29/07/2020
MONEY LAUNDERING PNG STYLE: PAYPAL
We all know PayPal. It’s the international partner of choice for SMEs in e-commerce. But did you know that using PayPal as a PNG business is probably breaking the law? The Arua Report investigates.
PayPal is a great service and in PNG we can use it to buy goods and services internationally. It connects to our PNG bank accounts and takes money out, sending it around the world. That’s all legitimate.
But PayPal does NOT allow a PNG based company to use its service to receive funds into a PNG bank account. There are a few reasons for this, but the main one cited by PayPal is that PNG’s anti-money laundering laws are not secure enough for PayPal to operate. So it happily takes money from a PNG bank account, but will not deposit money INTO a PNG bank account.
Why does this matter? Glad you asked.
Let’s say there is a PNG registered business, let’s call it Go Funding Me, and let’s say it is a local company owned by an Australian expatriate and a PNG national. A local company is required by Bank of Papua New Guinea to transact all business through a kina-denominated account in a PNG domiciled bank. Offshore accounts must be approved, are only allowed for certain industries, and all transactions must be documented and approved by Bank of Papua New Guinea.
But say the Australia expatriate has an Australian bank account. They could connect this account to Go Funding Me’s PayPal account and use it to receive funds paid by Papua New Guinean donors. So Go Funding Me could take Papua New Guinean’s money, which these Papua New Guinean’s wish to donate to a cause in Papua New Guinea, but the money would be deposited via PayPal to the account in Australia.
And this would bypass the Bank of Papua New Guinea’s controls over foreign exchange transactions, because none of these people will be filling in the forms required to track these transactions for currency management and anti-money laundering purposes.
Let’s say Meri wishes to fund a food distribution charity, called Feed Me Now, and wants to contribute K20. She would use her PayPal account to send the money to Feed Me Now through Go Funding Me, probably thinking the money would stay in PNG. But this money would instead go to its PayPal account in Australia.
What happens when Feed Me Now wants the money that has been donated?
Easy. And this is where the fun begins.
Transferring the money from the bank account in Australia, where the funds are being collected, would require paperwork if the amount is over $10,000 – Australia’s anti-money laundering limit. It would also incur transaction fees and exchange rate charges, which means Feed Me Now is likely to get funded quite a bit less than if the money had been collected in PNG.
But wait – there’s a simple, if not exactly legal, solution.
Instead of transferring the money back to PNG, Go Funding Me could instead use money the expatriate already had “trapped” in PNG to pay Feed Me Now. The expatriate could pay Feed Me Now with the money in their personal PNG bank account, which had been earned through other business enterprises, and leave the money in the Australian bank account. That way Feed Me Now gets all the money it should, there are no transaction fees, and everything is great. Right?
Wrong. Technically we have just laundered money between PNG and Australia using PayPal as the interchange.
The expatriate is able to access the money in Australia in Australian dollars, and without paying any of the fees or charges they would have paid to send it offshore from PNG. And there is no record of the kina leaving the country as none of the Meri’s contributing to the fund have filled in any of the required paperwork. The Australian account is not registered with Bank of Papua New Guinea, so it can’t be monitored, and none of the money can be traced. Plus, the expatriate just managed to transfer a whole wad of cash to Australia while incurring no personal transaction fees or charges, also beating Bank of Papua New Guinea’s transfer limit of only K5000 per week.
Brilliant.
This is not a one-off situation. There are now three PNG-approved payment gateways that could be used, offered by BSP, Kina and Westpac, but people are still using PayPal and offshore accounts to do business in PNG.
Arua Report has seen bilum sellers, media companies and other SMEs doing the same thing.
Most probably don’t realise what they are doing breaches PNG’s anti-money laundering rules, or that they put PNG at risk of being grey listed in its international review next year. And grey listing is a very bad thing, that stops legitimate PNG companies doing business internationally.
But ignorance is not an excuse under the law, and we suspect most of these people realise they’re not quite doing the right thing.
Next time someone asks you to use PayPal to buy goods or services in PNG – as opposed to offshore, which is perfectly legitimate – have another think about what you are doing. It might be charity but that doesn’t make money laundering OK.
The Arua Report cannot be bought (or intimidated).