Financial Action Task Force Research Articles

A New Human Right to Freedom from Corruption

In the long battle against corruption, the last 20 years or so has yielded a number of international legal and institutional initiatives -- most notably, the OECD Bribery Convention and the UN Convention Against Corruption; regional anti-corruption conventions (in both Africa and the Americas); and the Financial Action Task Force; as well as a swathe of political responses, from G8 and G20 statements and UN resolutions, to civil society campaigns and organizations such as Transparency International and the World Economic Forum’s Partnering Against Corruption Initiative. In terms specifically of human rights, however, the response has not progressed far beyond baseline analyses of the negative human rights impacts of corruption and calls for that much to be recognized in efforts designed to combat corruption. What, in particular, is missing is any concerted effort to assess what precisely international human rights law could do to promote those efforts and what tangible added value a human rights approach might offer. The proposal advanced in this paper is intended to fill that gap. While it takes the form of an international human rights law instrument, it is nevertheless meant to supplement these other responses, not to replace or oppose them. What I am suggesting is that there ought to be recognized a specific, free-standing human right combatting corruption -- that is a "right to freedom from corruption" (RFFC) -- at the level of international law. As such, and like all international human rights laws, it would demand implementation in domestic jurisdictions, while providing normative guidance and supervision at the international level. This paper outlines (i) why we need such a new right, (ii) what form it should take and (iii) whether it would work in practice.

MONEY LAUNDERING: HOW IT BECOMES AN INTERNATIONAL THREAT (RESPONSE AGAINST MONEY LAUNDERING FROM THE SIDE OF INDONESIA)

Money Laundering is one of the transnational organized crime which has been increasing intensively. Money laundering is the term used to describe a process of concealing the source of money that gained through crime (it is usually called “dirty money”). This process is done with the aim to make the “dirty money” converted into “clean money”. There are many ways for this process to be done, among them is by buying properties and houses. Other is by saving the “dirty money” in a bank account that will later turned it into “clean money”. This is where the bank service could get involved in this particular crime. In an attempt to overcome this problem, countries joining in the G-7 Summit established the Financial Action Task Force (FATF) in Paris in July 1989 that provides standards recommendation, national and international, as measures to make integrated cooperation among countries. This essay discusses the very definition of money laundering, the role FATF takes in order to prevent money laundering, and the responses of Indonesia regarding money laundering.

Institutionalization of risk management framework in Islamic NGOs for suppressing terrorism financing

Purpose – The aim of this paper is to propose solutions for improving internal controls and transparency to alleviate concerns of international community over alleged linked with terrorist groups. Design/methodology/approach – The authors explore the counter-insurgency theory and political process model to explain the current state of counter-terrorism activities aimed at Islamic NGOs after 9/11. Findings – The authors believe the idea of money flow disruption to be of greater importance than freezing the accounts to suppress terrorism financing. Practical implications – Islamic NGOs established for philanthropic and humanitarian aid in third world Muslim countries have been accused of being involved in terrorism financing. This revelation is to the disadvantage of the donors who do not channel their donations for such activities. The authors propose risk management framework useful at operational level to detect and prevent welfare activities financing warfare activities. Originality/value – The proposed risk management framework is to complement various regional and international initiatives championed by Asia/Pacific Group on Money Laundering and Financial Action Task Force to combat money laundering and terrorist financing.

(Inter)national standards on money laundering with regard to the FATF recommendation

In recent years, the international community has become more aware of the dangers that money laundering poses. To control the increase in money laundering, a number of initiatives were adopted, for example, the Financial Action Task Force (FATF) on money laundering in 1989. Money laundering activities can occur in any country, but they may have a more significant impact on developing countries with small or fragile financial systems or weak economies that are susceptible to disruption as a result of illicit activities. The new recommendations made by the FATF will be discussed critically with regard to combating of money laundering. This article gives an historical overview of what money laundering entails in South Africa, the typologies thereof as well as the legislation dealing with money laundering. Money laundering is difficult to measure, but a preliminary attempt is made to give recommendations on this global predicament.

