3. Money Laundering Typologies Evidenced in the “Panama Papers”

Garzón (2008).

Olson (2012).

Messineo (2010). See p. 301.

Record No. 2007.61.81.0011245-7/SP. Conviction in 2008 upheld by the Regional Federal Court for Region 3 (São Paulo and Mato Grosso do Sul). Criminal Appeal No. 0001234-26.2007.04.03.6181/SP, heard on June 3, 2012 (Rapporteur, Federal High Court Justice Johonsom di Salvo).

Under this theory, clean money facilitates the laundering of dirty money by hiding it. In doing so, the clean money becomes involved in money laundering. Thus, the clean money is itself tainted and subject to forfeiture. The Racketeer Influenced and Corrupt Organizations Act (RICO) provides for forfeiture of the proceeds of racketeering and reaches tainted assets even in the hands of others, except for bona fide purchasers for value. To make RICO an even more powerful weapon against organized crime, the U.S. Congress set forth harsh penalties: treble damages, recovery of reasonable attorney’s fees, and recovery of costs for the violation of acts prohibited under 18 U.S.C. § 1962(c). In United States v. Certain Funds on Deposit in Account No. 01-0-71417 and United States v. Certain Accounts, for example, the court held that the entire balances were subject to forfeiture under the facilitation theory, adding that even if only part of the legitimate money facilitated the offense, the entire sum was subject to forfeiture. See Gordon (1995), Hamm (2004).

In European Union v. RJR Nabisco, the United States Supreme Court, on June 20, 2016, issued a major decision restricting the extraterritorial application of RICO. “The Court held that RICO’s criminal provisions apply extraterritorially to a limited extent but that its civil cause of action applies only to domestic injuries suffered inside the United States.” Jones Day Law Firm (June 2016). Supreme Court limits extraterritorial application of RICO. http://​www.​jonesday.​com/​supreme-court-limits-extraterritorial​-application-of-rico-06-22-2016/​. Accessed 24 Oct 2016.

The understanding set forth in the sentence uttered by the author of this study is that a work of art, be it a sculpture, painting, photographs, etc., ought not to belong to any person or even to a given location, for here one is dealing with an asset of all humankind. To properly deal with this issue rather than become embroiled in economic discussions we rely entirely upon the Convention Concerning the Protection of the World Cultural and Natural Heritage passed by the General Conference of the UN Educational, Scientific and Cultural Organization (UNESCO) held 11/16/1972, stating that both works by men and notable places are considered cultural patrimony, and therefore protected by the Convention (Article 1), and that it is the duty of States to protect, preserve and present them for future generations (Article 4) and give them a function in the life of the community (Article 5). This was incorporated into Article 23, Subsections III and IV of Brazil’s Federal Constitution, which charges the various branches of government with the protection of historic, artistic and cultural goods, so as to prevent their deterioration, and is also written into legislation under the Constitution (e.g., Legislative Decree No. 25 of 11/30/1937 in its Articles 1 and 24). No such treatment would apply to any other goods apprehended, seized or libeled in criminal prosecution, other than works of art. In the decision rendered, mindful of the valuation of culture and its diffusion to poorer boroughs surrounding big city centers, in confidential records of Cooperative Debriefing, the Sixth Federal Criminal Court for São Paulo decided to turn over 1/15 of the amount as voluntary payment to culture, thus: Pursuant to the decision uttered in these records, on this date, I FIND: This court has earmarked sums obtained as voluntary indemnity in Plea Bargaining directly to charitable entities, duly listed with the court, and required to render accounts. This has been the established rule to preclude decision. São Paulo, December 10, 2008. (60th anniversary of the Universal Declaration), FAUSTO MARTIN DE SANCTIS, Federal Judge. The Second Section of the Appellate Court in Conflicts of Jurisdiction Nos. 76740/SP (record No. 2006/0280806-2, Questioner being the Office of the Public Prosecutor for the State of São Paulo) and 76861/SP (2006/0279583-9, Questioner being the No. 2 Court of Bankruptcy and Recovery for São Paulo), where the jurisdiction is, in both cases, the Sixth Federal Criminal Court, held on 05/13/2009, through Minister and Rapporteur Massami Uyeda, that the No. 2 Court of Bankruptcy and Recovery of the County of São Paulo ought to see to the recovery of the apprehended artworks, but only after the sentence handed down by the Federal Court becomes final, at which time forfeiture would be completed and it would fall to the bankruptcy judge to decide who are good faith third parties (see also De Sanctis 2013).

