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ONE-OFF TRANSACTION CHINA RISK AND Stringent local capital offshoring controls

09/02/2023

China is an example of a country that has significant constraints on its citizens investing or moving capital abroad. This has led to some people using alternative shadow banking networks to move wealth out of the country.

These networks usually have a dual purpose of cleaning illicit funds for criminals (while facilitating people to sidestep local capital controls), meaning that funds that pass through these networks will generally be the proceeds of crime, even if the client is not themselves a criminal. You may consider such networks as illegal money transfer businesses. Source of funds checks are very important where there is a risk that money has passed through one of these networks.

See here a link to the NCA's explanation of how this works in China. https://www.nationalcrimeagency.gov.uk/who-we-are/publications/445-chinese-underground-banking/file

 

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