
the decision to form a strategic alliance with a clear distribution of roles: Italians are involved in
the acquisition and sale of drugs, while Russians provide security for transit routes and a trading
network in the CIS7. Consequently, in the current case, I will have to look for all possible
stakeholders from within and without the country. I will also consider companies as key
stakeholders. Specifically, I will use certified public accountants to get important information
regarding the movement of the funds used to facilitate the illegal activities. Foreign anti-money
laundering practices have proven that CPAs should submit reports of suspected money
laundering crimes. Although they have a duty of confidentiality, they are not restricted in

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safeguarding the legitimate rights and interests of society and reporting illegal crimes. According
to auditing standards, certified public accountants need to pay attention to suspicious transactions
of the audited unit, but the inherent flaws of auditing cannot find all illegal and illegal situations.
Another stakeholder is UNODC. The United Nations Office on Drugs and Crime (UNODC)
provides multilateral support to Member States to strengthen their capacity to prevent, detect,
investigate and prosecute corruption. UNODC also supports countries by developing and
coordinating the provision of anti-corruption technical assistance at the regional, national and
international levels. The Anti-Corruption Advisory Team is currently active in South and
Southeast Asia, most parts of Africa, as well as in the Caribbean and Central America, the
Pacific, the Middle East and small island developing States. Various anti-corruption programs
are also implemented by the UNODC field network. Over the past two years, UNODC has
implemented programs in Afghanistan, Brazil, Colombia, Egypt, Indonesia, Iraq, Libya, Nigeria,
Panama, Paraguay and Timor-Leste. Over the past two years, UNODC has supported 27
countries in improving their national anti-corruption legislation and in ensuring its compliance
with the UN Convention against Corruption. Strengthening national institutional and political
structures and the capacity of government officials to combat corruption is equally important.
Among other tasks, UNODC assists the training of investigators, auditors and magistrates in
establishing corruption in Mozambique. Training programs for investigating corruption, money
laundering and returning stolen funds are being developed in Panama. Professional training
courses for prosecutors and investigators during stage-play trials were organized in Botswana,
Tanzania and Uganda. Since 2007, UNODC has also been providing technical assistance as part
of its Global Anti-Corruption Trainers Program, whose main goal is to provide high-quality,
expert advice on a long-term basis. The program is being implemented through the appointment

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of UNODC anti-corruption experts to government agencies authorized to prevent and combat
corruption
Identifying investigative strategy to use
The success of my responsibilities would also be influenced by the quality of
investigative strategy I would adopt. Although the issue involves criminals from specific district,
the investigative strategy should be comprehensive so that it can identify sponsors and
facilitators from the other countries. The created international legal framework allows in a rather
effective way to counteract the illegal distribution of drugs within a single state, as well as
globally. Providing the states with wide opportunities to solve the problems of drug trafficking in
the process of cooperation, international legal norms, meanwhile, constantly require their
improvement and refinement. The significant potential of their use is far from being fully
realized in practice. One of the prerequisites necessary to achieve this goal is that the
international legal framework will be supplemented by the action of national legal means, which
will make it possible to counteract the illegal distribution of drugs in a sufficiently effective form
both within a single state and on a global scale. Legislation designed to regulate drug trafficking
should be amended and supplemented in order to meet the current situation. Addressing gaps in
legislation at the national level will deprive drug smugglers of the opportunity to evade
responsibility.
Financial investigation and profiling
With the help of CPAs of different financial investigation, I will be able to carry out
financial investigation and profile the suspects based on their risk appetite. Customer
identification consists of initial identification and continuous identification (corresponding to the

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first undertaking business and continuous audit business in the audit). Auditing standards
stipulate that when a certified public accountant undertakes business for the first time, he should
have an understanding of the shareholders of the audited entity and the actual controlling person,
consider the integrity of the client, analyze whether the client has any illegal activities, including
suspected money laundering, and communicate with the former accountant if necessary. Anti-
money laundering regulations stipulate that when a customer refuses to provide a valid identity
document, or the documents provided are verified to be false, the financial institution shall refuse
or suspend business for the customer. Taking corporate customers as an example, accountants
have a wider scope of identification than customers of financial institutions. Auditing standards
emphasize understanding of the possibility of misstatement of customers' financial statements
(you need to understand the macro environment, industry environment and micro environment of
the company, and analyze corporate executives. Factors such as their motivations, opportunities,
and pressures), the authenticity of the information required by the anti-money laundering rules
that financial institutions rely on (when providing financial services or account opening services,
they must retain and verify customer identity information that “proves that the customer has been
established and operated according to law”, (Such as business scope, registered capital). In
collaboration with CPAs. I will pay attention to non-recurring economic transactions and their
impact on annual financial conditions and operating results; pay attention to fictional transactions
or transactions that deviate from market prices and transactions with tax havens; pay attention to
cash and multiple funds Port business such as supermarkets; pay attention to economic business
between related parties, especially pay attention to unfair transactions at the cost of concessions
between related parties; evaluate whether the commercial reasons (or lack of commercial
reasons) of major unconventional transactions indicate that the audited unit is engaged in The