Panama: Detailed Assessment Report—FATF Recommendations for Anti-Money Laundering and Combating the Financing of Terrorism

This report evaluates the level of implementation of Financial Action Task Force (FATF) Recommendations for Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) in Panama. The findings reveal that Panama is vulnerable to money laundering from a number of sources, including drug trafficking and other predicate crimes committed abroad, such as fraud and financial and tax crimes. The AML Law covers most of the core financial sectors but does not fully apply to the insurance sector and does not extend to a number of other financial activities as required under the FATF standard. Competent authorities, including law enforcement and the Financial Intelligence Unit, do not have timely access to information on legal persons and arrangements as required under the FATF standard.

An analysis of the 'know your customer' policy as an effective tool to combat money laundering: is it about who or what to know that counts?

The ‘know your customer’ (KYC) policy has emerged as an important strategy for a proactive war against money laundering both nationally and internationally. In terms of this policy, financial institutions in most countries are required to identify their clients and the legitimacy of their financial transactions. The main purposes of this policy are profiling the originators of this potentially anti-economic crime as well as tracking the audit trail of any money that flows into our banking systems. However, a closer look at both the international and many of the national anti-money laundering strategies reveals that their regulatory instruments do not address both these purposes for combating money laundering. The question that needs to be asked is whether the buck of KYC policy can effectively stop with financial institutions profiling who their customers are rather than also tracking the trails of money through all the banking systems that money flows into. This paper will analyse both the South African and the international money laundering regulatory frameworks with specific focus on the Financial Action Task Force on Money Laundering and attempts to explore the shortfalls of the KYC policy as an anti-money laundering tool.

10.5937/timsact8-6041 = Sport without game: Money laundering

Sport is firmly connected to politics in the whole world, the Republic of Serbia being no exception. Pronounced motives of profit in sport led to the appearance of new problems, like money laundering and business and moral unreliability of the participants. Some of anomalies are connected with politically exposed persons (PEP). Offering services within the banking industry, especially considering the private banking, entails a higher degree of discretion and confidentiality in comparison with the ordinary clients. Misuse of these business relationships by PEP has been identified. This paper surveys the statistically significant differences between domestic banks and the domestic banks with the foreign capital in relation to the groups of procedures concerning PEP based on the Recommendation 6 of the Financial Action Task Force on Money Laundering - FATF. Although the domestic banks with the foreign capital were obliged to apply the procedures related to the FATF's Recommendations to the same extent as the Main Office, significant differences between domestic and foreign banks were not found, in terms of Recommendation 6. Inadequacy of regulations and lack of enforcement procedures jeopardize the program of reforms, threatening, the privatisation in sports.

Legal Principles and Solutions to Combat Money Laundering in the International System

This study focuse on combat money laundering legal principles and solutions to in the International System. As its clear Money laundering is the attempt to disguise the proceeds of illegal activity so that they appear to come from legitimate sources. Money is laundered through banking systems and credit institutions, non financial institutions and non financial economic activities. Combating money laundering phenomenon dates back to the 1980s. In 1989, Financial Action Task Force was set up to combat money laundering which published forty recommendations pertaining to money laundering in 1990. In 1997, it published an important document titled as Core Principles for Effective Banking Supervision. Also Basel Committte on Banking Supervision offered its ninth special recommendation to further reinforce international stadndards of anti- money laundering in 2004. At the end of the study, experiences of U.S., European Union and jurisdictions pertaining to combating money laundering are presented.

Recent Trends in Regulating Money Laundering & Terrorism Financing in the Banking, Insurance and Capital Market Sectors of the Financial Economy of Nigeria: Role of the Financial Regulators

