Introduction What is money laundering?

The definition of money laundering under the Anti-Money Laundering Act 1 (AMLA) as it is an act which acquire, receive, possesses, disguises, transfer, converts, exchanges or removes from or brings into Malaysia proceeds of any unlawful activity ( Section 3 of the AMLA). Money laundering is also been defined as the use of money derived from illegal activity by concealing the identity of the individuals who obtained the money and converting it to assets that appear to have come from a legitimate source. In other words, money laundering is a process to make dirty money appear to be clean. In the sight of law, dirty money is never clean, no matter how many times it goes through the rinse and spin cycle. Money laundering is a lot like stage magic. The money doesnt really disappear, it just changes form and gets harder to find. Most important of all, the money never really gets clean, it just looks that way. Using proven and secret techniques to make the money obtained in one way appear to have been acquired elsewhere is exactly the job of the money launderer. The anonymity of cash provides certain flexibility and the cash transaction system is used for the vast majority of illegal activities. The Financial Crimes Enforcement Network (FinCEN) describes the money laundering process as having three important stages namely the placement, layering and also integration. In the placement stage, the form of the money is changed or rather be converted. Activity like buying of a football player for instance relies upon cash as an initial medium of exchange and placement mechanisms usually involve either the

AMLA

conversion of currency into some other form or the physical movement of the currency. Placement of dirty money relies on businesses that deal heavily in cash for example in the sports world. Next in the layering stage, launderers attempt to hide their tracks on the paper trail. As the name implies, layers of transactions, business entities, fronts, or other concealment mechanisms are imposed between the money and its source. Sometimes these layers may involve many parties as well as countries where bank secrecy makes following the money trail difficult or impossible at times. In some countries, paper trail can be broken only with difficulty for instance in the United States where in other countries it is the opposite. Last but not least, the stage of integration. Integration mechanisms use the same financial institutions and instruments employed in the other stages with a slightly different aims. At this stage, the apparent source of the funds is the main focus. The launderer now needs to make the funds look as if their origin is legitimate. A close relationship between money laundering and sports has been formed. As the world of sports evolved into a mega money-making activity, automatically money laundering will has its own fair share. Nowadays, the sports industries are getting more attention regarding the issue of money laundering as the industries often involved a big sum of business transactions for example they buying and selling of players of the cricket or the football clubs. Therefore, law has to be there to curb the situation. The following content will contain discussions regarding the issues of relevant sports law or law on the subject of money laundering in various countries for namely Malaysia, United Kingdom and also India. Besides that, other areas that covered money laundering and how it is conducted will also be discussed.

Malaysia There is sports law act in Malaysia. The sports law in Malaysia is governed by the Sports Development Act 19972. The Act regulates all sporting issues. Malaysian Sports Law is relatively recent and has failed to incorporate the salient factors essential factors for protecting the rights of sportspersons. The fact that there is only a few reported cases under the heading of sports law in the Malaysia Law Reports proves that sports law is relatively undeveloped even by the courts. The principal reasons could be attributed to the fact that the disputes and conflicts are usually settled out by courts or by in-house tribunals set up within a particular sports organization. Examples of Malaysian cases are Woon Kwok Cheng v HR Hochstadt3, where a trained jockey was deprived of a jockey license after the domestic tribunal refused to grant license and in Datuk P Murugasu v Wong Hung Nung 4 , regarding a disciplinary proceeding against a football player where action was taken by Executive Committee instead of the Disciplinary Committee of FAM. This deprives the sportsperson of their legal rights especially in matters related to their employment contract. Another problem is the lack of proper procedure in determining the amount of compensation payable to a sportsperson in the event they suffer injury during a sporting event. However, problems faced by Malaysian sportsperson at present are the various other laws and not the Sports Development Act 1997 regulates all social activities related to sports. The issue of match fixing such in the case Raveychandran s/o Goonydo v Datuk Abdul Kadir Jasin and Anor5 are not fully regulated by this

