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Procedia Computer Science 00 (2022) 000–000
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Procedia Computer Science 207 (2022) 2454–2463

26th International Conference on Knowledge-Based and Intelligent Information & Engineering

Systems (KES 2022)

The Proposed PDCA Model to Counter Money Laundering

Chi-Cheng YANGa, Hsuan CHUANG b, Da-Yu KAO b,*
Department of Foreign Affairs Police, Central Police University, Taiwan
a

Department of Information Management, Central Police University, Taiwan

b

Abstract

The failure to investigate money laundering cases is most commonly due to a lack of crucial cooperation between public sectors
(supervisory authorities, law enforcement agencies, or the police) and private sectors (financial institutions or banks). Global
public sectors require a consistent and sustainable alignment of all cash flow activities. The success of the complex anti-money
laundering transaction is determined by analytic skill sets in Public-Private Partnerships (PPP). Through the PPP, public sectors
can use the resource provided by private sectors. For example, the consultant in the banks can negotiate with the police to
investigate money laundering cases. This study proposes a practical Plan-Do-Check-Act (PDCA) management cycle model for
supporting these activities processes in the law enforcement community. The PDCA model has proven a practical methodology
for reducing the complexity of anti-money laundering.
© 2022 The Authors. Published by Elsevier B.V.
© 2022 The Authors. Published by ELSEVIER B.V.
This is an open access article under the CC BY-NC-ND license (https://creativecommons.org/licenses/by-nc-nd/4.0)
This is an open access article under the CC BY-NC-ND license (https://creativecommons.org/licenses/by-nc-nd/4.0)
Peer-review under responsibility of the scientific committee of the 26th International Conference on Knowledge-Based and
Peer-review under responsibility
Intelligent Information of the scientific
& Engineering committee
Systems (KES 2022)of the KES International
Keywords: Money Laundering, PDCA Model, Public-Private Partnership, Law Enforcement Agencies, Proxy Bank
Accounts, Cash Flow Reconstruction

1. Introduction

1.1. Money Laundering Transactions

* Corresponding author. Tel.: +886-3-328-2321*4224; fax: +886-3-328-2321.

E-mail address: dayukao@gmail.com

1877-0509 © 2022 The Authors. Published by ELSEVIER B.V.

This is an open access article under the CC BY-NC-ND license (https://creativecommons.org/licenses/by-nc-nd/4.0)
Peer-review under responsibility of the scientific committee of the KES International

1877-0509 © 2022 The Authors. Published by Elsevier B.V.

This is an open access article under the CC BY-NC-ND license (https://creativecommons.org/licenses/by-nc-nd/4.0)
Peer-review under responsibility of the scientific committee of the 26th International Conference on Knowledge-Based and Intelligent
Information & Engineering Systems (KES 2022)
10.1016/j.procs.2022.09.303
 Chi-Cheng YANG et al. / Procedia Computer Science 207 (2022) 2454–2463 2455
2 C. C.Yang et al./ Procedia Computer Science 00 (2022) 000–000

Criminals often recruit money mules to help launder proceeds from online scams, frauds, human trafficking,
drug trafficking, or crimes. Money mules will move funds on behalf of someone else for illegal profits. They
transfer illegally acquired money in Taiwan through multiple bank accounts, virtual currency, or money service
businesses. Moreover, they often add layers of distance between crime victims and criminals. When the fraudulent
money was deposited, the proceeds were remitted to various bank accounts in Figure 1. They were subsequently
layered through many proxy bank accounts, making it harder for the police to trace money trails accurately. It forms
an extensive network of proxy bank accounts [6].

Figure 1. Money laundering transactions via bank accounts

2456 Chi-Cheng YANG et al. / Procedia Computer Science 207 (2022) 2454–2463
C. C.Yang et al./ Procedia Computer Science 00 (2022) 000–000 3

(1) Placement
In order to infiltrate illicit gains into the legitimate financial system and avoid attracting attention, the smurfs
usually divide criminal proceeds into small-scale through trading many times. Furthermore, to avoid detection by the
surveillance system, the smurfs trade in a different approach, for example, certificate of deposit, demand deposit, and
foreign currency changing.
(2) Layering
Money mules create complex layers of financial transactions from the source to various accounts. It makes it
the police challenging to track the sources of money. Most money launders use proxy structures to confuse the fund
trace through complex layering schemes. These schemes consist of a complex chain of proxy bank accounts. The
funds from different users are mixed within the proxy bank accounts, which makes tracing funds from a particular
customer.
(3) Integration
The smurfs integrate funds in the ostensibly legal form, try to make money enter the legitimate economic
system again, and attempt to use illicit gains legally.

