It took just hours for Switzerland to order its 300 banks to freeze all assets belonging to the freshly deposed Egyptian President Mubarak and his family. A similar freeze was imposed on four high-ranking Mubarak ministers and the secretary of Egypt’s ruling National Democratic Party. But a money-laundering expert who helped trace the Marcos millions has told Crikey that Egyptians will have trouble tracing their money if Mubarak’s investment banker son, Gamal, is looking after the loot.

According to unnamed “Western intelligence sources” quoted in London’s Telegraph the embattled dictator may already have shifted his money to safer havens. Certainly, Mubarak and his mates had plenty of warning, because the Swiss froze bank accounts belonging to ex-President Ben Ali and 40 associates in mid-January, as soon as Ali fled Tunisia.

And it would definitely not be the first time a toppled dictator has outrun the repo men. Slobodan Milosevic shifted money into Liechtenstein in 1999, before his Swiss accounts could be frozen. Ferdinand Marcos is said to have extracted $400 million from Switzerland in 1986 and was attempting to transfer another $213 million to Austria when the Swiss slapped a freezing order on him and General Mobutu transferred hundreds of millions of dollars out of Switzerland in 1997 in the weeks following Zaire’s first, unsuccessful, request to freeze his accounts.

No one knows how much Mubarak has in Geneva, Zurich or Zug. Neither do they know much he has stolen: estimates range from $2 billion to $70 billion. Nor are they going to find out soon. When the Swiss froze Marcos’s assets in 1986 it took five years to release bank documents revealing what he had there. And it took almost as long with Nigeria’s dictator, Sani Abacha, 12 years later, even though new laws streamlined the process.

Getting the money back will take even longer, and probably won’t happen while Mubarak is alive. Marcos’s Swiss stash was finally handed to the Philippine Treasury in 2004, 18 years after his downfall and 15 years after his death, while Baby Doc Duvalier’s millions are still awaiting repatriation to Haiti (where he has now returned) after 25 years.

Egyptians will also be lucky to see a tenth of what’s been stolen. According to Australian lawyer David Chaikin, the money-laundering expert who helped trace Marcos’s millions, less than 10% of the Filipino dictator’s assets have been located and recovered, despite a 25-year search.

And most other teams of asset hunters have found even less. Only a tiny fraction of General Mobutu’s money has been recovered and none of Liberia’s Charles Taylor’s fortune has been found so far. The one real success has been with Abacha, where $1.7 billion (out of $2 billion to $5 billion) has been frozen or repatriated.

Why is it always so hard? Largely because corruption and money laundering go hand in hand, and dictators who steal millions employ the best bankers and lawyers to clean it for them.

Marcos’s money, for example, was taken out of the Philippines in cash, deposited in Hong Kong and wired around the world. Handily, the dictator also controlled 12 Filipino banks, which exported his money electronically with no questions asked.

Most of this would never have been found had documents not been left in Manila’s Malacanang Palace during the dictator’s hurried flight. These included blank share certificates, blank deeds of assignment and correspondence with assorted trustees, fiduciaries, dummy corporations and offshore shell companies in Panama, Switzerland, Netherlands Antilles, Liechtenstein and Hong Kong.

Mubarak would have had at least two weeks to clean up in Cairo before he left, so it’s unlikely he has been so helpful. “The key will be to find Mubarak’s advisers,” says Chaikin, “the people who did it all for him.”

If Egyptian investigators (or Swiss banks) do find Mubarak’s money offshore, they will need to show it was illegitimately obtained. Marcos’s pursuers did that by taking his financial disclosures from 1965 and adding the income he declared in tax returns. He had started out with $7500 and earned $2.4 million over 21 years. Easy.

They could do similar sums with Hosni, who earned $808 a month as President. But they’ll have far more trouble if son Gamal is looking after the loot, as some suggest.

“Gamal has been an investment banker for years and may well have earnt tens of millions of dollars legitimately,” Chaikin adds, “Even if he got the money by having the inside running on Eqypt’s privatisation deals. That’s going to complicate matters.”

Egypt will also need to begin a criminal investigation, because the Swiss government refuses to pierce the veil of secrecy or repatriate hidden funds in civil complaints. But it may not be necessary to get a conviction. Marcos was never convicted; nor was Imelda.

Whatever happens it will take an age, says Chaikin. The Swiss system is set up to give extensive rights of challenge and appeal before banking secrets (or funds) are handed over. And dictators have the money and nous to use every opportunity, including using their former head of state status to claim immunity from prosecution (which did not help Marcos and Duvalier because new leaders in the Philippines and Haiti waived immunity on their behalf).

Back in Cairo, pressure to prosecute Mubarak has already begun but for the moment his minions still hold power. “All the judges, officials and army officers he appointed are still there, and they could easily frustrate this process,” says Chaikin.

The final and perhaps most intriguing question is what happens to the money they don’t find. Chaikin says that dictators and their families often lose control of the funds when they lose power. “It often ends up with the banks and fiduciaries who are hiding it, especially if the money is in Liechtenstein foundations. It’s a fabulous opportunity for them to get rich.”