October 9 saw our GI-ACE project’s first workshop, held in the illustrious surroundings of Oxford’s Martin School. The workshop gathered together our research team, along with the project’s advisors and around twenty hand-picked experts from the worlds of journalism, civil society, politics, law enforcement, academia and risk management, all with their own unique perspective on the fight against corruption. Our aim was to lay out the research that has been done so far in 2019, and to ask for our experts’ advice on future lines of enquiry. Our project (“Testing and evidencing compliance with beneficial ownership checks: investigating the laundering of monies and reputations by elites from African and Central Asian kleptocracies”) aims to look at possible enabling or complicit practices regarding money-laundering in three different but related areas – banking, real estate and reputation management.
Over the summer we sent out the first 7,000 of 48,000 total email solicitations (a major undertaking!) to banks from a series of specially created shell companies that we have registered in a variety of jurisdictions. Some of the locations are hot spots for money laundering, which should raise red flags for anti-money laundering (AML) compliance teams at the banks. Our aim is to calculate the number of positive responses we get from the banks despite these red flags, in order to assess the level of compliance in financial institutions located in various countries.
Our real estate strand began with the compilation of a database using publicly available sources of real estate purchased by Central Asian and African politically-exposed people (PEPs). From this we hope to create a possible typology of enabling and complicit practices by real estate agents and conveyancing solicitors. One potential roadblock here is the fact that the filing of Suspicious Activity Reports (SARs) to the UK’s National Crime Agency – which is required by law in regulated sectors such as real estate when an individual knows or suspects that money is being laundered – is confidential, and so we will be unable to ascertain in how many of the database examples (over 60 so far) led to concerns being flagged via the SAR system. However, research conducted over the summer suggests that real estate agents and solicitors are not filing enough SARs when suspicion exists, because of either a lack of knowledge of the law (which appears to be more common with real estate agents) and/or a lack of supervision and enforcement of the law in regulated sectors, which has resulted in very few prosecutions of individuals for a failure to report money-laundering concerns. The next stage of this strand of research aims to ‘fill in the blanks’ in our database through the conducting of interviews with industry professionals to get their insights into enabling practices, possible loopholes and other issues with the Money Laundering Regulations.
The workshop’s section on reputation management focused on examples of the type of practices associated with individuals looking to ‘launder’ their reputation – the gifting of charitable donations, the commissioning of ‘puff pieces’ in the media, and the supressing of negative commentary through the use of high-powered law firms who try to prevent publication with ‘Cease & Desist’ letters. This element of the research may prove to be the trickiest to quantify, because of the range of behaviours and tactics that can be employed, many of which fall on a distinctly grey spectrum which, though arguably unethical, are not illegal. Our workshop’s participants aided our understanding of this area by giving some concrete examples that they themselves had experienced, and by suggesting ways we could research the topic in a quantitative fashion. The coming months will see the remaining email solicitations being sent out, the conducting of the interviews to allow us insight into the world of high-end real estate, and a mapping out of possible avenues into the world of reputation management, which may also include an analysis of university funding. We would like to thank our participants, especially those who travelled to Oxford from Africa and Central Asia, for their valuable contributions. We hope to convene a smaller workshop of journalists in 2020 in order to further assess the element of reputation management through the silencing of critical voices.
Full list of workshop attendees and affiliations
|Name||Affiliation||Relation to project|
|John Heathershaw||University of Exeter||Project lead|
|Alex Cooley||Columbia University / Barnard College||Team member|
|David Lewis||University of Exeter||Team member|
|Ricardo Soares de Oliveira||University of Oxford||Team member|
|Jason Sharman||University of Cambridge||Team member|
|Tom Mayne||University of Exeter||Research Fellow|
|David Mora||Columbia University||Research Fellow|
|Tena Prelec||University of Oxford||Research Fellow|
|Jon Benton||Intelligent Sanctuary||Advisor|
|Ana Gomes||Former Member of the European Parliament||Advisor|
|Kate Mallinson||Chatham House||Advisor|
|Alisher Ilkhamov||Open Society Foundation||Advisor|
|Kemel Toktomushev||University of Central Asia||Advisor|
|Wale Adebanwi||University of Oxford||External|
|Olga Binnions||Independent Researcher||External|
|Dan Haberly||University of Sussex||External|
|Edmund Herzig||University of Oxford||External|
|Irna Hofman||University of Oxford||External|
|Jody LaPorte||University of Oxford||External|
|Ava Lee||Global Witness||External|
|Richard Murphy||City University||External|
|James Nixey||Chatham House||External|
|Matthew Page||Chatham House||External|
|Ronen Palan||City University||External|
|Louise Russell-Prywata||Open Ownership||External|
|Troy Sternberg||University of Oxford||External|
|Shayakhmet Tokubayev||University of Exeter||External|