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Sports Development Act 1997 [1997] 4 CLJ 4 [1998] 1 CLJ 119 5 [1997] 3 CLJ SUPP

Act. Issues regarding tax and recreational land in sports are regulated by other legislations such as the National Land Code. The Sports Development Act 1997 merely deals with and provides for the administration and development of sports association in Malaysia. The existing general laws in Malaysia do not specifically deal with a sportspersons rights and therefore, it is timely to introduce legislation to cover this are. It is vital that such legislation concentrate on the safety aspects and protection of a sportspersons rights. Sport is an area of human activity and has become a way of life in many societies. In Malaysia, sport is regarded as an instrument capable of contributing to nation building. Malaysia aspires to foster the growth of a united, healthy, active, disciplined and productive society to enhance national pride and prestige in international arena. Thus, in 1986, during the Sports Convention held in Langkawi the discussion focused on introducing a National Policy on Sports, which was subsequently drafted in 1988. The policy emphasizes more on sports culture and focuses mainly on the development of high performance sports for local and international competitions. However, the National Policy for Sports lacks legal sanction to provide for the necessary protection for sportspersons. Therefore, in 1997, the Sports Development Act 1997 was passed to provide legal measures to regulate sports activities. However, as has been mentioned earlier, then Sports Development Act 1997 merely provides for the administration of sports bodies, it is timely for the Minister of Sports to review the Sports Development Act 1997 to provide better protection for sportspersons and the related sports community. The National Sports Policy (NSP) was initiated and approved by YAB Tun Dr Mahathir Mohamad and his cabinet on 20 January 1988. This document is of historical importance for sports in Malaysia for it provides the foundation and
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guidelines for the sports system, development and growth. The main aim of NSP is to develop an active, healthy and fit society through sports and physical recreation activities. The Malaysian Association for Physical Education, Sports Science and Fitness (PPJSKM) organized a public forum in 2002 and proposed that the NSP should be understood as providing the foundation of Malaysian sports system. The forum believes that since sports system comprises of different organizations, a partnership concept must be present in all interactions such as understanding, respect and appreciation of their different roles and the working relationship must be based on persuasion and consensus. With the establishment of the Cabinet Committee for Sports, it is hoped that the policy in NSP is implemented and carried out with honesty by the appointed authorized personnel. As can be seen, although there is sports law in Malaysia, it clearly does not cover any area of money laundering. This is mainly because the area of sports in Malaysia is still new and has not fully developed yet. The main act that covers the money laundering in Malaysia is Anti Money Laundering Act 2001 (AMLA). The AMLA came into force in 15 January 2002. The AMLA complies with nearly all the FATF Forty Recommendations and recent amendments have been included into the AMLA pursuant to the AMLA (Amendment) Act 2003. These amendments extended to areas covering offence of terrorist financing. Subsequently, the AMLA is now Malaysias primary legislative framework on anti-money laundering and anti-terrorist at the same time. Under the AMLA, it is an offence for any person to engage in or abet the commission of money laundering and terrorist financing. The AMLA seeks to implement measures to prevent money laundering and terrorism financing offences. The Bank Negara Malaysia is put in-charge of the implementation of the provisions of the AMLA. The Bank Negara Malaysia is also required to report requirements in the
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AMLA to accountants who are members of the Malaysian Institute of Accountants. These accountants must hold valid practicing certificates pursuant to Rule 9 of the Malaysian Institute of Accountants (Membership and Council) Rules 2001.

