The Role of Professional Enablers in Facilitating Unfettered Money Laundering for Politicians: Legal, Accounting, and Banking Means and Systemic Impact on Anti-Money Laundering

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Continent of residence/work [ ] Africa [ ] Europe [ ] North America [ ] South America [ ] Asia [ ] Oceania 4. Sector [ ] Private Practice [ ] Public Sector [ ] Financial Institution [ ] DNFBP [ ] NGO/CSO [ ] Multilateral Body 5. Have you handled or reviewed transactions involving Politically Exposed Persons ? [ ] Yes [ ] No [ ] Prefer not to say 6. Highest educational qualification [ ] Diploma [ ] Bachelor’s [ ] Master’s [ ] PhD [ ] Professional Certification e.g. CAMS, ICA SECTION B: EXTENT OF THE PROBLEM – UNFETTERED MONEY LAUNDERING BY PEPs 7. Politicians in my jurisdiction routinely engage in money laundering without facing prosecution. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 8. Current AML laws are inadequate to detect laundering schemes used by PEPs. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 9. The term “unfettered money laundering” accurately describes PEP financial activity in my country. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 10. Regulatory bodies lack political independence to investigate PEP-linked transactions. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 11. Banks rarely file Suspicious Transaction Reports on high-value PEP accounts. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 12. PEPs exploit legal loopholes more than ordinary criminals do. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 13. Asset recovery from convicted politicians is extremely rare in my jurisdiction. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 14. Media exposure of PEP laundering rarely leads to regulatory action. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree SECTION C: MEANS USED BY PROFESSIONAL ENABLERS C1: Legal Means 15. Lawyers routinely create offshore shell companies for PEPs to hide beneficial ownership. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 16. Law firms invoke “client confidentiality” to avoid reporting suspicious PEP transactions. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 17. Trusts and foundations are deliberately structured by lawyers to obscure PEP funds. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 18. Lawyers facilitate sham litigation to legitimize PEP illicit funds as “court awards”. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 19. Legal practitioners face no real disciplinary sanctions for enabling PEP laundering. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree C2: Accounting Means 20. Accountants help PEPs overstate business income to co-mingle illicit funds. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 21. Auditors deliberately overlook red flags in PEP-owned company accounts. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 22. Accountants create complex group structures to layer PEP funds across jurisdictions. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 23. Tax advisors design schemes specifically to repatriate PEP illicit funds as “tax refunds”. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 24. Accounting firms prioritize PEP clients over AML compliance due to high fees. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree C3: Banking Means 25. Private bankers create bespoke products to facilitate unfettered money laundering for PEPs. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 26. Banks waive enhanced due diligence for PEPs with political influence. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 27. Relationship managers actively advise PEPs on how to avoid triggering transaction alerts. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 28. Banks in my jurisdiction open accounts for PEPs without verifying source of wealth. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 29. Correspondent banking relationships are used to move PEP funds despite weak controls. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 30. PEPs receive preferential treatment in loan approvals used for layering illicit funds. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree SECTION D: SYSTEMIC IMPACT ON AML COMPLIANCE IN HOST COUNTRIES 31. Unfettered money laundering by PEPs has weakened the overall AML compliance culture. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 32. Financial institutions commit less resources to AML because PEP cases are “untouchable”. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 33. Regulatory arbitrage increases as enablers shift PEP funds to weaker jurisdictions. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 34. Failed PEP prosecutions reduce public confidence in the financial system. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 35. Compliance officers face career risk if they escalate STRs on senior politicians. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 36. PEP laundering cases cause correspondent banks to de-risk the entire country. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 37. DNFBPs like real estate and law firms have weaker AML regimes because of PEP influence. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 38. International AML ratings of my country are negatively affected by PEP impunity. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 39. Professional bodies fail to sanction members who enable PEP laundering. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 40. The financial system now treats AML more as “tick-box” compliance due to PEP cases. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree SECTION E: EFFECTIVENESS OF CURRENT COUNTERMEASURES 41. Existing PEP due diligence rules are effective in preventing unfettered money laundering. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 42. Beneficial ownership registries have reduced the use of shell companies by PEPs. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 43. Sanctions on professional enablers are strong enough to deter misconduct. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 44. Whistleblower protections are adequate for staff reporting PEP laundering. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 45. Financial Intelligence Units act independently on PEP-related STRs. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 46. International cooperation is effective in tracing PEP illicit funds. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 47. Mandatory reporting for lawyers/accountants has reduced their role as enablers. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 48. Penalties for non-compliance by banks are proportionate to PEP laundering risk. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree SECTION F: FUTURE OUTLOOK 49. Without political will, unfettered money laundering by PEPs will increase in 5 years. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 50. Technology like AI transaction monitoring will significantly reduce enabler-assisted laundering. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 51. Making professional enablers criminally liable will deter assistance to PEPs. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 52. Public beneficial ownership registries should be mandatory globally to curb PEP laundering. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 53. Host countries will face more financial sanctions if PEP laundering remains unfettered. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 54. Professional bodies should permanently disbar members proven to enable PEP laundering. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 55. Cross-border asset recovery will improve within the next decade for PEP cases. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree 56. The financial system in my country will become more resilient to PEP laundering in 5 years. 1 = Strongly Disagree | 2 = Disagree | 3 = Neutral | 4 = Agree | 5 = Strongly Agree