Pepo Ghana Ltd operated three accounts at the Arena branch of Coin Bank Ltd. On 27 May 2020, the Financial Intelligence Centre (FIC) in a letter, directed Coin Bank Ltd to freeze all the accounts of Pepo Ghana Ltd.

i) Explain money laundering and explain TWO (2) stages of money laundering. (6 marks)

ii) List TWO (2) anti-corruption institutions in Ghana.

(4 marks)

i) Money Laundering is the act of transferring illegally obtained money through legitimate people or accounts so that its original source cannot be traced. The offence of money laundering is established if the person knows or ought to have known that a particular property is or forms part of the proceeds of an unlawful activity and the person:

  • Converts, conceals, disguises or transfers the property,
  • Conceals or disguises the unlawful origin of the property, or
  • Acquires, uses or takes possession of the property.

It is also a crime to aid and abet money laundering activities where a person, knowing that another person has obtained proceeds from an unlawful activity, assists them.

Stages of Anti-Money Laundering:

  1. Placement: This is the first stage in money laundering. At this stage, ‘dirty’ money is placed into the legal financial systems. The movement of cash from its source and placing it in circulation through financial institutions, casinos, businesses, disguised shops, forex bureaus, transfers both locally and abroad, etc.
  2. Layering: This is meant to make the trailing of illegal proceeds difficult for the law enforcement agencies, making it difficult to detect and uncover laundering activity. This involves creating a complex web of transactions to obscure the audit trail and conceal the original source and ownership of the illegal funds.
  3. Integration: This is the movement of previously laundered money into the economy, mainly through the banking system, thus legitimizing it. The money is now absorbed into the economy. Once the money has been placed and layered, the funds will be integrated back into the legitimate financial system as legal tender.

(6 marks)

ii) Anti-Corruption Institutions in Ghana:

  • Economic and Organized Crimes Office (EOCO)
  • Financial Intelligence Centre (FIC)
  • Securities and Exchange Commission (SEC)
  • Internal Audit Agency (IAA)
  • Public Procurement Authority (PPA)
  • Office of the Special Prosecutor
  • Commission for Human Rights and Administrative Justice (CHRAJ)

(Any 2 points @ 2 marks each = 4 marks)