BOX 3.8
(continued)
Payment records and entries in accounting records: • • • • • • • • •
Significant invoices or invoice amounts recorded in generic general ledger accounts, such as miscellaneous expenses or consulting Use of suspense or transitory accounts that eventually are written off as bad debt Payments processed outside of the normal accounts payable process (for example, one-off manual payments, cash payments) Failure to follow payment procedures (for example, obtaining one signature when two are required) Reluctance of company personnel to approve invoices for payment through normal channels, such as online or directly on the invoice Pressure from a third party or company personnel to process payment urgently Unusual interest by company personnel in the processing of payments to specific third parties Unusual responses or hostility from company personnel or third parties in response to a search for additional supporting documentation Payments to third parties for which risk management processes were not followed
Payment mechanisms by which funds are remitted from the company: • • •
Request for payments to be remitted through tax-haven jurisdictions Requests by employees to hand-deliver payment Requests to split payment across multiple company bank accounts and/or country offices • Requests by employees that payments be made in cash or cash equivalents • Requests by employees for purchase of high-value “gifts” (such as watches or jewelry)
found, it will be possible to filter the population of suspicious transactions and focus the investigation on the issuer of the fictitious invoice (the suspected bribe recipient). In the absence of more specific leads, attention should be paid to large, unusual, or oneoff items recorded under expenditure accounts—consultancy, commissions, entertainment, travel, and miscellaneous expenses. In addition, practitioners should consider account receivables that are not repaid and are written off as bad debts. 3.4.6 Insurance Policies Some life insurance policies may be of great value and may be purchased with a single downpayment, making them attractive to would-be money launderers. Practitioners should determine if the targets have cash-value insurance policies. In addition, 70
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Asset Recovery Handbook