Many sectors continue to be significantly exposed to the risk of money laundering and the financing of terrorism, the Commission states in an assessment published earlier this summer, which attracted little media attention.
The Commission has identified 40 products and determined the threat on a scale from one to four, between 'very low' and 'very high'. Few of these products are completely free from any cause for concern.
The emblematic case of real estate. Real estate, for instance, is one of the most susceptible sectors to the threat. In its analysis, the Commission drew a distinction between the threat in itself (in other words the attractiveness of a given sector to criminal organisations) and the vulnerability of the sector. As regards the threat, the assessment shed light on the frequent use of real estate by criminal organisations to launder the proceeds of their crimes, it explains in its document. These organisations purchase property at below market price and pay the difference under the table.
Using real estate does not require any particular skills and can be highly attractive financially. This requires the complicity of professionals in the sector, the Commission states, which leads it to conclude that the threat, in this case, is 'very high'.
As for the vulnerability of the sector, the Commission notes that cash (and therefore anonymous) transactions are still happening. Furthermore, the level of awareness in the sector to the threat varies considerably.
The Commission concludes that the real estate sector is not sufficiently organised to ensure a sufficient level of awareness and there are so many different entities involved in a transaction that it discourages them from carrying out due diligence on their customers. The Commission therefore concludes by stating that the sector's vulnerability is also 'very high'; but the ball is not in its court.
In the measures to be taken, it refers for instance to the creation of specific training for professionals in the sector or the obligation for the competent authorities to publish annual reports on the level of supervision set in place to ensure that the sector complies with the anti-money laundering and financing of terrorism legislation.
Other vulnerable products. The other products or sectors in which the threat is high (in terms both of threat and the vulnerability of the sector) are cash couriers, cash payments, electronic currency and fund transfers.
Other sectors, such as crowdfunding, consumer credit, using notaries or other professionals to create opaque structures or even counterfeiting are in second league as regards the Commission's vigilance. The European institution does not mention VAT fraud, which was recently identified by the Commissioner for Taxation, Pierre Moscovici, as a potential source of funding for terrorism. (Original version in French by Élodie Lamer)