DIFFERENT ANGLE by Kenneth Rijock
Financial crime observers disagree on exactly where the estimated $30m taken as ransom payments by Somali pirates has gone. Some have been quoted as claiming that the pirate leaders are using their ill-gotten gains inside Somalia, and spending it all there, where governmental influence and control is non-existent but still others claim that some of the funds are being laundered through Kenya. This is important to anyone in compliance operating a risk-based AML programme. Where is the money going?
It is suggested that, until some reliable law enforcement agency can conclusively prove where the piracy proceeds are going, that one must raise the level of risk for Kenya.
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* INSCR, Volume II, at P. 290
http://www.state.gov/documents/organization/102588.pdf
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