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TitleThe Puppet Masters
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Total Pages288
Table of Contents
                            Contents
Foreword
Acknowledgments
Abbreviations
Executive Summary
	A Significant Challenge
	The Elusive Beneficial Owner: A Call for a Substantive Approach
	Wanted: A Government Strategy
	The Advantages of Service Providers
	Why Service Providers Should Be Obligated to Conduct Due Diligence
	Enforcing Compliance
	Attorneys and Claims of Attorney-Client Privilege
	A Two-Track Approach
	Why Due Diligence Is Not Enough
	Enhancing the Skills and Capacity of Investigators
	Transnational Investigations
	Building a Transnational Case
	Conducting Risk Analysis and Typologies
Part 1. The Misuse of Corporate Vehicles
	1.1 Introduction
	1.2 Objective of This Report
	1.3 How to Use This Report
Part 2. The Beneficial Owner
	2.1 Introduction
	2.2 Origin of the Term “Beneficial Owner”
	2.3 Defining Beneficial Ownership: The Theory
	2.4 Applying the Concept of Beneficial Ownership in Practice
	2.5 The Service Provider’s Perspective
	2.6 Conclusion and Recommendations
Part 3. Where Does the Beneficial Owner Hide?
	3.1 Introduction
	3.2 Corporate Vehicles: Types and Features
	3.3 Conclusion and Recommendations
Part 4. Finding the Beneficial Owner
	4.1 Introduction
	4.2 Company Registries
	4.3 Trust and Company Service Providers
	4.4 Financial Institutions
	4.5 Conclusion and Recommendations
Appendix A. Compliance with Financial Action Task Force on Money Laundering (FATF) Recommendations 5, 12, 33, and 34
	Texts of FATF Recommendation 5 and Recommendation 12
	Texts of FATF Recommendation 33 and Recommendation 34
Appendix B. The Five Component Projects: Methodology and Summary of Findings
	Project 1. The Grand Corruption Database Project
	Project 2. The Bank Beneficial Ownership Project
	Project 3. The Trust and Company Service Providers Project
	Project 4. The Registry Project
	Project 5. The Investigator Project
Appendix C. Short Description of Selected Corporate Vehicles
	Legal Persons
	General Partnerships
	Limited Partnerships
	Companies
	Limited Liability Company
	Foundations
	Legal Arrangements
	The Trust
Appendix D. Grand Corruption: 10 Case Studies
	Case Study 1: Bruce Rappaport and IHI Debt Settlement
	Case Study 2: Charles Warwick Reid
	Case Study 3: Diepreye Alamieyeseigha
	Case Study 4: Frederick Chiluba
	Case Study 5: Jack Abramoff
	Case Study 6: Joseph Estrada
	Case Study 7: Saudi Arabian Fighter Deals and BAE Systems
	Case Study 8: Pavel Lazarenko
	Case Study 9: Piarco International Airport Scandal
	Case Study 10: Telecommunications D’Haiti
Appendix E. An Overview of Corporate Vehicles in Selected Jurisdictions
Glossary
Boxes
	2.1 The Origin of the Trust
	2.2 Basic Attempt at a Concealment
	3.1 Setting Up a Shell Company
	3.2 Misusing a Shell Company
	3.3 Using Shelf Companies to Conceal Ownership of Bank Accounts
	3.4 A Typical Advertisement for “Shelf Corporations and Aged Corporations”
	3.5 Laundering Money through a Front Company
	3.6 Setting Up Companies with Bearer Instruments
	3.7 Misusing a Bearer-Share Company
	3.8 Misusing a Trust
	3.9 Hiding the Proceeds of Corruption in a Charitable Foundation
	3.10 Receiving Fraudulent Government Contracts by a Partnership
	3.11 Laundering Money through a Sole Proprietorship
	3.12 “Chaining” Corporate Vehicles to Conceal Beneficial Ownership
	3.13 Developing a “Nose” for Inappropriate Complexity
	3.14 Setting up Formal Nominee Arrangements for BCP Consolidated Enterprises (Nevada)
	3.15 The Opacity Benefits of Using Nominees
	3.16 Finding the Front Men: An Insider’s View
	3.17 The Control of Corporate Vehicles by a Front Man
	3.18 The Experience of the United States
	4.1 The Jersey Model
	4.2 Tracking Down Disqualified Directors: United Kingdom
	4.3 The Directors Index: Hong Kong SAR, China
	4.4 Information Sharing and Financial Reporting Systems: Singapore
	4.5 Establishing a Legal Entity Involving More Than One TCSP
	C.1 The Liechtenstein Anstalt
	C.2 The Panamanian Foundation
	C.3 The British Virgin Islands VISTA Trusts
Figures
	3.1 Example of a Complex Legitimate Corporate Vehicle Structure
	4.1 Types of Information on Corporate Vechicles Collected by Registries
	4.2 The Balancing Act of the Corporate Registry
	4.3 Extensive Online Search Facilities Publicly Available at the Company Register of Dubai International Financial Centre
	4.4 Extensive Online Search Facilities Publicly Available at the ICRIS Cyber Search Centre in Hong Kong SAR, China
	4.5 Types of Information Made Available Online by Registries
	4.6 Requirement to Provide ID in Forming Companies (Sampled OECD Countries)
	4.7 Requirement to Provide ID in Forming Companies (Other Countries)
	4.8 Requirement to Provide ID in Forming Companies (Worldwide)
	A.1 FATF Recommendation 5
	A.2 FATF Recommendation 12
	A.3 FATF Recommendation 33
	A.4 FATF Recommendation 34
	B.1 Questionnaire: Financial Institutions’ Rules on Beneficial Ownership and Their Implementation
	B.2 Questionnaire: Investigator Project
	C.1 Composition of Economic Activity Undertaken in the United States as Ascertained by Internal Revenue Service Tax Data
Tables
	3.1 Two Examples in Which the Registration of Corporate Directors Is Addressed in Law
	3.2 Examples in Which Nominees Are Addressed in Law
	B.1 Grand Corruption Cases Database: Case Summary
	B.2 Grand Corruption Cases Database: Corporate Vehicles
	B.3 Grand Corruption Cases Database—Key Statistics
	B.4 Complete Results of First Audit Study
	B.5 Complete Results of Second Audit Study (noncompliant responses in italics)
	B.6 Combined Results
	E.1 Companies
	E.2 Exempt/International Business Companies
	E.3 Limited Liability Companies
	E.4 Partnerships
	E.5 Limited Partnerships
	E.6 Trusts
	E.7 Foundations
                        

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