The AMLA covers the offences of money laundering. In addition, it creates mechanisms for investigating and recovering proceeds of unlawful activities. Not only that, the AMLA brings anew the power for the freezing, seizure and forfeiture of the proceeds of unlawful activities. The AMLA also consolidates the requirements on reporting institutions to report knowledge or suspicion of, money laundering activities. The Anti-Money Laundering Act 2001 has been renamed and revised as AntiMoney Laundering and Anti-Terrorism Financing Act 2001 (Act 613). This new Act came into force on 6 March 2007 that incorporated relevant requirements in the area of terrorism financing. On the other hand, the Penal code gives directly or indirectly the provisions for the lawyers regarding the money laundering case. It is provides under Section 130 of the Penal Code of Malaysia. The Criminal Procedure Code which also known as the CPC is a compilation of all steps or procedures accord with all the offences under the Penal Code. The Star newspaper reported Malaysia's law on par to control money laundering. It reported that Malaysias legislation is currently on par with other jurisdictions to control terrorist funding activities and global money laundering abuses in the country. Malaysian Attorney-General Abdul Gani Patail made this remark during the International Conference on Financial Crime and Terrorism Financing 2010. Here, Abdul Gani stated that since Malaysias Anti Money Laundering Act (AMLA) and Anti-Terrorism Financing Act 2010 came into force, the number of
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cases involving these activities underwent sharp decrease from 2004 to 2009. Abdul Gani also stressed that Malaysia hoped to overcome terrorist financing activities and erase all forms of money laundering abuses of the global financial system. According to Abdul Gani, "We have enacted and implemented effective anti-money laundering and terrorist financing legislations that encompass a comprehensive framework to control, if not, to curb these activities

As to the money laundering cases under sports, in Malaysia, there is still no case being reported under this category. Under sports, match-fixing and bribery are more commonly seen and heard. Under the match-fixing, as reported in Dawn.com sports network, Malaysia comes under the match-fixing cloud. Three officials from FIFA came to Malaysia to do some global investigation into match-fixing and illegal gambling (betting). The News Straits Times newspaper said that FIFAs full investigation into match-fixing brought them to two Malaysians. FIFA suspects that the match officials were being paid $10,000 to help wangle specific results in international friendly matches. The newspaper also said that FIFA would investigate two Malaysia-Zimbabwe friendly matches played in 2009. Malaysias football was badly hit by a match-fixing scandal in 1994 to 1995 when a police investigation resulted in more than 100 players, including the then-national captain Matlan Marjan, being banned for life. Steve Darby, chief coach of former Malaysian Cup champions Perak state suggest that Malaysia should legalize football betting to knock-out matchfixing. Legalized betting will help (prevent match-fixing). The money can be ploughed back to provide better training facilities for the players, Darby said. Bung money can also come under money laundering. Bung money is a secret payment that comes under part of football transfers. In football, taking a bung

is illegal and therefore, against the rule. Lets say, if a club wants a particular player in their team, there are usually two ways they can get them. First, wait until their contract timed out and get the players for nothing. Second, agree on a transfer fee with the players club and then agree on a deal. An agent could give bung money to the manager in favour of the manager telling his chairman that he wants to buy a player that agent works for. The particular agent would then pay a sum of money. They would then get money themselves when the deal has taken place. An agent could also give a bung to a chief scout for recommending one of his players to a manager or club. The most famous case involving money laundering is the Indian Premier League game in cricket. The guardian newspaper reported that India launches inquiry into IPL money-laundering allegations. "The concerned department has already started the investigation process," said Mukherjee. "I can assure the honourable members that all aspects of IPL including its source of funding, from where the funds were routed, how they have been invested etc, are being looked into and the appropriate action as per law will be taken. No guilty or wrongdoers will be spared." Shashi Tharoor, a government minister, resigned over claims an associate was handed equity in the new franchise in Kochi. "The minister's resignation is not the issue," said the leader of the Communist Party of India, Gurudas Dasgupta, during parliamentary debate. "The issue is the IPL. [The] issue is laundering of money." So as can be seen here, money laundering is a serious offence and should not be taken lightly. As David Conn said, too much money had corrupted the heart of a great and decent game.

