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Money Laundering Research Related to Informal Value Transfer Systems
Informal Value Transfer Systems and Criminal Organizations; A Study Into So-Called
Underground Banking Networks
With increasing regulation of the conventional banking sector in the Netherlands and
elsewhere, a strong concern has been voiced about the actual or potential use of so-called
"underground banking systems” by criminal organizations. Calls have been made for new measures to
deal with this problem, some of them drastic. So, the chief objectives of this preliminary study were
to find out whether 1) publicly available evidence supports this concern and 2) how are governments
around the world responding to the issue. This would lead to policy recommendations to be considered
by the Dutch government.
Nikos Passas, LL.B., Ph.D. Professor of Criminal Justice
Northeastern University
Research and Documentation Centre of the Ministry of Justice
Advisory Committee for Research on Organized Crime

The Hawala Alternative Remittance System and its Role in Money Laundering
This paper presents a description of the hawala (also referred to as hundi)
alternative remittance system. Hawala is an ancient system originating in South Asia; today it
is used around the world to conduct legitimate remittances. Like any other remittance system,
hawala can, and does, play a role in money laundering. In addition to serving as a tutorial
on hawala transaction, this paper will also discuss the way in which hawala is used to facilitate
money laundering.
Patrick M. Jost
United States Department of the Treasury
Harjit Singh Sandhu
INTERPOL/FOPAC

Historical Traces of Hundi, Sociocultural Understanding, and Criminal Abuses of Hawala
This article presents a comprehensive descriptive and exploratory analysis of issues related
to Informal Value Transfer Systems (IVTS), including Hawala and Hundi, beginning
with the historical traces of Hundi as rooted in the indigenous banking system in India. It discusses
legitimate sociocultural and economic reasons, as well as political corruption and economic
crimes that sustain Hawala. The article concludes with a discussion on abuse of
Hawala by criminals, including terrorists, bringing to the fore the need to regulate the system.
Some other well-known IVTS include fei ch’ien (Flying Money), Undiyal, casa de cambio
(stash house), and phoe kuan (message houses) Chop Shop and Chits, but it is Hawala that
gained global notoriety after the September 11, 2001, attacks on the United States.
Divya Sharma
Utica College
September 2006
International Criminal Justice Review

Underground Banking: Legitimate Remittance Network or Money Laundering System?
Underground banking, where money is transferred through informal rather than formal banking sectors, is
a recognised method by which legitimate remittances from overseas workers are routinely transferred.
However, underground banking has also long been regarded as a conduit for money laundering by
criminal organisations and arguably by terrorist networks. It is important to achieve a balance between
regulating the underground banking sector in an attempt to reduce the flow of illicit funds, and permitting
its continued use as a legitimate, alternative remittance system. This paper provides policy makers and
others with an interest in underground banking matters with a concise overview of how underground
banking systems work, along with the potential associated with such systems for criminal activity and the
various regulatory responses that governments have employed to date.
Rob McCusker
Australian Institute of Criminology
July 2005

Approaches to a Regulatory Framework for Formal and Informal Remittance Systems: Experiences and Lessons
Remittance flows are an important source of funds for many countries. Money transfers
to countries with a large number of overseas migrants have become the largest component of
remittance flows. A large proportion of remittance flows goes through informal remittance
systems.
Chee Sung Lee
Internation Monetary Fund
Maud Bökkerink
Internation Monetary Fund
Joy Smallwood (LEG)
Internation Monetary Fund
Raul Hernandez-Coss
The World Bank
February 2005

The Regulation and Supervision of Informal Remittance Systems
This paper is a review of recent efforts to strengthen the regulatory and supervisory
framework for informal remittance systems. The authors argue that because there is
insufficient theoretical and practical experience with formal and informal remittance
regulation and supervision, the international and domestic policies currently being
developed should not impose an overly excessive level of regulations. The development
of remittance regulatory theory is still in its infancy and does not provide sufficient
guidelines for policy makers faced with a highly innovative and growing remittance
industry.
Nikos Passas
Northeastern University
Samuel Munzele Maimbo
World Bank
December 2003

Informal Value Transfer Systems, Terrorism and Money Laundering: A Report to the
National Institute of Justice
For many years, representatives of national, foreign, and international law
enforcement agencies have been concerned about the role played by Informal Value Transfer Systems
(IVTS) in the facilitation of serious crimes, including money laundering. Terrorism is now at the
top of the list.
Nikos Passas
Northeastern University
November 2003