1.2. AML/CFT Guidelines

Effective information sharing is crucial between public and private sector authorities in the Anti-Money
Laundering/Combating the Financing of Terrorism (AML/CFT). These victims were directed to deposit lots of
money into proxy bank accounts controlled by online fraud criminals. This study outlines how Public-Private
Partnerships (PPP) can support AML/CFT efforts to combat financial crimes in Taiwan. Public sectors are planning
to make better use of financial crime investigation intelligence for the comprehensive prevention of money
laundering and terrorist financing. The PPP role should encourage the various information exchange of typologies,
trends, and patterns on suspects [5]. PPPs can improve financial crime investigation, as information sharing
enhances analysis and prosecution.
To prevent the bank's financial services from being used for money laundering or terrorism financing, banks must
confirm that those customer transactions are reasonable and match the customer's identity. In money laundering, a
proxy bank account uses others' identities and escapes an arrest. Anti-money laundering and anti-terrorism financing
guidelines in Taiwan are listed below [12]:
(1) Follow the relevant laws and regulations
AML/CFT matters are processed under the financial sector account-opening agreement or the applicable law and
regulations.
(2) Monitor transaction
It is necessary for enhanced transaction monitoring for more than NT$500,000 or the equivalent value in foreign
currency.
(3) Identify suspected money laundering
Suppose some funds are often allocated to multiple different accounts without proper excuses. Those transfer
funds between accounts may be considered money laundering. The private sector will check the following:
 whether the account transactions are consistent with the customer’s identity, income, scale, and nature of
business operations;
 whether the trades are reasonable;
 whether the source of funds is legitimate to identify suspected money laundering or terrorism financing.
(4) Request identity proof
Some suspicious anonymous, dummy, or proxy bank accounts use pseudonyms or shell corporations. If necessary,
banks may request that customers confirm their proof of identity.
(5) Explain the fund sources
From January 1, 2015, banks may request that customers present transaction-related supporting documents to
reduce the risk of money laundering and terrorism finance. Banks can ask customers to explain the source of funds
and intended use.
(6) Suspend or decline transactions
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A customer does not provide relevant information and explain the nature of the transaction or the purpose of the
funds. Banks may suspend or decline transactions under the applicable contracts, laws, and regulations.

1.3. Challenges to Counter Money Laundering

The fight to prevent criminals or money launderers from utilizing the financial system has posed some challenges
to plague the financial system's health [13].
(1) Online transferring funds
Money laundering group often uses the best efficiency and conversion method to take out the victim's money.
They also operate online banking APPs with overseas IP addresses or utilize VPNs to transfer funds. The whole
money-laundering transactions are completed in less than 30 minutes in Figure 1.
(2) Layering schemes
The police can quickly monitor the first warning account. Then money mules often use the third cash account to
withdraw deposits. More tiers can reduce the chance of being arrested. It can also confuse the police and the bank to
tracking the victim's money. Investigators will also face the difficulty of effectively arresting the money mule who
directly withdraws if the victim's money is transferred or withdrawn from the second or third tier.
(3) Public-private partnerships
When money laundering facilitates myriad financial flows to prevent sanctions, numerous countries have
established PPP initiatives. There is a unique dynamic to sharing information and countering financial crime
between the police and the banks. Public and private sector stakeholders share knowledge, skills, and abilities on
critical money laundering risks. Open dialogue and trust can contribute to PPP implementation [2]. That can be
inherently complex and complicated around the world. Any PPPs can share actionable money transfer information
and focus on establishing a meaningful dialogue on detecting, monitoring, or blocking proxy bank accounts.
Jurisdictions can adapt these methodologies to suit their domestic circumstances. The police can quickly respond by
disrupting these complicit, flexible, and adaptable actors [6].
(4) Crucial leadership for the uncertainty
One of the most significant challenges and opportunities in the police is to cope with today's uncertainty. It is
even more important to build leadership and manage tomorrow's unending uncertainties. PPP implementations turn
future expectations into policing processes. The following categories are crucial for leadership effectiveness in banks
[9, 10]:
 Behave with the consistent aims;
 Inspire a shared, achieved vision;
 Encourage teamwork and raise expectations to follow or challenge the process;
 Build enthusiasm by recognizing and celebrating achievements.
This paper is organized as follows. In Section 2, the cash flow reconstruction method (functional, temporal, and
relational analysis) investigates the money laundering case. The PDCA model, the TTP approach, and future action
for countering money laundering are presented in Section 3. The conclusions are given in Section 4.

