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• direct access banking • suspense accounts • pass-through banking • representative offices of banks • money laundering through banking financial institutions in general Text3 A random reading of cases in the country analysis reveals that a new category of professional money laundering specialists is emerging. These professionals have been emerging in Belgium, the Netherlands and Portugal as white collar criminals acting as financial advisers both as individuals or as organisations like firms. In the United Kingdom they emerged mainly as solicitors. In Italy they are often members of the criminal organisation or very close to it, as a branch of the same, providing specific laundering services. They sell high quality services, contacts, experience and knowledge of money movements, supported by the latest electronic technology, especially in international financial centres such as Germany or the United Kingdom, to any trafficker or other criminal willing to pay their fees. In addition to buying into established companies, or creating shell corporations in out-of-the-way venues, and buying and trading commodities, purchasing equipment, and the like, the more sophisticated money managers put the traffickers' proceeds into a wide range of financial instruments. The possibilities offered by important international financial and stock exchange centres in the European Union comprise an endless variety of possibilities of diversification. They often manage funds for third parties beyond contracts such as fiduciary contracts, financial management, foundations, third party accounts and new typologies of contracts such as trust companies. Professionals number criminal organisations among their many clients, and make available to them the same mechanisms used by other clients to smuggle gold or to hide profits and shelter proceeds from the tax collector. In a variation on this procedure, some money brokers are buying cash in bulk, at a discount rate. The criminal organisations get their proceeds back from the point-of-sale countries without making the moves themselves. These professionals once acted as brokers, charging a commission for handling cash and other transactions; today, they increasingly buy the entire proceeds at a discount and control its disposition, reaping profits by investing in legal businesses. Organised crime is changing parallel to the way in which the laundering methods for proceeds of crimes are changing. These changes are effects of many factors, including also the policies enacted for combating organised crime. In just a few years an international anti-money laundering regime has been built upwind inside it a European network, composed of institutions, mechanisms, hard and soft norms, has been formed. The European Money-Laundering Directive of 1991 is the main instrument for future development in this network. Having a regulatory task, as addressed to the financial institutions, and an indirect one in supporting tougher crime control policies, the Directive contributes to the future challenge of combining more free circulation and competition in the European markets and, at the same time, less risk of infiltration of crime. Still, European countries have some difficulty in adopting harmonised anti-money laundering policies that could effectively combat this phenomenon.
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