In the recent past, more countries are becoming vulnerable to the risks of money laundering and its contagious effects. According to the International Monetary Fund (IMF), the scale of money laundering globally could be between 2% and 5% of World Gross Domestic Product at the very lowest. This translates into a range of anything between US Dollars 590 billion to USD 1.5 trillion of laundered money per year.According to a very recent release by the Nigerian Economic and Financial Crime Commission (EFCC), an estimated $129 billion dollars (equivalent to N21 trillion Naira) was illicitly transferred out of Nigeria in the last ten years (2003-2013). The sources of the funds are often corruption, tax avoidance, tax evasion, illegal mining activities, drugs and human trafficking. The Nigerian Financial Intelligence Unit domiciled with the EFCC estimates that between 2009 and 2013, about $25.4 billion dollars were moved out of the country through cross border physical movement of cash and financial instruments. While these figures may not be necessarily indicative of the proceeds of crime, it shows vulnerabilities associated with cash movement within and outside the West African sub-region..The African region and indeed most of the developing countries are vulnerable to money laundering and terrorist financing particularly because of their cash-based and open economies. In Africa, this is further aggravated by the porous and weak controls at the borders. Combating money laundering and terrorist financing in these economies is further complicated by weak or ineffective regulation of financial institutions, lack of comprehensive legal framework, weak law enforcement agencies and poor coordination and collaboration between law enforcement agencies and financial regulatory bodies.Recent studies, including the ones carried out by the Inter-Governmental Action Group Against Money Laundering in West Africa (GIABA) and the Financial Action Task Force (FATF), suggest that advances in technology and the progressive tightening of Anti-Money Laundering (AML) regulations are leading money launderers to make more complex arrangements outside the formal financial services industry, such as the use of various professional services, and in particular the real estate business, legal practitioners, tax consultants, chartered accountants and designated Non-Financial Institutions or sectors, such as the International football, casinos and gaming, hotels, supermarkets, dealers in luxury goods, cars and jewelry.The above opportunities and skills acquired by money launderers and their collaborators led to the renewed strategy and initiatives adopted by the Nigerian Government between 2011 and October 2013 in combating money laundering and terrorism financing in Nigeria. This resulted in the promulgation of the Money Laundering (Prohibition) Act, No. 11, 2011, which inter alia, repealed the 2004 Act, made comprehensive provisions to prohibit the financing of terrorism, provide for appropriate penalties and expand the scope of supervisory and regulatory authorities so as to address the challenges faced in the implementation of the anti-money laundering regime in Nigeria. A year later, amending the 2011 Act, the Money Laundering Act, No.1, 2012 introduced new initiatives that greatly improved and added value to the provisions of sections 2, 3, 6, 9, 11, 15, 16, 20, 23 and 25 of the amended 2011 Act. Furthermore, the other recent trend is the provision for liability regime for financing of terrorism under the Terrorism (Prevention) Act, 2011 as amended by the 2013 Terrorism (Prevention)(Amendment) Act and strengthened by the 2013 Regulations on the Freezing of International Terrorists Funds and other related Measures.It is against this background that this paper seeks to realize the following objectives:1. To examine why and how is combating money laundering and financing of terrorism a top priority for the international community;2. To appraise the development and initiatives reflected in the legal and institutional frameworks in combating money laundering and financing of terrorism in Nigeria;3. To highlight the critical roles of financial regulators in regulating money laundering and terrorism financing in the banking, insurance and capital market sectors of the Nigerian economy;4. To conclude with some recommendations.

Appraisal of Legal, Regulatory and Institutional Frameworks in Combating Money Laundering and Terrorism Financing in Nigeria

In the recent past, more countries are becoming vulnerable to the risks of money laundering and its contagious effects. According to the International Monetary Fund (IMF), the scale of money laundering globally could be between 2% and 5% of World Gross Domestic Product at the very lowest. This translates into a range of anything between US dollars 590 billion to USD 1.5 trillion of laundered money per year.The African region and indeed most of the developing countries are vulnerable to money laundering and terrorist financing particularly because of their cash-based and open economies. In Africa, this is further aggravated by the porous and weak controls at the borders.Combating money laundering and terrorist financing in these economies is further complicated by weak or ineffective regulation of financial institutions, lack of comprehensive legal framework, weak law enforcement agencies and poor coordination and collaboration between law enforcement agencies and financial regulatory bodies.Recent studies, including the ones carried out by the Inter-Governmental Action Group Against Money Laundering in West Africa (GIABA) and the Financial Action Task Force (FATF), suggest that advances in technology and the progressive tightening of Anti-Money Laundering (AML) regulations are leading money launderers to make more complex arrangements outside the formal financial services industry, such as the use of various professional services, and in particular the real estate business, legal practitioners, tax consultants, chartered accountants and designated Non-Financial Institutions or sectors, such as the International football, casinos and gaming, hotels, supermarkets, dealers in luxury goods, cars and jewelry.It is against this background that this paper seeks to realize the following objectives: 1. To examine why and how is combating money laundering and financing of terrorism a top priority for the international community;2. To appraise the development and initiatives reflected in the legal and institutional frameworks in combating money laundering and financing of terrorism in Nigeria.3. To conclude with some recommendations.