Hawala Discourses and the War on Terrorist Finance
In this paper I argue that the informal hawala money-transfer networks, which were made to
take much of the blame for terrorist financing in the wake of the September 11 attacks, are not
`underground' banking systems but are connected to Western banking in a myriad of ways. I argue
that negative stereotyping of hawala in press and policy discourses has implicitly constructed Western
banking as the normal and legitimate space of international finance and has deflected calls for
regulation of Western investment banking. I discuss how hawala is connected to the financial
exclusion of migrant workers in the West. In the war on terrorist finance, discourses of hawala have
led to the underestimation of the complexity of cutting off terrorist funding, while criminalising
remittance networks.
Marieke de Goede
Politics, School of Geography, Politics and Sociology
University of Newcastle
April 2003

Hawala
Since the September 11, 2001, terrorist attacks on the United States,
public interest in informal systems of transferring money around the
world, particularly the hawala system, has increased. The reason is
the hawala system's alleged role in financing illegal and terrorist
activities, along with its traditional role of transferring money
between individuals and families, often in different countries. Against
this background, governments and international bodies have tried to
develop a better understanding of these systems, assess their
economic and regulatory implications, and design the most
appropriate approach for dealing with them.
Mohammed El-Qorchi
International Monetary Fund
December 2002
Finance and Development Magazine

Asian Underground Banking Scheme
Less is known of underground banking in law enforcement circles and
government regulatory agencies than any other form of money laundering
or cash movement. The lack of understanding is largely due to lack of
understanding of the cultures in which the systems operate. Many underground
banking families/networks nowin operation predate the electric light
and the horseless carriage. Their origins are buried in antiquity and they are
part of traditional life in Asia. Given the current war on international terrorism,
a better understanding of the operational methods of different Asian
underground banking schemes would shed much light on money trails used
by the Al Qaeda organizations.
Larry Lambert
Orange County Regional Gang Enforcement Team
November 2002
Journal of Contemporary Criminal Justice

Informal Money Transfer Systems: Opportunities and Challenges for Development Finance
This paper reviews the main types of informal money transfer systems (IMTS). Developed
centuries ago as a way to settle financial obligations, IMTS remain today the preferred
remittance vehicle among migrant communities. Characteristics, such as low transactions costs,
speed, and little paperwork, render them more attractive than banking institutions. After
September 11, IMTS were suspected of being used for terrorist purposes, leading some to call
for their prohibition. The authors think such a response is too drastic and instead propose
measures to make IMTS less prone to possible abuse by criminal elements and encourage the
development of formal sector alternatives.
Leonides Buencamino and Sergei Gorbunov
United Nations
November 2002
DESA Discussion Paper No. 26

Hawala and other Informal Payments Systems: An Economic Perspective
In the months since September, 2001, hawala has been in the news with greater
frequency, often in alleged connection with terrorist activities or as some mysterious system
for “moving money” without money moving at all, and without leaving traces or records.
Such accounts leave impressions of some mysterious financial system that is both dangerous
and beyond ordinary analysis. For better or worse, “hawala” has gotten a bad name and it has
become an issue. In this context, Fund and Bank staff are presently working on a study of
hawala, with primary emphasis on its economic context and mechanisms, which seem to be
widely misunderstood.
John F. Wilson
Senior Economist, Middle Eastern Department, IMF
May 2002
Seminar on Current Developments in Monetary and Financial Law

Hawala and Underground Terrorist Financing Mechanisms
Hearing Before the Subcommittee on International Trade and Finance of the Committee
on Banking, Housing, and Urban Affairs
United States Senate
November 2001

Hawala and Terrorist Financing
While U.S. troops and allies stormed Afghanistan in the fall of 2001, millions of terrorist dollars
were shifted to Dubai, the key location for money laundering in the United Arab Emirate (UAE). Taliban
and al-Qaida operatives gathered money and gold taken from Afghanistan’s banks. These commodities
were then transferred to Dubai by courier and a practically untraceable system known as hawala.
Kristen Parker, MBA
John Bowdidge, Ph.D., Professor
C. Edward Chang, Ph.D., Professor
Southwest Missouri State University

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