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Illicit Financial Flows Linked to Atrocity Crimes: Enabling Conduct and Money-Laundering Risks 

Atrocity-crimes generate substantial financial proceeds. The laundering of these proceeds is already occurring but anti-money laundering regimes have not consistently treated them as predicate offences, creating a gap in accountability. 

 

To bridge this gap, this paper:

  • Explains how atrocity crimes generate, move and conceal proceeds;

  • Identifies common enabling typologies and red flags; 

  • Summarizes the FATF standards relevant to predicate offences and highlights the gap; 

  • Provides practical recommendations for FATF, member States, financial institutions, law enforcement and the private sector, including a central recommendation to explicitly recognise atrocity crimes as predicate offences. 

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