2. Cash Flow Reconstruction from Money Laundering Investigation

Reconstructing the events relating to money laundering includes temporal, functional, and relational analysis of
available data [3]. Money laundering reconstructions of cash flow can help answer any questions in an investigation
at a given time. The reconstruction tries to understand money laundering better using available transaction records.
That reconstruction can determine how and when the criminals transferred their money and which accounts were
involved [1].

2.1. Functional Analysis in Suspicious Money Laundering Transactions

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Functional analysis determines how a particular money laundering works and how it was transferred to gain a
complete understanding [3]. Since criminals often use financial institutions for money laundering, in order to
prevent their crimes, financial institutions should be obliged to report suspicious transaction reports because of the
PPP strategy when they discover that they have committed money laundering crimes. According to the Taiwan
Ministry of Justice Investigation Bureau (MJIB) statistics, the numbers of suspicious transactions reported by
financial institutions are in Figure 2.

Figure 2. The suspicious transactions in Taiwan

During the money-laundering investigation, the Taiwan Criminal Investigation Bureau (CIB) discovered financial
money laundering of layering schemes [7, 12].
(1) Money mules collect proxy bank accounts to avoid arrests
They aim to confuse and delay the investigations from tracing the money back to the criminals through layering.
In money laundering schemes, criminals may place the cash into multiple bank accounts using structured deposits
and then forward these funds to money mules. The collected proxy bank accounts in Figure 1 are divided into the
first warning (placement), second transit (layering), and third cash (integration) accounts. As far as money
laundering groups are concerned, they have tried to extend the period of the proxy bank accounts as much as
possible.
(2) Criminal proceeds are transferred or collected by money mules
In Figure 1, the money laundering group used the first warning account to collect the victim's money, which was
transferred to the second transit account through online banking. Then, it was immediately transferred to the third
cash account again. The money mules use the nearby ATM to withdraw cash and avoid bank deposits in fraud
schemes. Funds are transferred to criminals physically or electronically. Most criminal activities generate illicit
proceeds held in bank accounts. Unknown customers usually sell their identities as proxy bank accounts, which may
be used for laundering funds. These accounts are used to transfer money to different layers. It varies depending on
the types of predicate offenses.

2.2. Temporal Analysis from Proxy Bank Accounts

The police can create a timeline to gain a more straightforward overview of events relating to money laundering.
Analyzing temporal trails can find periods of highest activity and identify the relevant patterns [3]. Due to the
limitations of investigation technology, it is difficult for the police to detect suspicious money transfers. Banks can
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work with the police to block illicit cash flows and cut off money laundering channels. It is essential for two or more
banks with shared interests to stop money laundering. The following information can help the police find the money
laundering group's proxy bank account and cash flow network.
(1) Joint defense/warning accounts
The victim’s money needs to be collected through the third cash account. After the police remit the first warning
account, the banks will initiate the related joint defense accounts. The police can investigate money laundering by
using big data to identify and monitor potential third cash accounts.
(2) Agreed transfer of relevant accounts
The agreed transfer account of the above-mentioned joint defense accounts is available for the follow-up tracing
of the cash flow investigation—these joint defense accounts matter in the criminal context. The police can track
down the total cash flows from the relevant accounts. The police can catch the money mules immediately when they
withdraw the deposit at the scene.
(3) Internet banking login information
Internet banking login information includes IP address, timestamps, and device records of the above account, such
as Universally Unique Identifier (UUID), Unique Device Identifier (UDID), or International Mobile Equipment
Identity (IMEI). The IP address and relevant documents are recorded if customers log in to the online banking
websites with a mobile device or computer.