The house cost approximately R$143,000,000 (US$72 million) to build in August 2004.

Money laundering through the football sector. Disponível: www.​fatf-gafi.​org (http://​www.​fatf-gafi.​org/​media/​fatf/​documents/​reports/​ML%20​through%20​the%20​Football%20​Sector.​pdf), accessed on Nov. 3rd, 2016.

See De Sanctis (2014).

De Sanctis (2015).

“2. From the analysis of the facts imputed to the defendants, a preliminary question arises from the case that must be faced before any procedural or substantial matter. It is indicated in the pleading that the money collected from Universal Church of the Kingdom of God’s followers was transferred to publicly traded corporations CREMO and UNIMETRO, which, on their own turn, sent it to other two companies headquartered in tax havens, called “INVESTHOLDING LIMITED” and “CABLEINVEST LIMITED”, located, respectively, on Cayman Islands (British territory in the Caribbean, south of Cuba) and Channel Islands (UK islands located near the French coast). According to the accusatory pleading, that capital sent to foreign countries would return to Brazil by means of simulated “loans” between “CABLEINVEST” and “INVESTHOLDING” and intermediaries owned by the criminal group. Then, repatriated money was, supposedly, used to acquire communication companies, such as it happened with TV Record. CREMO and UNIMETRO, led, in fact, by some of the defendants and formally directed by others, were, allegedly, according to the indictment, used to disguise and occult the nature, origin, location, disposition, movement and property of those expressive funds that came from larceny by fraud perpetrated against church followers and the religious entity itself. “CABLEINVEST” and “INVESTHOLDING”, according to prosecution, constitute “offshore companies”, i.e. companies located on privileged investment zones abroad. They are located in territories known as “tax havens”, where tax exemptions, reduced income taxes, as well as businesses secrecy attract companies and entrepreneurs searching for greater profitability and privacy. “Offshores” are subject of a differentiated legal regime, thus, extraterritorial, when the residence of its owners and shareholders are taken into consideration. They exist, legally, because some countries adopted a radical policy of tax exemption aiming at attracting investments and foreign capital. Thus, the behaviors attributed to defendants involve, hypothetically, foreign territories, marking the alleged crimes of money laundering with a “transnational” character. Transnationality is a characteristic of a criminal behavior whose execution and fulfillment occurs on foreign territory, outside national borders. This theme is a subject of the United Nations Convention against Transnational Organized Crime, concluded on December 15, 2000, in Palermo, Italy, ratified by Legislative Decree No. 231/03 and promulgated by Presidential Decree No. 5.015/04. It is called “Palermo’s Convention”. In view of the insertion process of the Convention’s text in national Law, it integrates our national legal order with a “federal act” status. This is the major position of national legal doctrine, which is aligned to the understanding of the Supreme Federal Court itself. A brief incursion in international norm is indispensable for full knowledge of the matter. Article 1 of the Palermo Convention states that “The purpose of this Convention is to promote cooperation to prevent and combat transnational organized crime more effectively”. Its article 3, which disciplines its scope, is very explanatory regarding the meaning of transnationality. According to item 2 of article 3, “ an offence is transnational in nature if: (a) It is committed in more than one State; (b) It is committed in one State but a substantial part of its preparation, planning, direction or control takes place in another State; (c) It is committed in one State but involves an organized criminal group that engages in criminal activities in more than one State; or (d) It is committed in one State but has substantial effects in another State.”