United Kingdom According to Edward Graysons argument, he had claimed that, no object exists which jurisprudentially can be called sports law. As a sound-bite headline, shorthand description, it has no juridical foundation: for common law and equity create no concept of law exclusively relating to sports. Each area of law applicable to sport does not differ from how it is found in any other social or jurisprudential category... This question whether is sports law considered as a written or unwritten law and whether it can be found under the United Kingdom laws. Sports often experience problems that could bring down a particular sport. Most people out there could not see the underlying problems faced by the popular sports like football and cricket. These are one of the few sports experiencing serious matters such as money laundering. Recently, the arrest of Alan Stanford had brought the matter to the limelight. The hearing of Alan Stanfords case will be held in early September 2011. Money laundering in sports often happened in big sport clubs such as football or cricket. The sports law itself do not cover money laundering in its provisions but it can be recognized in various sources of law that have anti-money laundering provisions such as under the criminal law. Few of the statues containing provisions of anti-money laundering are the Proceeds of Crime Act6 and the Money Laundering Regulations7. Laws against money laundering first came into effect when the first directive came from the European Commission in 1991 to meet the terms of the recommendations made by the Financial Task Force or better known as, FATF8. The

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2003 No 171,2006 No.308, 2006 No 1070 1993 No 1933, 2001 No 3641, 2003 No 3075, 2007 No 2157 8 October 2003

FATF is an inter-governmental body that is established to build and endorse policies at an international or national level to contest against any terrorist financing and money laundering. FATF had made it obligatory for the members of the states to mark money laundering as a criminal offence alongside the application of financial institutions. The Anti- Money Laundering Act was incorporated into the United Kingdom Law through several acts. They are, respectively, the Criminal Justice Act 1991, the Drug Trafficking Act 1994 and the Money Laundering Regulations 1993. Ten years later, the second directive on money laundering was passed to incorporate the amendments to the recommendations made by the FATF. With the passing off the second directive, it extended anti-money laundering commitments to a definite set of events provided by a number of service professionals such as independent legal professionals, accountants, auditors, tax advisers and real estate agents. Recently, in 2005, the third money laundering directive came to broaden the due diligence measures by the advantageous owners, recognising that such methods can be applied on a risk-based approach and it is required to enhance the due thoroughness that needs to be undertaken in certain state of affairs. The directive was incorporate into the United Kingdom law by the Proceeds of Crime Act 2002 (Amendment) Regulations 2007 (POCE Regulations 2007)(the TACT Regulations 2007, the POCA Regulations 2007), the Money Laundering Regulations 2007 and the Terrorism Act 2000 (Amendment) Regulations 2007 (TACT Regulations 2007). The Proceeds of Crime Act plays a fundamental role in the legislation of Criminal Law. Its primary role concerns the seizure and retrieval of profits arising from crime and the effects may distort the different classes of criminal activities, money laundering in particular, if which it is the personification of the United Kingdom law. The Proceeds of Crime Act enables convicted criminals to be served
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with exclusion orders, obliging then to pay back that state financially for income resulting from the crime. Aside from that, it allows the upturn of crime proceeds from the criminals who are not convicted as well as the police force authorised with plentiful other abilities to assist them in battling the criminal offences. On the other hand, this act applies to all citizens, despite some failures to report the offences and the tipping off offences only apply to those who are occupied in activities in the synchronized sector. There were distinct offences for drug money laundering under the Criminal Justice Act 1988 and the Drug Trafficking Act 1994 under the pre-Proceeds of Crime Act 2002. Because the 2002 Act has significantly changed all principal money laundering offences and related definitions whether the conduct alleged to be the physical element of the offence was committed before or after the commencement of the Act, the provisions of the old legislation (Drug Trafficking Act and Criminal Justice Act) will apply to conduct before the Act comes into force. Part 7 of the Proceeds of Crime Act commenced on 24 February 2003 and acts of money laundering begun on or after that date are offences under the new Act. When the predicate offence that generated the proceeds took place is irrelevant in determining whether the Act applies. S.340 (4) clarifies that the new offences bite on the proceeds of criminal conduct that took place before commencement. Schedule 9 of Proceeds of Crime Act states the key activities which may be relevant to business such as it advices about the tax affairs of another person by a firm or sole practitioner, the buying and selling of real property or business entities, the managing of client money, securities or other assets as well as the opening or management of bank, savings or securities accounts and the creation, operation or management of trusts, companies or similar structures. Under S.327, 328 and 329, money laundering is
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defined as well as the act which constitutes an offence or conspiracy or attempt to commit such an offence. The offences under these provisions replaced the parallel drug and non-drug money laundering offences with single offence that do not distinguish between the proceeds of drug trafficking and other crimes. There were separate offences for drug money laundering under the Drug Trafficking Act 1994 and non-drug offences under the Criminal Justice Act 1988 under the pre-existing laws. Hence, The Crown sometimes had difficulties in pinpointing for the purposes of charging under the appropriate Act the source of the criminal proceeds. This can be seen in the case of R v Ali & Others [2005] EWCA Crime 87. Some amendments to Proceeds of Crime Act 2002 are contained in the Serious Organised Crime and Police Act 2005 (SOCPA). S103 s108 SOCPA came into force on 1 July 2005. They contain; a new defence to the failure to report offences where the person making the report has no information to identify the money launderer or the whereabouts of the criminal property; a new offence of failing to report on the required form, and other changes to reporting procedures; a new threshold amount below which deposit-taking institutions need not seek consent to operate accounts; a change to the legal professional privilege defence for professional legal advisers. On the 15th May 2006, S.102 of the Serious Organised Crime and Police Act came into force. It creates a new defence to the main money laundering offences and the failure to report offences where the conduct generating criminal property or the money laundering took place overseas but was lawful there. The Money Laundering Regulations 2007 repeal and substitute the Money Laundering Regulations 2003 and implements the third directive. They set