2.3. Relational analysis from Money Laundering Investigation

Relational analysis can reveal a crucial relationship between any communication, transaction, or location of
people and accounts by the quantity of transferred money [3].
(1) Check the cash flow of proxy bank accounts
Many fraudulent groups take advantage of the fast transfer of Internet banking, making it difficult to trace
through layer-by-layer transactions. Banks actively cooperate with the police to investigate fraud and money
laundering, assist the police in integrating digital intelligence, provides professional consulting services, and check
the cash flow of proxy bank accounts.
(2) Link cases from related device information
Smurfs may remain the same user code, IP address, or device name in the same or different banks. The police
analyze the information collected from different banks, like audit records, access logs, and operating records of the
user. It is possible to find out the real identity of the smurfs. The police implement correlation analysis to find out
the smurf by collecting related information. The police checked the tracking information and found out the device
was possibly related to the money laundering case. Then, the police track down the information about the devices,
like UUID, UDID, or IMEI. If the device is a mobile phone, the police should investigate the mobile phone number.
As for the private sector, Internet banking apps should retain data about cookies and UUID. Therefore, the private
sector can provide the public sector with search-related information about a case.
(3) Initiate an innovative model for money laundering investigation in Taiwan
In the past, after the police received the warning account, they applied for access to the transaction details,
checked the transaction details of the account layer by layer, and finally arrested the driver who took the money.
Effectively combine the warning account and the agreed transfer account of the private sector to form a defense
mechanism, and then quickly find out the large-value currency brokers. The integration of intelligence speeds up the
time for investigation

3. PDCA Model to Counter Money Laundering in PPP

The Tactics, Techniques, and Procedures (TTP) approach can be utilized to analyze a money laundering
operation or profile a specific suspicious cash flow in PPP partnerships. The word ‘tactics’ outlines their
implementation to carry out his anti-money laundering from the beginning to the end. Feasible ‘techniques’ can be
used to achieve intermediate results. The organizational PPP approach is defined by to-do-list ‘procedures [2].’ This
section proposes a practical Plan-Do-Check-Act (PDCA) management cycle model for supporting these activities
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C. C.Yang et al./ Procedia Computer Science 00 (2022) 000–000 7

processes in the law enforcement community. The PDCA model in Table 1 has proven a practical methodology for
reducing the complexity of anti-money laundering.

Table 1. PDCA model to counter money laundering

Management Cycle Anti-Money Laundering Tactics Feasible Techniques To-do-lists Procedures
Plan Integrate and align PPP Planning and feasibility Coping with Tomorrow's
implementation around the Uncertainties
police
Do Shape and executable strategy Implementation Innovating and Integrating
through PPP implementation arrangement PPP Implementation
Check Build a cooperation pattern of Partnership relationships Initial PPP
sustained change Implementation
Performance
Act Get the administrative duties of Relationship management Evaluation PPP
PPP done flawlessly Implementation

3.1. Anti-Money Laundering Tactics

A top-down and bottom-up process is used to identify the requirements to build PPP enhancement relationships of
mutual trust by knowing the proxy bank accounts [8]. There are four key competency domains for PPP
enhancements to contribute to the success of anti-money laundering [14]:
(1) Integrate and align PPP implementation
(2) Shape an executable strategy through PPP implementation
(3) Build cooperation patterns of sustained change
(4) Get the administrative duties of PPP done flawlessly

3.2. Feasible Techniques

More details on feasible tasks at the PDCA model of PPP implementation are provided below:
(1) Planning and feasibility
 PPP project identification
 The setting of project committees
 Conceptual project structure in public sectors and private sectors
(2) Implementation arrangement
 Appointment of a particular body for PPPs
 PPP implementation arrangement
 Project implementation in a legal and regulatory framework
(3) Partnership relationships
 Project development and due diligence
 Public sector support and private sector help
 Establishment of a dispute resolution process
(4) Relationship management
 Bidding legal documents
 Relationship management and negotiation