. In the present case, the money that was allegedly acquired by illegal means was supposedly sent to two “tax havens”, integrated the property of two “offshore companies” and returned as simulated loans, which would characterize the internationalization of the offence hypothetically committed. With this evident transnationality, a matter arises regarding what court has jurisdiction to process criminal cases of money laundering and its related crimes. About jurisdiction, Act No. 9.613/98, in its article 2nd, item III, states that “Federal Justice’s jurisdiction includes: (a) those crimes practiced against the financial system and financial–economic order, or to the detriment of goods, services and interests of the Union, or its public companies and independent agencies; (b) those crimes whose preceding crimes are within Federal Justice’s jurisdiction”. Out of these expressly stated hypotheses, the jurisdiction would belong to State Justice. There are two situations (line “a”) that can find their basis in the general rule of article 109, items IV and VI, of the Constitution, and a third (line “b”) which arises from the connection rule recognized by Superior Court of Justice’s Precedent No. 122, that states: “Federal Justice has jurisdiction for processing and judging, in a unified manner, related crimes that normally belong to State jurisdiction, since article 78, II, a, of the Brazilian Criminal Procedures Code, is inapplicable”. For part of national legal doctrine, Federal Justice always has jurisdiction for processing and judging money laundering offences, given the complexity of the legal subject treated, which certainly involves the national financial system. For Souza Nucci, as an example, “when money is laundered, taxes are left uncollected and the national economy might get affected. In sum, in face of this, there is an interest of the Union and there must be an ascertainment within the federal sphere”. {in Leis Penais e Processuais Penais Comentadas 4ª ed., 2009, Ed. RT, PP. 834/835}. In spite of this venerable doctrinal understanding, I believe that jurisdiction must be verified in each case. It will be State Justice’s if none of the hypotheses referred to in item III (article 2 of Act No. 9.613/98)—which, we must emphasize, is not a thorough list—is applicable. Apart from these cases, another determining factor for excluding State Justice’s jurisdiction is precisely “transnationality”, which makes it, in my view, imperative for Federal Justice’s jurisdiction. I start from the premise that Federal Justice’s jurisdiction is not limited by the three hypotheses of article 2, item III, of Act No. 9.613/98. On that non-thorough list, there must be the inclusion of “transnational money laundering”, which is not present in Act No. 9.613/98, but is shaped and disciplined by Palermo’s Convention, obviously, not as a different crime definition, but as a subject of combat measures that must be created and implemented by signatory countries. It brought, thus, its concept. The aforementioned Convention did not create an autonomous international money laundering definition—it could not do so. In light of the principle of the necessity of a legal definition for crimes, it is indispensable that legislation—in the strict sense—must be enacted, according to ordinary legislative procedure and as manifestation of the will of the Parliament, for a criminal offence to be created. The Convention established, in fact, general prevention and combat measures against money laundering and corruption in general. It uses instruments such as confiscation and seizure of goods, special investigation techniques and international cooperation programs, for protection of witnesses and victims and, at last, regulating extradition. It also specified requirements for laundering to acquire transnationality outlines and, from that, the jurisdiction for processing and judging in Brazil must observe currently enacted norms, interpreting them systematically. Therefore, money laundering partially or totally fulfilled abroad constitutes, per se, a crime that induces Federal Justice’s jurisdiction. In other words, transnationality