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purpose of the transaction is to make false reports on financial information or cover up the
situation of asset appropriation. To some extent, it can be inferred from corruption, smuggling
and tax-laundering crimes.
Financial investigation and profiling would form basis for my investigation because this
is the best way of detecting some money laundering crimes. Money laundering involves the
circulation of funds, which is reflected in the receipt and expenditure of funds in the course of
the company's economic turnover, and is also reflected in fraud in the handling of accounts.
Comparatively speaking, the CPA conducts audits in accordance with the Code of Practice and
the anti-money laundering methods provided by financial institutions for financial services.
Whether the client is suspected of money laundering, the CPA judges the authenticity,
legitimacy, and reasonableness of the accounting records, that is, the internal control test can
infer the risk of misstatement of financial statements; detailed testing in substantive testing
(appropriate audit procedures are sufficient) Falsified evidence, accounting confirmation and
measurement errors can be found; substantial analysis procedures can find that the transaction
price deviates from the market price, the operating scale does not match the enterprise size, and
the account balance or balance deviates from the industry's normal level. Financial institutions
judge the rationality of fund transactions, that is, by fetching data from the trading system, such
as the unit name (or name) and account number of the client's counterparty (foreign business
must provide the counterparty's bank), or access to cash The following situations were found to
be suspicious: the size of the transaction did not match the size of the company, the counterparty
did not match the scope of the business, the transaction method did not match the business
habits, and so on.

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When an enterprise has an off-book account, the shortcoming of the audit is that it cannot
find out all the capital accounts of the enterprise, and it is difficult to identify the authenticity of
the bill, but Can find out whether the business relationship of some capital transactions is true
and reasonable. The anti-money laundering functions of the two are complementary: transferring
funds through the financial system is an important channel for money laundering criminals.
During the disposition and isolation stages of money laundering (such as centralized transfer in
and decentralized transfer), financial institutions can take advantage of real-time fund
monitoring.
Securing evidence
The crucial and most important element of any corruption investigation is securing of
evidence. Without evidence, the investigation would be useless. The most probable source of
evidence would be the financial trails. In collaboration with financial institution, I will manually
monitor sufficient account activity to identify anomalous size, quantity, pattern or type of
transaction based on geographic factors such as jurisdictions designated as "non-cooperative" or
any "red flags" identified below. We will look at the transaction in the context of other account
activity, including deposits and wire transfers, to determine if the transaction lacks economic
significance or is suspicious, as this is an unusual transaction for this customer. The Anti-Money
Laundering Compliance Officer or his designee will oversee this, will record when and how it
will be done, and report suspicious activity to the appropriate authorities. The information we
will use to determine whether to submit a suspicious activity reports (SAR) is an anomaly report
that includes transaction size, location, type, number, and nature of activity.

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References
The Role of Financial Intelligence Units in Fighting Corruption and Asset Recovery.
https://egmontgroup.org/en/filedepot_download/1661/55
UNODC (2017). UNODC Technical Guide (Chapter III, Articles 15-42, Criminalization and
Law Enforcement),
https://www.unodc.org/documents/treaties/UNCAC/Publications/TechnicalGuide/
09-84395_Ebook.pdf
Study on paving the way for future policy initiatives in the field of fight against organised crime:
the effectiveness of specific criminal law measures targeting organised crime - Final report - Part
3: Legal and Investigative Tools,
http://ec.europa.eu/dgs/homeaffairs/elibrary/docs/20150312_1_amoc_report_020315_0_220_par
t_2_en.pdf
The Money Laundering Suppression Act of 1994, https://www.congress.gov/bill/103rd-
congress/house-bill/3235.
Money Laundering Control Act of 1986, available at https://www.congress.gov/bill/99th-
congress/house-bill/5077.
The Intelligence Reform & Terrorism Prevention Act of 2004, available at
https://www.gpo.gov/fdsys/pkg/PLAW-108publ458/pdf/PLAW-108publ458.pdf.
The Money Laundering and Financial Crimes Strategy Act of 1998,
https://www.congress.gov/bill/105th-congress/house-bill/1756.

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FATF (2008). Best Practices Paper Best Practices on Trade Based Money Laundering. Retrieved
from: https://www.fatf-gafi.org/media/fatf/documents/recommendations/BPP%20Trade
%20Based%20Money%20Laundering%202012%20COVER.pdf
Ivanov E. (2018). AML/CFT and anti-corruption compliance regulation: two parallel roads?
IACA Research Paper Series No. 2/2018:
http://iaca.int/images/Research/Research_paper_02_Eduard_Ivanov_final.pdf
OFAC (2019). Enforcement Information For October 1, 2019. Retrieved from:
https://www.treasury.gov/resource-center/sanctions/CivPen/Documents/20191001_ge.pdf
Ivanov E. (2019). Overview of anti-corruption compliance standards and guidelines. Practical
tool. IACA 2019.
https://www.iaca.int/images/Research/Overview_of_Compliance_Standards_and_Guidelines.pdf