Corruption indicators
Since corruption often facilitates illegal land conversion and other financial crimes linked to land conversion, signs of corruption are also a good indicator of land conversion related risk in certain high-risk jurisdictions.
Corruption Red Flags
- Dubious trade and shipment documentation, including invoices and shipment documents, which could indicate the forging, modification or sale of key authorisations and their sign-off by corrupt customs officials.
- Customs officials displaying sudden, unexplained increases in wealth, such as new luxury vehicles, expensive homes, or other high-value purchases that do not align with their salary.
- Transactions and other account activities that are inconsistent with a client's usual business, commercial purpose or profile.
- Large cash or other deposits, wire transfers, multiple cash deposits and withdrawals associated with government officials (especially from environment, agriculture or other ministries who have specific management or oversight authority of government stockpiles of seized timber or other relevant commodities like minerals, and their associates or relatives), border control authorities, or customs and revenue officials, forestry agencies, or CITES Management Authorities (CMAs) and their associates or relatives.
- Unexplained cash transfers involving senior officials or PEPs (or their family members), especially if these individuals operate within the natural resources, mining, wildlife, land management, forestry, or agricultural spaces.
- Payments to customs officials, law enforcement, police, guards manning highway checkpoints, border guards, or government officials which may constitute bribes.
- A customer’s inability to produce appropriate documentation (e.g. invoice or any other document) to support a requested financial transaction, or the bank finds double invoicing, or a customer fails to provide adequate information about the originator, beneficiary, and purpose of the wire transfer.
- PEPs or public officials with responsibilities for environment management/protection or land/tenure rights traveling to offshore jurisdictions for undisclosed business activities.