3.3. To-do-lists Procedures

(1) Coping with tomorrow's uncertainties

Forecasting fluctuation risks is an imprecise science. Private sectors cannot read public sectors' minds. The
employees who have been flagged as notably essential personnel can be surveyed regularly to detect any adverse
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change in their commitment in good time. That also is the opportunity to address the causes of their dissatisfaction.
Refining the methodology of PPP implementation has been a familiar item on the to-do-lists. The PPP
implementation can be planned systematically, delivered efficiently, and monitored transparently through target-
setting monitoring of the money laundering procedure [11].
(2) Innovating and integrating PPP implementation
The police focus emphasizes ambiguous results. Much of the innovation in PPP implementations will be
integrating the different practices among cooperation parties. The police chiefly direct this partnership to create a
seamless alignment safeguarding financial order [13]. The proper evaluation arises immediately from the
requirements analysis. That evaluation makes choosing high arrest rates easier and proactively identifies possible
suspects. Among various failings that are associated with the executive failure of PPP implementation, some of the
most common are [4]:
 Inability to get along with others;
 Excessive narcissism;
 Inability to take action or rebound from a failure when necessary;
 Failure to keep commitments and promises.
(3) Initial PPP implementation performance
The success of a PPP implementation intervention represents the benefit and becomes critical for the value of
anti-money laundering. Clear procedures of various tasks are necessary for running a successful PPP
implementation. The policing approval may be required at several stages in the entire process. Streamlined
administrative procedures can reduce uncertainties and improve a PPP implementation's success rate.
(4) Evaluating PPP implementation
There is still no consensus among academics or practitioners about PPP implementation, which is cyclical work.
Many proxy bank accounts are concerned with the likely suspects. The reporting system in the police should cover
key proxy bank accounts that have definite relevance to a specific case and can be tracked to their usefulness. It can
become meaningful when combined with relevant information. The police can piece them all together and assess the
associated criminals through detailed examination and analytical intelligence techniques.

3.4. Future Action for Countering Money Laundering

3.4.1 Enhancing the AML Action in the Private sector

(1) Policy and coordination
 Identify the risk of money laundering through the Risk-Based Approach (RBA)
 Improving the coordinating ability in each agency
 Blockade or attach the accounts of criminal groups
(2) Preventive measures
 Know Your Customer (KYC) and check the typology of suspicious money laundering
 Ensure the preservation of the transaction record, and assure the record to be retrieved at any time
 Monitor and evaluate the third-party transactions
 Designated Non-Financial Businesses and Professions report a suspicious transaction
(3) Enhancing transaction transparency
 Have the ability to get correct and the last information
 Implement internal management and supervision of the banks
 Set efficient mechanism to check-in time whether natural person or legal person has accounts
 Set a national measure for money laundering

3.4.2 Enhancing the AML Action in the Public sector

(1) Audit the operation of illegal businesses
From the information obtained, the customers of the third-party payment service that virtual accounts
correspond to are mostly proxy companies. These proxy companies are set for charging illicit money. The police
had difficulty finding the suspects after the investigation of proxy companies. The police need to cooperate with the
Ministry of Finance and Ministry of Economic Affairs and audit the operation of the third-party payment service
and proxy companies. If finding the proxy companies do an unlawful operation, the companies should be proscribed
or punished by government agencies.
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(2) Establishing a database of warning account

The Public sector establishes the database of the warning account for the bank to inquire about the suspicious
account. For security, the banks' branches can only connect to the Intranet. Therefore, the branches ask the
headquarters, which can connect to the Internet, to inquire about the specified account.
(3) Promoting international cooperation
The government should sign conventions with other countries, and the Judiciary of each country should have
mutual legal assistance mechanism. In other words, in terms of international norms, regardless of intelligence,
judicial cases, and supervision norms, there should be a basis for cooperation and the same value basis.

3.4.3 Money Laundering Investigation in Future

Due to the prevalence of Internet banking, suspects have multiple accounts with different IDs in the same bank,
and suspects can conduct internal transactions through mobile devices to evade investigation, making it difficult for
prosecutors to trace back. Unlike the past, the new method expands the investigation of relevant suspicious
information. For example, every time a bank customer logs in to mobile Internet banking with a mobile phone, the
system will retain the device's information. By checking the possible track information, conducting correlation
analysis, and tracing the suspect's mobile phone. There may be money laundering if multiple accounts exist in the
same bank with different IDs.

(1) PPP framework of AML/CFT

Due to global differences in the legal frameworks and practical arrangements, this study considers sharing the
good Taiwan practices in developing and operating PPPs currently working in the AML/CFT area. The need to
rethink global PPP implementation is evident. Systematic PPP implementation is a sequence of activities concerning
the application of information. That is used to direct focus on implementing policing strategy. It is essential to
improve the acceptance of PPP implementation and apply the PDCA model to meet policing needs. The use of
global PPP implementation within various anti-money laundering contexts should be explored and described in
nowadays e-workplace [11]. This study highlights where the systematic development of PPP should be headed in
the future.
(2) Anti-money laundering focus of PPP strategy
In the past decade, law enforcement shifted to a focus on the PPP strategy. PPPs are complex in the private and
public sectors. Even though its tasks have transferred to the private sector [4], this study reviews the current state of
PPP development, emphasizing upper-level leadership. The anonymity of the Internet hinders the financial crime
crackdown. There was proxy bank account involvement. The auditing procedures of personal accounts should be
tightened up, and the penalty for these accounts vending should be increased [8]. Money laundering or online fraud
has posed a severe threat to the development of e-commerce. These activities exert a substantial impact on national
economies. Anti-money laundering has evolved dramatically. Detecting proxy bank accounts can effectively prevent
money laundering.