A turn toward experimentalism? Rethinking security and governance in the twenty-first century

AbstractConventional understandings of security cooperation are rooted in the state-centric and materialist assumptions dominant in the Cold War and subscribe to the dictum of the Reagan years, ‘trust but verify’. In today's more complex setting, however, governance arrangements with the most potential to address constantly mutating security threats, such as the concern over nuclear terrorism, may not be those solely designed to ensure compliance, but rather those that are better equipped to identify and solve new problems. This article draws on a burgeoning literature on ‘new’ or ‘experimental’ governance and advances an analytical framework to consider the extent to which states and other actors might be turning toward an alternative set of mechanisms that rely more heavily on non-binding standards and recommendations, peer review, increased participation, and experimentation to generate new knowledge about the challenges they face, even in the ‘hard’ case of security cooperation. It then explores this potential reorientation in two separate, but complementary cases that have emerged as key tools in preventing illicit nuclear proliferation: the Financial Action Task Force on Money Laundering (FATF), which seeks to bolster states' counter-financing of terrorism systems, and the UNSC Resolution 1540 Committee, which guides efforts to fill the governance gaps in the nuclear non-proliferation regime. Although both cases on paper contain more traditional enforcement components, in practice they rely increasingly on experimental governance. The article concludes with an evaluation of the promise and limits of an experimentalist framework in understanding the evolution of governance arrangements in response to a more complex security environment and suggests potential avenues for future research.

Money-laundering in Southeast Asia: liberalism and governmentality at work

This article discusses the diffusion of a regulatory system against money-laundering in Southeast Asia. To this end, the article reconstructs how the Financial Action Task Force has securitised the issue of money-laundering into a global problem requiring a global solution and how this has spread to developing nations. The article seeks to demonstrate how these international norms and practices spread and are transformed into national law within Southeast Asia. The article further shows that these transformations reflect an increasing level of multilateral cooperation within the region and that this phenomena can be better understood as the articulation of a global expression of governmentality where a set of strategies and policing techniques emerges to effect control.

Michael Freeman, ed. Financing terrorism: Case studies

Michael Freeman, ed. Financing terrorism: Case studies Farnham: Ashgate, 2012. 266 pp $89.96 (cloth) ISBN: 978-1-4094-4261-5By the turn of the millennium the not-yet 10-year-old international anti-money laundering regime already appeared moribund. It was the War on Terror that reinvigorated this regime with a newfound zeal to counter terrorism financing. The Financial Action Task Force the regime's central inter-governmental actor to fight money laundering was asked to target terrorism financing. Several states proposed new legislation, or amended existing legislation, to make terrorism financing illegal. A broad literature emerged on international and national policies to counter illicit finance. Though we have a fair sense of how criminal organizations launder funds, less is known about how terrorist organizations finance their activities. Financing Terrorism, edited by Michael Freeman, attempts to address this gap.Financing Terrorism is not a theory-driven book; contributors present detailed accounts of terrorist organizations from around the world, their principal modes of operation, and their financing activities. The book's objective is to be practical on the assumption that better policy should come from a more complete understanding of how specific organizations operate. The book largely assumes that terrorist organizations need sustained and reliable funding to pursue their political objectives, continue operations, and in many cases, buy popular legitimacy. Contributors consider four key funding sources: state sponsorship, illegal activities, legal activities, and popular support (often provided knowingly or unknowingly through charitable donations). The book presents terrorist organizations region by region: the Middle East (Iraqi insurgent groups, Hezbollah), Asia (Partiya Karkeren Kurdistan, Lashkar-e-Taiba, the Taliban, the Liberation Tigers of Tamil Eelam, and Filipino terrorist groups), Europe (Loyalists in Northern Ireland, and Islamist groups in Albania), and the Americas (FARC and National Liberation Army, Colombia). Contributing authors come from academia as well as from military establishments in the US and elsewhere; all appear to possess excellent knowledge of the groups under consideration. Taken as a whole, the book provides a comprehensive overview of how various terrorist organizations finance and support their activities.Financing Terrorism's main conclusion, which is more implicit than explicit, is that while combating terrorism financing is important to diminishing a terrorist group's capacity to inflict harm, it is only one instrument among many with which to target organizations. From a Canadian perspective, the chapter on the Tamil Tigers written by Christopher L. Corley is most enlightening. The Tigers' apparent demise, as Corley argues right from the start, had more to do with the offensive launched by the Sri Lankan military in 2008 2009 than with any measure to block the organization's financing operations. The listing of the Tigers as a terrorist organization by foreign governments, including Canada's in 2006, made fundraising more difficult for the Tigers, especially from the diaspora. …

