Irish Police: Reported Money Laundering Crimes in Ireland More Than Doubled Since 2019

Over the past five years, Ireland has shown that it is dedicated to combating money laundering and terrorist financing.  On the Basel Institute of Governance’s AML Index, Ireland is ranked 106, which compares favorably with the United States (100) and the United Kingdom (116).  As a European Union Member State, it has transposed EU anti-money laundering (AML) directives into national law, most recently in the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021, which was just signed into law.  In addition, on April 19 the Irish Minister of Justice, Helen McEntee, issued a 22-point cross-government plan to address economic crime and corruption that would include capacity-building to combat money laundering and other economic crime.

A recent Irish Times article, however, contains several indications of the challenges that Ireland continues to face in rooting out money laundering.  According to information from An Garda Síochána (Garda), the Irish national police force:

  • The number of money laundering crimes recorded in Ireland in 2020 (524) more than doubled from 2019 (234), and increase more than 630 percent from 2018 (83).   Police believe that some of that increase “related to drug gangs being forced to pursue higher-risk money-laundering strategies because the cash businesses they usually run cash through were closed or operating with reduced cashflows due to the Covid-19 pandemic.”
  • In 2020, Dutch banks filed with the Garda and Irish Revenue Commissioners 28,865 suspicious transaction reports (STRs), which often relate to money laundering — an increase of 13 percent over the total STR filed in 2019s.
  • These trends “reflect the changing face of crime in Ireland, more of which is taking place online, and a culture shift in policing with extra resources being dedicated to white-collar and cyber crime.”  The Garda also reported “a significant surge in cyber frauds, which are often based on scam emails and texts being sent to unsuspecting victims.”

In addition, Garda detectives said that “there was now a major focus on investigating money-laundering by drug dealers and organised crime gangs in addition to their more traditional activities.”

These developments strongly indicate that the Government’s 22-point plan needs to be implemented in ways that provide the Garda’s National Economic Crime Bureau and the Dutch Office of the Director of Public Prosecutions with appropriate resources and training dedicated to money laundering investigation and prosecutions, as well as effective information-exchange mechanisms to facilitate information sharing between Dutch law enforcement and regulatory agencies for money laundering enforcement.  As money laundering organizations have become increasingly sophisticated and complex in their techniques, including trade-based money laundering and greater use of technology to facilitate international funds transfers, Irish authorities will need to keep pace if they are to identify and pursue such organizations successfully.

London School of Economics Received £350,000 in Cash from Students in 2015-2019

Since 2019, a series of media reports have highlighted the fact that universities in Canada and the United Kingdom have been willing to accept cash payments from ostensible students for student fees, despite the risk that accepting such payments could implicate those universities in possible money laundering activity.  In the United Kingdom’s case, an investigation by The Times found that at least 49 British universities let students use banknotes to pay £52 million in fees.

A new report yesterday by The Times disclosed that a leading United Kingdom university, the London School of Economics (LSE), accepted £350,000 in cash from students between 2015 and 2019 despite the risks of association with money laundering.  Although other United Kingdom universities accepted larger amounts of cash from students between 2015 and 2019 – notably Queen Mary University of London, which took in £7 million, and Teesside University, which took in £1.2 million – LSE had been the target of substantial criticism in 2011 when it accepted a £1.5 million donation from a son of the late Libyan dictator Muammar Qaddafi for training “future leaders” of the Libyan government.

An LSE spokesperson stated that “LSE stopped accepting cash as a form of payment for tuition from summer 2019,” and “has a robust ethics code and process for all potential grants and donations, which is kept under regular review.”  Nonetheless, Members of Parliament on the Education Select Committee reportedly called “for a complete ban on higher education institutions taking cash.”

In view of these continuing revelations, there is no point in any university, whether in the United Kingdom or elsewhere, continuing to allow students to pay cash for tuition or, for that matter, any university service other than de minimis cash purchases of meals or incidentals.  No college or university needs to take the risk of becoming a conduit for criminal proceeds, and it can only ease the compliance obligations of universities to refrain from accepting any amounts of cash that could be reportable under anti-money laundering regulations.