‘Safe Haven?’ Targeting the Proceeds of Foreign Corruption in Ireland
TI Ireland's ‘‘Safe Haven?’ Targeting the Proceeds of Foreign Corruption in Ireland’ report highlights the risk that the proceeds of international corruption are being laundered through Irish-based financial services and companies. Those risks include the use of Special Purpose Vehicles (SPVs) such as ‘Section 110 companies’ used to avoid tax on investments, as well as Ireland’s Immigrant Investor ‘Golden Visa’ Programme which allows wealthy non-EEA nationals to secure residency visas in return for at least €1 million investment in government approved schemes or a €500,000 donation to charity. TI Ireland also raised concerns about the potential use of new investment liability partnerships which do not currently have to file beneficial ownership details with the RBO.
The report notes that the Irish property market has substantially increased in value in recent years, which can promise a solid short-to-medium term investment for anyone looking to launder money. Although there is little evidence to suggest that Dublin has become a home for the world’s oligarchs in the same way as other major capitals, the report states the controls around the sector leave some room for concern, especially given the low level of anti-money laundering compliance by property service providers such as real estate agents. The risk that Irish company formation agents, lawyers and accountants are acting as ‘gatekeepers’ or ‘professional enablers’ on behalf of organised crime groups and corrupt individuals is highlighted as well. The report also deals with the mechanisms by which the proceeds of corruption is seized and repatriated to the victim country by the Irish authorities.
TI Ireland’s 18 recommendations to stem the tide of dirty money into the country, include the development of a national strategy against corruption and related money laundering offences; the establishment of a unified National Anti-Corruption Bureau and anti-money laundering supervisory authority for Designated Non-Financial Businesses and Professions (DNFBPs); as well as the prohibition of continued sale of dormant shelf companies in Ireland; and the requirement that legal persons acting as beneficiaries of life insurance policies become a heightened risk factor for relevant firms’ anti-money risk assessments. In the meantime, TI Ireland has called for additional resourcing of Ireland’s law enforcement and regulatory agencies including the Garda National Economic Crime Bureau.