Page 585 - IOM Law Society Rules Book

part of the picture means that it will be very difficult to determine if illegal activity is
taking place without first obtaining a picture of the whole operation. In short, the
criminal using the internet takes advantage of certain inherent aspects of the system to
ensure that the whole picture is not visible by the investigator.

As such, it seems that internet gambling might be an ideal web-based “service” to
serve as a cover for a money laundering scheme through the net. There is evidence in
that criminals are using the internet gambling industry to commit crime and to launder
the proceeds of crime. Despite attempts to deal with the potential problems of
internet gambling by regulating it, requiring licenses in order to operate, or banning
such services outright, a number of concerns remain in addition to the inability to
track the internet links mentioned above. For example, transactions are primarily
performed through credit cards, and the offshore placement of many internet
gambling sites makes locating and prosecuting the relevant parties more difficult if
not impossible. Furthermore, gambling transactions, the records of which might be
needed as evidence, are conducted at the gambling site and are software-based; this
may add to the difficulty of collecting and presenting such evidence.