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Loophole Masters: How Enablers Facilitate Illicit Financial Flows from Africa

For too long, professionals and businesses operating in the non-financial sector have escaped both public and regulatory scrutiny. Corrupt officials from around the world have taken advantage of this, employing lawyers, company formation agents, real estate agents and notaries at various stages of the process of hiding, laundering and investing their illicit gains. A lack of scrutiny has also meant that policy-makers have largely been unaware of the specific risks posed by these professionals and businesses.

We have undertaken an extensive review of publicly available evidence to better examine the role of such intermediaries in facilitating illicit financial flows out of Africa, producing the first study of this kind.

We collected and analysed 78 cases covering 33 African countries. These are cases which implicate politically exposed persons from across the continent in siphoning off proceeds of corruption abroad or parking their wealth offshore.

The report identifies patterns and trends in the case studies that illustrate the services provided, the type and location of the enablers. We also identify the key jurisdictions within and outside of Africa that play a significant role in facilitating illicit financial outflows from the continent.

Our analysis identifies specific enabling behaviours and high-risk services, while also revealing policy loopholes and regulatory blind spots that require decision-makers’ attention.

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