Top 5 Ways Used by Dokolo to Bypass Watchlist Screening

“The greatest trick the Devil ever pulled was convincing the world he didn’t exist.”

 — Charles Baudelaire

Did you know that Sindika Dokolo used his noble mission to reclaim African art and his political influence as a front for laundering dirty money into global financial systems?

Let’s explore Dakolo’s journey from cultural advocate to financial offender with us.

Find out the secret web of his deceitful acts and how he bypassed the major watchlist screening checks and regulatory measures as politically exposed persons.

From Art Gallery To Secret Vaults: Tracing Sindika Dokolo’s Financial Misconduct

Sindika Dokolo is a Congolese businessman and art enthusiast best known for his endeavor and efforts to reclaim African arts through the Sindika Dokolo Foundation.

He accumulated one of the greatest assemblages of African art, campaigning for the repatriation of cultural collections back to Africa.

However, Sindika Dokolo’s efforts in the revival of cultural art have been tainted with serious corruption charges in Angola while exploiting global watchlist search parameters.

Sindika Dokolo also used his political influence to launder millions of dollars, leaving one wondering as he reveals how crucial flaws in the international financial system with inefficient PEP regulations and poor watchlist matching process promote his laundering activities without any legal action.

He was 48 when he passed away on October 29, 2020, in a free-diving accident in Dubai, United Arab Emirates.

Every Masterpiece Has A Shadow!

According to the International Consortium of Investigative Journalists (ICIJ), his story takes a rather grave twist when one considers his business operations and financial dealings.

The combination of financial fraud and cultural advocacy is the portrait of a man who skillfully concealed his illegal actions behind his love of business and the arts.

Unsurprisingly, Isabel Dos Santos, the richest woman in Africa, and eldest daughter of former president-dictator Eduardo Dos Santo is married to Sindika Dokolo, and this way his profile is considered as politically exposed persons facilitating various ways to launder illegal money without any hurdle.

“In many of these authoritarian places, economic power derives from political power. The moment you lose political power, you’re vulnerable all over the world”

-Oxford professor Ricardo Soares de Oliveira

This connection provided him with access to her vast resources and political influence, enabling him to counter allegations of fraud, embezzlement, and money laundering in Angola.

The International Consortium of Investigative Journalists (ICIJ) based on over 715,000 confidential financial and corporate documents, revealed in January 2020 that Dos Santos and her spouse Sindika Dokolo have connections to over 400 companies and subsidiaries across 41 nations.

The consortium claimed that Dos Santos & Sindika Dokolo made a “fortune by taking a cut of Angola’s wealth” in its report on the documents, known as the “Luanda Leaks.”

Let’s discover some of the renowned strategies he uses to gain money through illegal sources and successfully convert it into clean money.

5 Ways Used By Dokolo To Bypass Watchlist Screening

The story of Dokolo has very interesting and eye-opening aspects for global regulators that show how he conducted money laundering while avoiding various legal requirements and watchlist monitoring protocols. The most prominent ways include:

Utilize Multiple Offshore Accounts

Offshore accounts are the ultimate game of ‘catch me if you can!

Dokolo and Isabel Dos Santos transferred millions of dollars through various offshore accounts in secrecy jurisdictions such as Dubai.

These accounts provided a significant amount of secrecy, and thus it became difficult for the regulators to track the wealth back to the original unlawful sources.

A well-publicized instance is where “$38 million wired to a Dubai-based shell company after Dos Santos lost her position– as the head of Sonangol; the Angolan state-owned oil and gas company”. ​

The rules that helped them was a strict non-disclosure policy by the Dubai banks, where the actual source of the funds could not be traced hence providing a basis for avoiding scrutiny by regulators.

Create Complex Ownership Structures

Money-making trails tangled more than a mystery novel!

The two were very smart in ensuring that several layers of veil were placed to obscure the real financial operations that they were carrying out.

Dos Santos and Dokolo employed a web of over 400 companies and subsidiaries in 41 countries.

These entities also operated from jurisdictions with poor transparency regimes such as Malta and Mauritius and they were able to mask the ownership and source of their funds.

One of the publicized deals saw Sonangol, a state oil company of Angola, sell 40% of its shares in Esperaza Holding BV to Exem Energy BV a company owned by Dos Santos and Dokolo.

This transaction was however later concluded to have been corrupt thereby amounting to about $99 million, by the Netherlands Arbitration Institute​.

Misappropriate Use Of Diamond Revenues

Diamonds stay forever, but their revenues can vanish in a flash!

Dokolo and Dos Santos made deals with various state-owned diamond companies like Sodiam; where Sodiam sold diamonds at very low prices to companies that were controlled by them.

They would then retail the diamonds at full market price leaving pockets full of cash with a handsome difference.

