Now that the Paradise Papers are shedding further light on lack of global financial transparency, we can compound the lessons learned from the Panama Papers released in 2016.

“A year ago… the 11.5 million leaked documents known as the Panama Papers implicated hundreds of wealthy individuals and public officials from around the globe in transferring funds to anonymously owned offshore business entities known as shell corporations. While this practice isn’t technically illegal, many clients of Mossack Fonseca, the Panamanian firm at the center of the controversy, used the anonymous accounts associated with these organizations to conduct illegal activities including tax evasion, money laundering, and dodging sanctions. One year later, it is still legal and permissible for corporations in America to be anonymously owned.” (Ferrarello, 2017)

Although the Paradise Papers are unlikely to be as condemning as Panama, the information reinforces similar themes to mitigate financial crime and transparency risk:

  • Comprehensive UBO disclosures (addressed in part by recent UBO-related legislation in the US and Europe)
  • Effective monitored transaction activity
  • Need for investigations of NIS-affiliated shell companies
  • Despite privacy concerns, controlled data sharing