constitutes another criterion, other than those given by article 2, III, of Act No. 9.613/98, for the laundering offence to be subject of judgment and processing by Federal Justice. Even if preceding offences are within State Justice’s jurisdiction, transnationality is a determining element for establishing federal jurisdiction. That is what happens in the current case, in which the pleading mentions, as preceding offences, larceny by fraud practiced within religious organizations (article 1, item VII, of Act No. 9.613/98). Such conclusion arises from article 109 of the Federal Constitution, which, in its item V, determines that federal judges have jurisdiction for processing and judging “crimes predicted in international treaties or conventions, if, once initiated the execution in the Country, the result has or should have happened abroad, or vice versa”. Now, transnational money laundering, as noted, encounters its definition in Palermo’s Convention, ratified by Legislative Decree 231/03 and promulgated by Presidential Decree 5.015/04, inserting itself, in that manner, in our national legal order. Without doubt, it is an offence defined—yet not legally defined, or typified—in an international convention and, whose execution, initiated in Brazil, touched the territory of another country. It is present, then, another hypothesis that defines federal jurisdiction: if, once initiated the iter criminis of money laundering, any of the offence’s phase (assets collection, occultation or disguise and integration) happens in Brazilian territory and abroad, then, based on article 109, V, of the Constitution, the jurisdiction of Federal Justice is set. Therefore, if the pleading attributes to the defendants the participation in capital laundering in which “offshore” companies, located in the Cayman Islands and Channel Island—safe havens to which the money that came from larcenies by fraud practiced against church followers was sent and then returned to Brazil as simulated loans, so that they could be used to buy companies, were used, then transnationality is constituted. We are, thus, facing a constitutional commandment, an absolute jurisdiction rule, whose strictness does not admit any alteration or prorogation, under penalty of violating the principle of the natural judge (Constitution, article 5, LIII). In sum, notwithstanding the solution aimed by HC No. 990.09.289589-0 was different—the closure of the criminal procedure in face of defendant Veríssimo de Jesus -, by better analyzing the matter, I review, in this opportunity, the prior understanding set and, by the aforementioned arguments, I recognize that State Justice has no jurisdiction for processing and judging this criminal procedure, as well as this Court for judging the current habeas corpus. The scope of the current judgment is limited to the recognition of the lack of jurisdiction of this Court of Justice, so much so that any other deliberations are hampered, for which reason the effects of this decision, regarding ratification or not of procedural acts practiced until now for this criminal procedure, constitute subjects exclusive for Federal Justice’s jurisdiction. 3. For these reasons, by my vote, ex officio, I recognize the State Justice’s jurisdiction does not cover processing and judging the proposed criminal procedure against the defendants, as well as judgment on the merits of the current habeas corpus, by which reason I annul the procedure since the pleading was received—including the pleading itself—and I determine the case file and the criminal procedure (Proc. No. 1121/09—control number) to be sent to Federal Justice, which has jurisdiction over the case.” (Habeas Corpus n.º 990.10.247420-8, 16th Criminal Panel, Judge Almeida Toledo, in São Paulo State Appellate Court site, in http://​esaj.​tjsp.​jus.​br/​cjsg/​getArquivo.​do?​cdAcordao=​4776713&​cdForo=​0, accessed on Oct. 12, 2014; Justiça comum não pode julgar caso da Universal, in Consultor Jurídico, http://​www.​conjur.​com.​br/​2010-out-20/​justica-comum-nao-competencia-julgar-universal-tj-sp, on Oct. 20, 2010, accessed on Nov. 03, 2016).