Compliance with international regulation on AML/CFT: the case of banks in Lebanon

PurposeThe purpose of this paper is to highlight and analyze the experience of banks operating in Lebanon in their compliance with international regulation on anti‐money laundering and the counter‐financing of terrorism (AML/CFT). The paper addresses the compliance policies by presenting a case study of the experience of the Lebanese banking sector in achieving a global anti‐money laundering strategy.Design/methodology/approachLebanon has been achieving its AML/CFT procedures by following a combination of three approaches: abiding by the recommendations of the international body in charge of regulation namely the Financial Action Task Force on the laundering of money (FATF); cooperation among countries in the form of mutual agreements, assistance and treaties developed by various conventions; and personal unilateral initiatives. After presenting the sources of deposit growth in Lebanese banks and highlighting the uses of funds, the paper uses a chronological approach to analyze the compliance of banks, central bank and legislators with international regulations governing the financial and banking systems, and addresses the latest developments concerning the Lebanese banks' coordination and cooperation with international regulators and governments, especially on FATF recommendations and international sanctions.FindingsThe paper presents evidence on the effective anti‐money laundering domestic initiatives and sheds light on the positive international regulatory assessment of these initiatives, as well as the favorable view of the Lebanese banking sector that has kept it outside the current FATF list of countries with AML/CFT deficiencies.Originality/valueThe value of this paper is to present a case study for bankers and regulators on strategies to comply with AML/CFT.

Financial Inclusion and Financial Integrity: Aligned Incentives?

► Globally financial inclusion and anti-money laundering are viewed as complementary. ► Many new users of formal financial services also use informal financial services. ► In given cases transparency can feature in the client trade-off. ► The alignment can fail where clients are concerned about increased transparency. The Financial Action Task Force embraces financial inclusion as complementary to anti-money laundering and counter-terrorist financing, as it enhances transparency. This support is based on the premise that the increased use of formal financial services leads to a reduction of usage of informal services. We present evidence on eight African countries that both are not negatively associated. Moreover, informal employment and cash preference reduce the inclination to use mobile financial services. If an increase in transparency acts as disincentive to use formal services, the alignment of financial inclusion and integrity will fail.

Power Politics In Policymaking: The Anti-Money Laundering Act Of The Philippines

The Anti-Money laundering law (AMLA) is a financial regulation enacted mainly because of external demand, as the Financial Action Task Force (FATF) called on the Philippine Government to comply with the Anti-Money Laundering (AML) regime. The FATF not only summoned the Philippine Government, but also determined the shape and content of the AMLA by requiring the institutional policy actors to conform to the global standards. Thus, the FATF exercised direct powers — agenda setting and decision making — in persuading the Philippine Government to enact the law. The institutional policy actors were impelled to prioritize the consideration and deliberation of the financial regulation (agenda setting) and compelled to enact and rework the content of the policy to conform to the FATF standard within a time frame (decision-making). The FATF’s use of direct powers was made possible and reinforced by the context-shaping power of the prevailing financial structure, specifically, the establishment of the AML regime. Context-shaping bound the institutional actors to enact the policy because of the prevailing AML regime established by the FATF. As the context-shaping power underscored the exercise of the agenda-setting and decision-making powers, the lawmaking experience that created the AMLA highlights the employment of the different dimensions of power as well as the contemporary dynamics in the global financial structure vis-a-vis the policymaking process.

Anti-money laundering recommendations for cash-based economies in West Africa.

Money laundering can boost corruption, worsen poverty, and bankrupt vulnerable financial institutions. In view of this, a study was conducted amongst the banks in West Africa, in cash-based economies, with the objective to ascertain the level of their Financial Action Task Force implementation. The study found that the implementation of the Financial Action Task Force recommendations in these countries was at different stages due to these countries being cash-based economies. The majority of these countries have anti-money laundering legislation but lack the capability to monitor and counter money laundering activities. This may be ascribed to a lack of adequate resources, expertise, investigations and prosecution capabilities. Some amendments to the Financial Action Task Force recommendations are proposed to incorporate cash-based economies in order to effectively combat money laundering.