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administrative requirements for the anti-money laundering regime within the regulated sector and frames the scope of customer due diligence. The regulations aim to limit the use of professional services for money laundering by demanding professionals to know their clients and monitor the use of their services by clients. Regulation 3 states that the regulations apply to persons acting in the course of businesses carried on in the UK in the following areas; credit institutions, financial institutions, auditors, insolvency practitioners, external accountants and tax advisers, independent legal professionals and etc. The prosecutions of most money laundering cases revolve around proving one of the two things which are; the proceeds that were laundered were Criminal Property. It is defined here as the benefit that is gained from criminal demeanour. Such can be proven by establishing that the property constitutes a benefit and would not be available to the defendant without criminal proceeds and that the defendant was themselves aware of this situation. The property in question can be in monetary form or it can be property or real estate. Even if the offence charged is conspiracy to launder the proceeds of crime, it is essential for the Crown to demonstrate that the property is the actual proceeds of crime; R v Roy Peter Harmer9; R v Liaquat Ali & others10. If the property has not yet been recognised at the time of the agreement to be criminal property, it must be proved that there was an intention that the property laundered would be criminal property in cases where conspiracy to commit any of the principle money laundering offences is charged. The knowledge that the property was criminal property must be

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[2005] EWCA Crim 01 [2005] EWCA Crim 87

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proved if the property has been identified; R v Saik [2007] 1 AC 18 (which was a decision in relation to a charge of conspiring to contravene s 93C(2) CJA 88). Property is defined in s 340(9) POCA 02 and covers all property wherever situated, including money, real property, personal property and things in action. Next, that the proceeds laundered were the result of criminal conduct. Hence, in the UK, this conduct would constitute as an offence. Proving that proceeds are the benefit from criminal conduct in money laundering prosecutions will usually be done by circumstantial evidence. Where money laundering offences are proceeded with on the same impeachment as the underlying crimes, the underlying criminal conduct will be proved as part of the proceedings as well as the money laundering offence. It is not necessary for prosecutors to prove that the property in question is the benefit of a particular or specific act of criminal conduct where money laundering is charged on its own without a predicate offence. It is essential for the prosecutors to produce sufficient circumstantial evidence from which inferences can be drawn to prove that the property in question has a criminal origin. If there is clear evidence of money laundering a charge may succeed if the real source of the money remains unknown: R. v Anwoir11. Since the introduction of the provisions contained in the Proceeds of Crime Act 2002 and the Money Laundering Regulations of 2003, the prosecutions for money laundering is increasing steadily. Statutory duty have been placed by these acts and regulations on institutions and professionals that operate in finance or accounting to report transactions and investment that are known to be or reasonably suspected of
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[2008] EWCA Crim 1354

