This week's scandal in Ghana illustrates a little-known aspect of the global money laundering pipelines employed by Colombian narcotics traffickers: proceeds of crime being repatriated from and through West Africa to Colombia. Compliance officers in Western Europe and North America rarely focus on identifying and interdicting drug profits that come from obscure non-drug producing countries, but that is how laundrymen operate. You choose an obscure or isolated location largely for that reason, provided that geopolitical factors are favourable for a successful operation.

Ghana is an established destination for Colombian cocaine destined for Europe and North America. Its special relationship with the United Kingdom, due to its former colonial status as the Gold Coast, facilitates potential use of the UK both as a portal to bring narcotics into the EU, and a pipeline to export criminal proceeds outbound, disguised as trade profits. It is not known as a money laundering centre, due in large part to the lack of a well developed financial infrastructure that limits the utility of the country for that purpose.

The case under study involved a fugitive Colombian drug kingpin alleged to have earned $46m in profits; a search of his residence by Ghanian law enforcement yielded 588 kilograms of cocaine. A scandal is emerging due to reports that $34m is being quietly repatriated to Colombia by associates of the trafficker, some of whom are reputed to be corrupt government officials.

Money laundering reporting officers and compliance officers, particularly those located in the UK and the US, should be alert for: 

• Large wire transfers from West Africa to European banks, purporting to be payments for shipments of goods, to newly-formed companies with no prior business activity.

• Transfers from African financial institutions to companies located in Spain, with further instructions for transfer to Latin American destinations, such as Panama, Venezuela or Colombia.

• Cheques from African branches of European banks to payee companies having no prior business relationship, and who immediately upon clearance, wire the funds to a Caribbean tax haven bank.

• Large amounts of shipment of currency from an African money service business, in dollars, sterling or euros, when the MSBs prior business was minimal or nonexistent.

Remember, laundrymen utilise imaginative permutations and combinations in their illicit trransactions, sometimes only slightly tweaking the scheme, to make it appear different. Pay close attention to unsual transactions originating in Africa. Perhaps you can interdict some of that missing $34m, as it passes through London or New York or Miami.