FERREIRA, F. Justiça de SP anula processo contra bispos da Universal. Folha.com: São Paulo, out. 2010. In http://​www1.​folha.​uol.​com.​br/​poder/​817422-justica-de-sp-anula-processo-contra-bispos-da-universal.​shtml, accessed Nov. 3, 2016. The decision will be analyzed by the Brazilian Supreme Court (Recurso Extraordinário com Agravo, ARE n.º 737566, Justice Teori Zavascki, in http://​www.​stf.​jus.​br/​portal/​processo/​verProcessoAndam​ento.​asp?​incidente=​4375014, accessed on Nov. 3, 2016).

Habeas Corpus n.º 0038794-85.2011.4.03.0000/SP, 5th Panel, Federal Appellate Judge Luiz Stefanini, (in Tribunal Regional Federal da 3ª Região site, published on Sept. 11, 2012, http://​web.​trf3.​jus.​br/​acordaos/​Acordao/​BuscarDocumentoG​edpro/​2279490, accessed on Nov. 3, 2016). There is no a final decision yet.

“When even a single act of sexual abuse by a priest or deacon is admitted or is established after an appropriate process in accord with canon law, the offending priest or deacon will be removed permanently from ecclesiastical ministry, not excluding dismissal from the clerical state, if the caso so warrants” (A Report on the Crisis in the Catholic Church in the United States, in http://​old.​usccb.​org/​nrb/​nrbstudy/​nrreport.​htm, accessed on June 26, 2014, p. 22 and 25).

Vatican Bank investigated over money laundering. Bbc.co.uk. [S.l.], set. 2010. In http://​www.​bbc.​co.​uk/​news/​world-europe-11380628, accessed on Nov. 3, 2016.

Papa nomeia comissão de inquérito para o Banco do Vaticano: Integrantes responderão diretamente a Francisco. Globo.com. Cidade do Vaticano, jun. 2013. In http://​oglobo.​globo.​com/​mundo/​papa-nomeia-comissao-de-inquerito-para-banco-do-vaticano-8818007, accessed on August 26, 2014.

Cardinal commission for Vatican bank could undergo changes, in Patheos site, published on January 10, 2014, http://​www.​patheos.​com/​blogs/​catholicnews/​2014/​01/​cardinal-commission-for-vatican-bank-could-undergo-changes/​, accessed on Nov. 3, 2016.

Leigh, David, Tand, Jean François and Benhamou, Jessica. How the Vatican built a secret property empire using Mussolini's millions. Papacy used offshore tax havens to create £500 m international portfolio, featuring real estate in UK, France and Switzerland. The Guardian published on January 21, 2013 (in http://​www.​theguardian.​com/​world/​2013/​jan/​21/​vatican-secret-property-empire-mussolini, accessed on Nov. 3, 2016).

Macedo (2015).

On July 20, 2016, US$1 = R$3.25.

It was extracted from Marqueteiro de Dilma sabia que dinheiro era de origem ilegal, diz PF (2016, Feb 22). UOL. http://​noticias.​uol.​com.​br/​politica/​ultimas-noticias/​2016/​02/​22/​marqueteiro-de-dilma-sabia-que-dinheiro-era-de-origem-ilegal-diz-pf.​htm. Accessed 20 Mar 2016.

Há evidências de que Lula recebeu R$ 30 mi desviados da Petrobrás, diz MPF (2016, Mar 4). UOL. http://​noticias.​uol.​com.​br/​politica/​ultimas-noticias/​2016/​03/​04/​lula-e-seu-instituto-receberam-valores-expressivos-de-empreiteiras.​htm. Accessed 22 Mar 2016.

Força-tarefa aponta “patrimônio oculto” do ex-presidente (2016, Mar 4). UOL. http://​noticias.​uol.​com.​br/​ultimas-noticias/​agencia-estado/​2016/​03/​04/​forca-tarefa-aponta-para-patrimonio-oculto-do-ex--presidente.​htm. Accessed 22 Mar 2016.

Verret (2010).

The bill hasn’t been passed yet. It continues to be introduced by representatives. See https://​www.​congress.​gov/​bill/​114th-congress/​house-bill/​4450/​text. Accessed 4 Nov 2016.

Reps. Maloney, King and Senator Whitehouse introduce bills to stop anonymous money laundering operations by requiring disclosure of shell corporation beneficial owners, Carolyn B. Maloney Press Release https://​maloney.​house.​gov/​media-center/​press-releases/​reps-maloney-king-and-senator-whitehouse-introduce-bills-to-stop. Published 3 Feb 2016, accessed 5 Nov 2016.

Article 8 reads as follows:

The registration information relating to the entities and entities referred to in sections V, XV, XVI and XVII of the caput of art. 4 shall cover the persons authorized to represent them, as well as the chain of ownership interest, to reach individuals characterized as final beneficiaries or any of the entities mentioned in § 3.

§ 1. For the purposes of the caput, it is considered final beneficiary:

I—the natural person who ultimately, directly or indirectly owns, controls or significantly influences the entity; or

II—the natural person on whose behalf a transaction is conducted.