Phishing in the world wide web ocean : Roestof v Cliffe Dekker Hofmeyr Inc - a case of cyber laundering through an attorney's trust account

Money launderers are always exploring new channels to clean their ill-gotten gains. The attorney's trust account is especially attractive to persons, or organisations, that seek to launder money. As a result, the Financial Action Task Force (FATF) has included lawyers amongst other professionals who are regarded as targets in complex money laundering schemes. In Roestof v Cliffe Dekker (Roestof) a trust account of an attorney was transformed into an instrument of crime and manipulated in pursuit of a criminal purpose. This crime was in the process hidden behind the veil of credibility which attaches to the trust account. Attorneys' firms have vast amounts of money in their trust accounts. They must be heedful, on the one hand, of not becoming victims of money launderers as a result of phishing schemes and, on the other hand, they must be alert to the fact that their accounts may be used as one-stop laundromats to clean the money. In this article the behaviour of two attorneys will be discussed: the one attorney, Roestof, whose money was fraudulently transferred out of his Absa Bank private account, and Adriaans, the other, a director at the time of Cliffe Dekker, who caused the money to be transferred to the cyber launderer. The article then further examines the court's failure to discuss the conduct of the attorneys in relation to suspicious and unusual transactions and includes recommendations as to how attorneys can put safeguards in place to avoid becoming victims. In Roestof, an amount of R350 000 was fraudulently transferred out of the plaintiff's personal account, and R200 000 thereof was cleaned via the trust account of the defendant firm. One of the directors of the firm was led to believe that the firm was receiving payment of a debt due to one of its clients. It was the client who used the attorney firm's trust account as a conduit to decontaminate the criminal proceeds of the phishing scam and caused the onward transmission of the money to another party. Attorneys need to be much more watchful to avoid becoming victims of phishing schemes and be much more alert to the fact that there are criminals who may masquerade as clients, who will utilise their accounts as devices to clean their ill-gotten gains.

International anti‐money laundering regulation of alternative remittance systems

PurposeThe purpose of this paper is to examine the recommendations of an influential international advisory body, the Financial Action Task Force (FATF), towards regulation of Alternative Remittance Systems (ARSs).Design/methodology/approachThe research design is a comparative analysis of Afghanistan and the United Arab Emirates, using available FATF documentation and external sources.FindingsThe analysis shows that FATF is right in pointing out that ARSs are useful vehicles for criminals to move operational expenses and launder the proceeds of their crimes. However, based on the cases of Afghanistan and the United Arab Emirates (UAE), it is argued that FATF's main approach of seeking to integrate these informal, traditional systems into the sphere and regulations of the formal banking system can be ineffective and even counterproductive in developing countries. Rather than taking a genuinely risk‐based approach, all ARS operators are required to be registered or licensed, conduct Customer Due Diligence (CDD) and fill out Suspicious Transaction Reports (STRs), just like commercial banks.Research limitations/implicationsThe impact of mandatory registration and requiring CDD and STRs has been negligible in Afghanistan and the UAE. Therefore, the article calls for new approaches to control money laundering in ARSs.Originality/valueThe paper is the first independent, comparative case study analysis of FATF regulations and implementation. It illustrates the limited knowledge/research in the field, and the inherent limitations of the current regulatory approach.

Laundering Pirates?: The Potential Role of Anti-money Laundering in Countering Maritime Piracy

Officials only recently have begun considering the use of financial investigative techniques, especially anti-money laundering (AML) tactics, in counter-piracy efforts. Europol and INTERPOL are attempting to establish coordinated law enforcement approaches to the problem of piracy, while the Financial Action Task Force on Money Laundering has generated early research on the possible use of AML in particular. Based on an analysis of the evolution of the AML regime more broadly, we suggest that a financial law enforcement approach, on paper, could be a valuable additional tool in countering piracy. To date, however, two obstacles have limited the wider acceptance of those tools. First, until very recently, no ‘norm entrepreneur’ has stepped forward to make financial investigative tactics a central tool in counter-piracy efforts. Secondly, while ‘following the money’ has much potential as a means of fighting piracy, we still know too little about the on-shore side of piracy to put those tools to use.