3.5 Criminal finances online - Recommendations
- Countries should ensure that policy-makers, financial intelligence units, law enforcement authorities and other relevant competent authorities have mechanisms in place to facilitate cooperation and coordination concerning the development and implementation of money laundering policies .
- Legislative changes at EU level, or the uniform application of existing anti-money laundering regulations are required to address the criminal use of virtual currencies.
- Law enforcement should strengthen relationships with money transfer businesses to promote lawful assistance in the identification of suspicious transactions and suspects.
- Virtual currency scheme operators and exchangers should fall under the same regulatory framework as their non-virtual counterparts, providing protection for consumers and accountability on the part of the scheme provider. The absence of the central authority makes the enforcement more problematic for the decentralised cryptocurrencies while for certain schemes such as the private forum currencies, regulation will have no impact at all.
- Law enforcement should develop a working relationship with the financial sector including banks, money transfer agents, virtual currency scheme operators and exchangers in order to promote the lawful exchange of information and intelligence.
- Digital investigators need to be familiar with how virtual currencies operate and how to recognise the wide variety of digital accounts which may hold a suspect’s digital assets.
- Forensic teams must be aware of the nomenclature and file formats for digital currency wallets and accounts so that these can be identified and retrieved during analysis of a suspect’s device.
- Law enforcement should establish relationships with the major cryptocurrency exchanges and websites offering cryptocurrencies for sale, with a view to facilitating the exchange of relevant information and intelligence in a lawful manner.
- Law enforcement should work in conjunction with relevant public sector actors to initiate awareness campaigns targeting prospective money mules.
- Law enforcement should not cease investigative efforts after detecting the low level mules. It is important to follow the flow of money or goods upstream to other jurisdictions to map the criminal network.
- Law enforcement should proactively monitor job classified job advertisements for those that are suspicious. Increased activity of mule herders may indicate upcoming fraud operation.