§ 2. It is assumed significant influence, referred to in § 1, when the natural person:

I—has more than 25% (twenty five percent) of the capital of the entity, directly or indirectly; or

II—directly or indirectly holds or exercises the preponderance in corporate resolutions and the power to elect a majority of the entity’s management, even without controlling it.

§ 3 Exempt from the provisions in the heading:

I—legal entities incorporated as a public company in Brazil or in countries that require public disclosure of all shareholders considered relevant and are not incorporated in jurisdictions with favorable tax or subject to preferential tax regime that in arts. 24 and 24-A of Law 9430 of December 27, 1996;

II—nonprofit entities that do not act as fiduciary managers and are not incorporated in jurisdictions with favorable tax or subject to preferential tax regime that in arts. 24 and 24-A of Law No. 9430, of 1996, provided that regulated and supervised by government authorities;

III—multilateral organizations, central banks, government agencies or linked to sovereign wealth funds;

IV—the pension funds, pension funds and similar institutions, if regulated and supervised by government authorities in the country or in their country of origin; and

V—national investment funds regulated by the Securities and Exchange Commission, provided it is informed to the RFB in e-Financial the Register of Individuals (CPF) or CNPJ of unit holders of each fund managed by it. Instrução Normativa RFB no. 1634 (2016, May 6). http://​normas.​receita.​fazenda.​gov.​br/​sijut2consulta/​link.​action?​idAto=​73658. Accessed 5 Aug 2016.

U.S. Department of Treasury (2016).

U.S. Department of Treasury (2016, July 19). FinCEN Expands Reach of Real Estate “Geographic Targeting Orders” Beyond Manhattan and Miami, Fincen site, https://​www.​fincen.​gov/​news/​news-releases/​fincen-expands-reach-real-estate-geographic-targeting-orders-beyond-manhattan. Accessed 4 Nov 2016.

Grewal (2016).

Al Sayegh and Torchia (2016).

Mubangizi (2007) quoting Das L. “The spectre of poverty in the Commonwealth: A serious violation of human rights?” http://​www.​jha.​ac/​books/​br025.​htm (accessed 1 March 2006).

Cousin and Albert (2002, p. 89).

Vazamento revela ligação de políticos com offshores nas Bahamas (2016).

Levi and Reuter (2006, p. 293).

Goddard (2012).

Goddard (2012).

In www.​planalto.​gov.​br/​ccivil_​03_​leis)L4131.​htm. Accessed 16 July 2016.

The fact that the Central Bank deals more simply with amounts of up to $3000, dispensing with the currency exchange agreement, in no way constitutes a waiver of the requirement that all debits and credits in customer accounts or through financial instruments be recorded so as to allow tracking of assets.

See www.​planalto.​gov.​br/​ccivil_​03/​leis/​L9069.​htm. Accessed 16 July 2016.

In www.​planalto.​gov.​br/​ccivil_​03/​Decreto-Lei/​Del0857.​htm. Accessed 17 July 2016.

In www.​planalto.​gov.​br/​ccivil_​03/​decreto-1930-1949/​D23258.​htm. Accessed 17 July 2016.

International Capital and Foreign Exchange Market Regulations (RMCCI). www.​bcb.​gov.​br/​?​RMCCI. Accessed 29 Oct 2016. Resolution No. 3568 of May 29, 2008, is the primary regulation http://​www.​bcb.​gov.​br/​pre/​normativos/​busca/​normativo.​asp?​tipo=​Res&​ano=​2008&​numero=​3568. Accessed 20 July 2016.

For more on the influx of new immigrants who wire money back to their countries of origin, and their profiles, see Inter-American Dialogue (2012).

International Institute for the Unification of Private Law (1988).