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being the result of criminal money laundering. Solicitors, accountants, financial advisors and such professionals that are concerned with the areas of acquisition or disposal of assets or managing funds and investments have this duty bestowed upon them by these acts and regulations. The purpose of s328(1) POCA 02 was not to turn innocent third parties like the bank into criminals; its purpose was to put them under pressure to provide information to the relevant authorities to enable the latter to obtain information about possible criminal activity and increase their prospects of being able to freeze the proceeds of crime. This can be seen in Squirrell Ltd v National Westminster Bank Plc 12 ; a bank froze a clients account without warning or explanation once it suspected that the account contained the proceeds of crime. It was held that once the bank suspected that the applicants account contained the proceeds of crime, under s 328(1) POCA 02 it was obliged to a) report that to the relevant authority; b) ensure that no transactions were carried out in relation to that account; c) ensure that no disclosure was made which could affect any inquiries the authorities might make. Therefore the bank in freezing the account did precisely what the legislature intended it to do. Regarding the relation between sports and money laundering, popular sports such as football often succumbed into this offense as there are a number of stake holders investing in the clubs. Other than that, there is a deficient of the ownership of the clubs and last but not least, with a popular sport favoured by everyone, there would be a great volume of income concerned. As identified by the FATF, there are three precise areas where money laundering occurs in the sport. Firstly, the ownership of the clubs are often transferred, secondly, the ownership of the players and the
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[2005] EWHC 664 (Ch)

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market is always transferred. Thirdly, money laundering occurs often due to image rights, advertising agreements with several parties and also the sponsorship of the clubs to play. In a nutshell, money laundering in sports does occur in the United Kingdom but they do not have special provisions of money laundering under the sports law. This is because sports law is considered as an unwritten law as it can only be found in various sources where it applies alongside the FATF recommendations.

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Other Areas That Cover Money Laundering And The Ways It Is Conducted. There are few areas that cover the money laundering in Malaysia. Money laundering for example gambling is the best example in Malaysia. Regardless in any country in the world, gambling is generally accompanied with crime and illegal. Therefore in Malaysia there have the gambling law review in order to check or regulate on the money laundering. A government team has formed to look into the governing law of gambling in order to rewrite them to stem money laundering and other illicit activities. The money laundering also governs in the business area in Malaysia.

Money laundering is conducted by structuring or smurfing, bulk cash smuggling, cash intensive business, trade based laundering, Shell companies & trusts, bank capture, casinos, real estate and last but not least, through black salaries.

Structuring or even known as smurfing, is a way of position where income are segregated into minor deposits. Through the segregation, the doubt of money laundering is more or less conquered and also, the requirements needed in the antimoney laundering reports can be avoided. Secondly, bulk cash smuggling. Bulk cash smuggling literally involves a substantial smuggling of cash to another influence. The smuggled cash is deposited into a financial body, most preferably a bank located away from the depositor or offshore banks. Offshore banks are banks which provide great bank secrecy with low or no taxation, inclusive of accessibility and protection from financial steadiness and politics.