4. Conclusions

After decades of accelerating online globalization, the need for PPP implementations is immediately evident in a
globalized world. Its purpose is to justify its existence if full global awareness takes over from obliviousness to the
PDCA model. Significant pressure engages the banks and the police closer to facing AML/CFT challenges. Taiwan
has an excellent opportunity to advance its ability to fight financial crime and its predicate crimes. The substantive
application of best practices cannot be overstated. Financial crime needs to be addressed to encourage a shift to
substantive collaboration and develop trust between crucial partners. Partnerships can have a significant impact
under effective analytics from the police and banks. The proposed PDCA model can measure the effectiveness and
success of those partnerships and reduce any potential obstacles to information sharing and faced challenges. This
study has developed a workable methodology to protect the global financial system against money laundering or
online fraud. That effort demonstrates the importance of PPP importance in combatting AML/CFT.
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Reference

[1] Årnes, A., Digital Forensics, Wiley, J. & Sons Ltd., 2018
[2] Beck, S., Sutken, C., Schou-Zibell, L., and Daza-Estrada, C., Financial Crimes Compliance-the Power of
Partnership,. Retrieved April 25, 2020 from https://www.adb.org/sites/default/files/publication/712346/adb-
brief-180-financial-crimes-compliance.pdf, 2021
[3] Casey, E., Handbook of Digital Forensics and Investigation. Elsevier Inc., 2010
[4] Chalofsky, N. F., Rocco, T. S., and Morris, M. L., Handbook of Human Resource Development. John Wiley &
Sons, Inc., 2014
[5] European Commission, Public Consultation on Guidance on the Rules Applicable to the Use of Public-Private
Partnerships in the Framework of Preventing and Fighting Money Laundering and Terrorist Financing.
Retrieved April 25, 2020 from
https://ec.europa.eu/info/sites/default/files/business_economy_euro/banking_and_finance/documents/2021-anti-
money-laundering-public-private-partnerships-consultation-document_en.pdf, 2021
[6] FATF – Egmont Group, Trade-based Money Laundering: Trends and Developments. Retrieved April 25, 2020
from www.fatf-gafi.org/publications/methodandtrends/documents/trade-based-money-laundering-trends-
anddevelopments.html, 2020
[7] Financial Action Task Force, Professional Money Laundering. Retrieved April 25, 2020 from https://www.fatf-
gafi.org/media/fatf/documents/Professional-Money-Laundering.pdf, 2018
[8] Ku, H. C., Prevention of Internet Fraud－Focusing on the dummy account. Thesis. Institute of Technology Law
College of Management, National Chiao Tung University,. 2006
[9] Kouzes, J. M., and Posner, B. Z., The Leadership Challenge. San Francisco, CA: Jossey-Bass, 1987
[10] Kouzes, J. M., and Posner, B. Z., The Leadership Challenge (4th ed.). San Francisco, CA: Jossey-Bass, 2008
[11] Meifert, M. T., Strategic Human Resource Development: A Journey in Eight Stages. New York: Springer-
Verlag Berlin Heidelberg, 2013
[12] Money Laundering Office (Taiwan Executive Yuan), National Money Laundering and Terrorist Financing
Risk Assessment Report. Retrieved April 25, 2020 from https://www.fsc.gov.tw/fckdowndoc?file=/National
Risk Assessment Report.pdf, 2018
[13] Monsarrat, A., Encouraging Public-Private Partnerships to Fight Financial Crime. Retrieved April 25, 2020
from https://www.files.ethz.ch/isn/155412/AC-TR Financial Crime Report - Final.pdf, 2012
[14] Ulrich, D., Brockbank, W., Johnson, D., Sandholtz, K., and Younger, J., HR Competencies. Arlington Virginia:
Society for Human Resource Management, 2008
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