In one of the specific investments, Sodiam acquires shares in De Grisogono a Switzerland-based luxury jewelry company for $120 million.

This purchase was financed by loans offered by Sodiam and secured by the Angolan state; conversely, most of the profits were channeled to companies belonging to Dokolo and Dos Santos.

Strong Political Influence And Corruption

Who needs magic when you have political influence and authority for corruption?”

Leveraging his powerful political connections was one of the primary strategies he employed to launder millions.

As he was married to Isabel Dos Santos, Dokolo managed to receive good terms of the contracts, secure multiple favorable deals, and, thus, escape from strict international regulation.

Since they were defined as politically exposed persons (PEPs), the requirements of Customer due diligence were supposed to apply to them, however, failures in enforcing these rules allowed the two to incorporate considerable loopholes.

They also gained control over chief executive positions in most of the Angolan public corporations, making it easy for them to manipulate and bury their corrupt practices.

Purchase Of Luxury Real Estate

Buying mansions abroad, because who needs banks to keep money safe?

Dokolo and Isabel Dos Santos aimed most of their efforts at buying luxurious properties in Europe and Africa.

They turned illegal funds into tangible assets by acquiring expensive real estate. Such operations are informal and many of them involve the use of various financial instruments, as well as shell companies situated in the tax havens.

New methods and different techniques were reportedly employed to buy properties in Portugal and the UK and thus it was challenging for the regulators to follow the money back to Angola’s state funds.

The former “princess” of Africa and her husband are by no means bankrupt. They “bought a lavish house on a private island in Dubai, another one in London, and a $35 million yacht.”

A prime illustration of their fraud is the acquisition of stocks in the Portuguese energy company Galp. In 2006 the shares were purchased by Dokolo for as low as $15 million while its market value was discreetly $99 million. This was made possible through a premium setting where a short-term interest-free loan from Sonangol, the Angolan state oil company was arranged. These fraudulent transactions not only denied Angola considerable revenue but also depicted how state funds were utilized for the benefit of the individuals.

So till now, we have explored how Dokolo and his wife utilized various complex techniques to earn and convert their illegal assets into legal ones.

Let’s take on a journey to see the regulatory response by the State and various officials.

What Regulatory Measures Did The Angolan Government Take?

Government representatives in Angola informed ICIJ “that they are looking into claims that Dos Santos and her partner Sindika Dokolo stole and laundered hundreds of millions of dollars from the state’s diamond and oil trading businesses.”

The most prominent example includes a $38 million payment made by Sonangol to a Dubai-based business owned by a Dos Santos partner in November 2017. The transfer was mandated just hours after the president of Angola dismissed her from her position leading the country’s main oil company.

The “authorities claimed that her father’s government had given her companies state contracts worth over $1 billion”___ against what was actually allocated for those contracts.

Later on, Angolan authorities blocked their various assets earned from illegal means to keep state funds secure.

Interestingly, the legal efforts taken now have brought to light a substantial gap in regional and international regulatory measures, which has permitted the growth of their illicit activities.

Let’s take a quick look at those inefficient regulations where Western financial bodies ease their ways to exploit the systems.

Regulatory Gaps: Evading Legal And Regulatory Scrutiny

Dokolo and Dos Santos took greater advantage of gaps in the laws and regulations. Despite multiple red flags, they were able to engage reliable Western financial and consulting companies, who didn’t pay attention to or deliberately concealed suspicious actions.

The New York-based ICIJ said its findings illustrate “how the system of multilateral regulation fails to allow professional services firms to serve the powerful with almost no questions asked”.

While the ICIJ took over eight months and more than a hundred reporters to carry out the investigation, it identified that Sindika Dokolo and Dos Santos, with the help of their Western advisors, moved as much as hundreds of millions of dollars in several offshore companies and then to different kinds of assets like mansions and large enterprises. ” the ICIJ’s Ben Hallman said to Al Jazeera.

Unveiling Truths

Did you know that the ICIJ investigation revealed that Western consulting firms like PwC, McKinsey, and Boston consulting group were “apparently ignoring red flags” while helping them to transfer the public assets?

Regulators around the globe have nearly blinded themselves to the important role that Western professionals portray in facilitating an offshore industry that fuels money laundering and siphons trillions of dollars from the government’s treasury,” the report mentioned.

The document set also consisted of the letters that were partially deleted and in which consultants looked for opportunities to establish the accounts with nontransparent bank accounts. By creating businesses that concealed the true ownership of assets and providing tax avoidance advice, these corporations helped Dokolo evade regulatory attention.

As we’ve learned till now, ‘the International Consortium of Investigative Journalists— released information on the possible locations of all the shell companies spreading in 41+ countries — being part of the network of Dos Santos and her husband; Sindika Dokolo, money laundering networks.’

