The US Treasury’s Financial Crimes Enforcement Network (FinCen) has named Banca Privada de Andorra (BPA) as a “primary money laundering concern.”

FinCen said the bank based in the tiny European state relied on various methods to move funds including false contracts, mischaracterised loans, over- and under-invoicing and other trade-based money laundering schemes.

Trade-based money laundering
One of the trade-based money laundering methods described by FinCEN contemplates the activities of a high-level manager at BPA Andorra who accepted bribes in exchange for processing bulk cash transfers for another third-party money launderer, Gao Ping.

Ping acted on behalf of a transnational criminal organisation engaged in trade-based money laundering and human trafficking and established a relationship with BPA to launder money on behalf of this organisation and numerous Spanish business people.

Shell companies
Through his associate, Ping paid exorbitant commissions to BPA bank officials to accept cash deposits into less scrutinised accounts and transfer the funds to suspected shell companies in China.

Spanish law enforcement arrested Ping in September 2012 for his involvement in money laundering.

A detailed FinCen news release on BPA can be found here

FinCen’s Notice of Finding against BPA can be found here

FinCen’s Notice of Proposed Rulemaking in respect of BPA can be found here