Code of Federal Regulations—C.F.R. § 1010.100 (ff) (2016). https://​www.​gpo.​gov/​fdsys/​granule/​CFR-2011-title31-vol3/​CFR-2011-title31-vol3-part1010. Accessed 10 Sept 2016. The Code of Federal Regulations (CFR) annual edition is the codification of the general and permanent rules published in the Federal Register by the departments and agencies of the federal government. It is divided into fifty titles that represent broad areas subject to federal regulation. The fifty subject matter titles contain one or more individual volumes, which are updated once each calendar year, on a staggered basis. The annual update cycle is as follows: titles 1–16 are revised as of January 1; titles 17–27 are revised as of April 1; titles 28–41 are revised as of July 1; and titles 42–50 are revised as of October 1. Each title is divided into chapters, which usually bear the name of the issuing agency. Each chapter is further subdivided into parts that cover specific regulatory areas. Large parts may be subdivided into subparts. All parts are organized in sections, and most citations to the CFR refer to material at the section level. See https://​www.​gpo.​gov/​help/​about_​code_​of_​federal_​regulations.​htm.

Code of Federal Regulations—C.F.R. § 1010.100 (ff)(5)(i)(A) (2016). https://​www.​gpo.​gov/​fdsys/​granule/​CFR-2011-title31-vol3/​CFR-2011-title31-vol3-part1010. Accessed 10 Sept 2016.

See Lo (2016, pp. 113–114).

Field (2016).

Field (2016).

Field (2016).

Resnick (2016).

For a discussion of virtual worlds, see Landman (2009).

Hariharan (2012, p. 307).

World Bank (2016).

World Bank (2016).

Douglass (2010, p. 72).

Watterson (2013, pp. 745, 748).

Thompson (2009‐2010, 241–265).

Cuomo (2005).

Id.

Cf. I.R.C. § 170 (c) (2006).

See Mcleman v. United States. 24 Cl. Ct. 109, 91-2 USTC 50, 447, 1991.

In I.R.C. § 170 (e) (3) (2006).

Provided they are also recognized as such in the U.S. tax code, also known as the Internal Revenue Code, Sect. 501 (c); 527; 4947 (a) (1).

State of New York—Department of Law (2015, Mar). Solicitation and collection of funds for charitable purposes. https://​www.​charitiesnys.​com/​pdfs/​statute_​booklet.​pdf. Accessed 30 Sept 2016.

According to information provided by Patricia Lobaccaro on May 16, 2012. Ms. Lobaccaro is president and CEO of Brazil Foundation, with offices at 345 7th Ave., Suite 1401, New York City.

See http://​www.​nasconet.​org/​. Accessed 30 Oct 2016.

Terror outfit-turned ‘charity’ JuD set to come under Pak Central Bank scanner (2012).

Marpakwar (2011).

For more on this, see Sikarwar et al. (2011).

FATF (June 2014). Risk of terrorist abuse in nonprofit organisations. http://​www.​fatf-gafi.​org/​media/​fatf/​documents/​reports/​Risk-of-terrorist-abuse-in-non-profit-organisations.​pdf. Accessed 28 Sept 2016; Government plans ‘umbrella law’ to tighten scrutiny and regulation of religious trusts and NGOs (2011, May 2). Economic Times. http://​articles.​economictimes.​indiatimes.​com/​2011-05-02/​news/​29496119_​1_​religious-trusts-voluntary-sector-companies-act. Accessed 22 June 2016.

Government plans ‘umbrella law’ to tighten scrutiny and regulation of religious trusts and NGOs (2011, May 2). Economic Times. http://​articles.​economictimes.​indiatimes.​com/​2011-05-02/​news/​29496119_​1_​religious-trusts-voluntary-sector-companies-act. Accessed 22 June 2016.

Shah (2009).

Money laundering, terror financing: SECP imposes more conditions. Business Recorder. http://​aaj.​tv/​2009/​09/​money-laundering-terror-financing-secp-imposes-more-conditions/​. Accessed 28 Sept 2016.

Shah (2009).

For more on this, see Bickerton (2009).

See Crimm (2004, pp. 1449–1450).