Their network mainly functioned in countries where institutions were bound to adopt strong anti-money-laundering regulations created to’ screen, detect, and completely mitigate the dirty money operations.’ With all these strict measures still they succeeded in staying hidden for a long time.

“One of the keystones of these anti-money laundering policies is’ knowing your customer (KYC)’ — it seems that banks in the ‘Dos Santos network either didn’t know who they were working with’ or didn’t ask the right questions regarding the money’s origins.”

This leads to the point that major and reputed financial institutions did not complete proper KYC and CDD on Sindika Dokolo leading to serious gaps in identifying and stopping Sindika Dokolo’s money laundering activities.

This was because his accounts had missed out on AML screening for politically exposed persons (PEP) and had no regular monitoring of his other transactions. Thus, institutions now require sophisticated compliance solutions capable of delivering extensive and constant monitoring.

That is where AML Watcher can be advantageous to such institutions, as it provides a very reliable AML watchlist screening service. This solution includes a comprehensive database with coverage of global sanctions lists, PEP lists, and other high-risk entities.

It ensures real-time monitoring and updates, enabling institutions to detect high-risk individuals promptly. The customizable screening parameters allow for tailoring risk assessments to specific regulatory requirements, while automated alerts ensure immediate action can be taken on potential threats.

Additionally, detailed audit trails and reporting tools support regulatory compliance and

transparency, making it harder for individuals like Dokolo to bypass scrutiny unnoticed.

Let’s review it in detail how does it work

How AML Watcher Assists Financial Institutions To Stay Compliant In Situations Such As Sindika Dokolo

AML Watcher offers a robust suite of tools and options to protect financial companies from further violation of AML rules, especially when it comes to sharing PEP list screening for individuals such as Sindika Dokolo.  Here’s how AML Watcher’s PEP Screening parameters can be instrumental:

 1. Comprehensive PEP Screening

AML Watcher offers screenings against the global politically exposed persons databases for due diligence. This entails the detection of persons in leadership or significant roles in public organizations and their acquaintances.

Thus, by knowing the PEPs & RCAs such as Sindika Dokolo, financial institutions can perform high-risk checks on their activities to minimize money laundering by politically influenced individuals.

 2. Ongoing Monitoring

The incorporation of continuous monitoring maintains the identification of modifications in the status, actions, and connections of PEPs that help to reduce PEP risks on time. This also keeps AML compliance levels high and mitigates future failures from occurring.

3. Enhanced Due Diligence

AML Watcher performs advanced due diligence methods that include a thorough examination of financial history, wealth sources, and business relationships for high-risk individuals.

This level of focus is important for such persons as Sindika Dokolo who might use his political connections to conceal unlawful actions. Through EDD, it is made possible to identify their real business deals and associations.

4. Advanced Analytics and Risk Scoring

AML Watcher applies analytical evaluation to determine the risk factors that pertain to PEPs such as political risk, geographical risk, and other risk factors.

By assigning a risk score to individuals like Sindika Dokolo, financial institutions can better focus their monitoring efforts and direct resources toward high-risk instances.

 5. Reduce False Positives

Our proprietary algorithms, custom risk parameters, and improved control over data show accurate results while reducing false positives. It shows real-time notifications on any suspicious activities and generates quick alerts for the compliance teams to take proactive action.

6. Integration With Global Watchlists

AML Watcher offers separate global watchlists and detailed sanctions databases so that any PEPs involved in criminal business are reported immediately.

Compatibility with the extensive watch lists implies if Sindika Dokolo or any related people are under any international banned list, then the financial institution is aware and has to act accordingly.

7. Audit Trail and Compliance Documentation

Documented records to ensure a clear track and account of all activities of the organization as well as compliance measures for the regulators’ checks.

In this case, having a deliberate audit trail assists the financial institutions in showing that they complied with the AML regulations and that their decision-making when it comes to a pep search such as Sindika Dokolo was proper.

To conclude, under the disguise of his heritage conservation activities, Dokolo with his spouse Isabel Dos Santos were masterminds behind a complex web of money laundering operations.

Through a network of offshore corporations, complex financial structures, and offshore bank accounts, they stole billions of state money to lead luxurious lives and invest in upscale properties.

These smart strategies helped both to avoid the attention of the regulators and also highlighted the vulnerabilities in global anti-money laundering frameworks​.

In the future, financial institutions need to utilize sophisticated software like AML Watcher, which encompasses a deep PEP check, customized watchlist checks, real-time monitoring, tailored risk scoring, and up-to-date structured 60,000-plus databases.

AML Watcher’s watchlist screening solution is quite useful for any financial institution that has a goal to adhere to international and domestic AML standards.