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Next is cash intensive business. Money laundering occurs through the business that is classically drawn in the acceptance of income, will utilise their accounts to deposit cash obtained illegally or legitimately, and classifies the whole income as legitimate. The fourth area is trade-based laundering. Through trade-based laundering, the transaction of income is well hidden by under or over-valuing invoices obtained. Besides that, money laundering can occur through Shell companies and trusts. The true holder of the cash is kept discrete through the Shell companies and trusts. Depending on the authority, there might not be a need to reveal the true holder or possessor of the cash. The sixth area that involves money laundering is by bank capture. Here, bank captures allows money launderers to purchase a domineering interest in a bank, especially authorities that are weak in the controls of money laundering. After all the process, the cash is able to move out the bank, without being investigated. Other than that, casinos are one of the targets of money laundering. After each game in the casino, the players will bank in his payment; hell be issued a cheque. Here, the culprit of the money laundering activity will have the access to deposit the cheque into his own account and lastly, claiming the cash to be the income of the winnings of the casino. Money laundering can be conducted through real estates. The purchasing of real estates can be done illegally. The proceeds of the sale can appear to be legitimate to the outsiders. In other words, the pricing of the property is manipulated. The party who sells the property will enter into a contract that under-represents the actual value

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of the property. And thus, directly will obtain the illegal proceeds to add up to the dissimilarity. Last but not least, black salaries. Black income might be illegally used by some companies that hold unregistered employees without a contract in black and white, for cash salaries.

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References 1. 2. 3. 4. C. Davies Arnold, Money Laundering in Football, 8 July 2009. Datuk T.P Murugasu v Wong Hung Nung [1988] 1 CLJ 119 (SC) J.Chris, U.K Bribery Act Finally Takes Effect, 1 July 2011. Money Laundering in Sport and the Financial Action Task Force,

http://www.inbrief.com.uk/sports-law/money-laundering-in-sport-financial-taskforce.htm 5. 6. 7. 8. 9. P.Richard, The Birth of European Union Sports Law,2003. Proceeds of Crime 2003 No. 171 Proceeds of Crime 2006 No. 1070 Proceeds of Crime 2006 No. 308 Proceeds of Crimes Act Schedules

10. R v Ilham Anwoir [2008] EWCA Crim 1354 11. R v Liaquat Ali, Akhtar Hussain and Mohsan Khan [2005] EWCA Crim 87 12. R v Roy Peter Harmer [2005] EWCA Crim 01. 13. R. Kirstin, UK watchdog probes two banks over money laundering, 17 Jun 2011. 14. Raveychandran Goonydo v Datuk Abdul Kadir Jasin & Anor & Another Case [1997] 3 ClJ Supp (HC Sabah & Sarawak) 15. Squirrell Ltd v National Westminster Bank Plc [2005] EWHC 664 (Ch) 16. The Money Laundering Regulations 1993 No. 1933. 17. The Money Laundering Regulations 2001 No. 3641 18. The Money Laundering Regulations 2003 No. 3075 19. The Money Laundering Regulations 2007 No. 2157 20. Woon Kwok Cheng v Hr Hochstadt & Ors [1997] 4 CLJ, (HC) 21. Sports Development Act 1997
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22. Money Laundering - Business Areas Prone To Money Laundering (Billy Steel) http://www.laundryman.u-net.com/page9_bus_prone_ml.html 23. Money laundering in Malaysia (By Norwen Shahreedha Mohd Ghazali) http://www.azmilaw.com.my/archives/Article_outside_publications_asian_counsel/ Money_laundering_in_Msia_(00125811).PDF 24. Money launderinghttp://en.wikipedia.org/wiki/Money_laundering 25. How to Launder Money (by Philip Brewer ) http://www.wisebread.com/how-tolaunder-money 26. Money Laundering Guidance: Company and Commercial ( the law society) http://www.lawsociety.org.uk/documents/downloads/ML_company_commercial.pdf 27. XI. Gambling and Crime http://www.library.ca.gov/crb/97/03/Chapt11.html 28. MoneyLaunderingFAQhttp://www.fatfgafi.org/document/29/0,3746,en_32250379_3 2235720_33659613_1_1_1_1,00.html 29. FATF 40 Recommendations 2003

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