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         Money Laundering:     more books (100)
  1. Federal Money Laundering: Crimes and Forfeitures by B. Frederic Williams, Frank D. Whitney, 1999-01
  2. The Washing Machine: How Money Laundering and Terrorist Financing Soils Us by Nick Kochan, 2005-05-24
  3. European Money Trails by Ernesto U. Savona, Francesca Manzoni, 1999-02-01
  4. Hot Money and the Politics of Debt, Third Edition by R. T. Naylor, 2004-09-30
  5. Organized Crime and Money Laundering: Globalisation Series by William B.Z. Vukson, 2003-01-01
  6. International Guide to Money Laundering Law and Practice
  7. Arbitration: Corruption, Money Laundering and Fraud (ICC Publication) by edited by Kristine Karsten and Andrew Berkeley, 2006-08-07
  8. A Manual of Best Practice for Combating Money Laundering in the Financial Sector by Sue Thornhill, Commonwealth Secretariat, et all 2001-01-15
  9. Cyberpayments and Money Laundering: Problems and Promise 1998 by Roger Molander, 1998-04-25
  10. The Cash Connection: Organized Crime, Financial Institutions, and Money Laundering by President's Commission on Organized Crim, 2001-09
  11. Capital, Payments and Money Laundering in the European Union by John Handoll, 2007-02-22
  12. Insider Dealing and Money Laundering in the Eu: Law and Regulation by R. C. H. Alexander, 2007-04-09
  13. Suppressing Terrorist Financing and Money Laundering by Jae-myong Koh, 2010-11-30
  14. Integrity in Mobile Phone Financial Services: Measures for Mitigating the Risks of Money Laundering and Terrorist Financing (World Bank Working Papers) by Pierre-laurent Chatain, Raul Hernandez-Coss, et all 2008-06-11

41. Global Financial Services (AML)
GO. print. Please enable JavaScript to view this page properly. AntiMoneyLaundering, Anti-money laundering Financial Services. Anti
http://www.pwcglobal.com/Extweb/industry.nsf/docid/FD9226DB162697EE85256B820008F
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Anti-Money Laundering
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42. Funds Derived From Criminal Activities (FOPAC)
money laundering Interpol’s Definition Asia Pacific Group on MoneyLaundering (APG);; Caribbean Financial Action Task Force (CFATF);;
http://www.interpol.int/Public/FinancialCrime/MoneyLaundering/default.asp
10 April 2003
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Funds derived from criminal activities Introduction The international police community is aware that there is a need to achieve major results in the struggle against the financial criminal activities related to organized criminal groups. During recent years there have been a number of resolutions passed by the ICPO-Interpol General Assembly, which have called on member countries to concentrate their investigative resources in identifying, tracing and seizing the assets of criminal enterprises. Papers Alternative remittance systems distinguishing sub-systems of ethnic money laundering in Interpol member countries on the Asian continent
The Hawala alternative remittance System and its role in money laundering
These resolutions have also called on member countries to increase the exchange of information in this field and encourage governments to adopt laws and regulations that would allow access, by police, to financial records of criminal organizations and the confiscation of proceeds gained by criminal activity. (Resolutions AGN/55/RES/18 AGN/56/RES/11 AGN/60/RES/4 AGN/66/RES/15 and AGN/66/RES/15 A concise working definition was adopted by Interpol General Secretariat Assembly in 1995, which defines money laundering as:

43. Money Laundering - The Hawala Alternative Remittance System
The hawala alternative remittance system and its role in money launderingInterpol General Secretariat, Lyon, January 2000, Patrick
http://www.interpol.int/Public/FinancialCrime/MoneyLaundering/hawala/default.asp
10 April 2003
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The hawala alternative remittance system and its role in money laundering
Interpol General Secretariat, Lyon, January 2000 Patrick M. Jost
United States Department of the Treasury
Financial Crimes Enforcement Network (FinCEN) Harjit Singh Sandhu
Interpol/FOPAC
Executive summary
What is hawala? How does hawala work? Why would anyone bother with hawala ... End note Executive summary This paper presents a description of the hawala (also referred to as hundi) alternative remittance system. Hawala is an ancient system originating in South Asia; today it is used around the world to conduct legitimate remittances. Like any other remittance system, hawala can, and does, play a role in money laundering. In addition to serving as a 'tutorial' on hawala transaction, this paper will also discuss the way in which hawala is used to facilitate money laundering. What is hawala? Hawala ( ) is an alternative or parallel remittance system. It exists and operates outside of, or parallel to 'traditional' banking or financial channels. It was developed in India, before the introduction of western banking practices, and is currently a major remittance system used around the world. It is but one of several such systems; another well known example is the 'chop', 'chit' or 'flying money' system indigenous to China, and also, used around the world. These systems are often referred to as 'underground banking'; this term is not always correct, as they often operate in the open with complete legitimacy, and these services are often heavily and effectively advertised.

44. Follow The Money: Confusion At Treasury
to identify the criminal monetary proceeds of the drug dealers and then make itillegal to use or hide money from illegal activities ie, money laundering.
http://www.cato.org/dailys/02-05-03.html
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Policy Studies ... El Cato
February 5, 2003
Follow the Money: Confusion at Treasury
by Richard W. Rahn Richard W. Rahn is an adjunct scholar of the Cato Institute. If you want to catch a criminal or terrorist, does it make sense to "follow the money"? A "yes" answer makes sense if you can identify at least one of the individuals or institutions connected with the suspected wrongdoer. However, if you are trying to follow money flows in general or all money flows, it is not likely your work will be very productive, and it will also involve massive violations of civil liberties. Back in the 1970s and '80s, law-enforcement agencies were having trouble catching and convicting major drug dealers. Some thought the solution might be to identify the criminal monetary proceeds of the drug dealers and then make it illegal to use or hide money from illegal activities i.e., money laundering. The result was the Money Laundering Control Act of 1986 that, for the first time, made money-laundering illegal. There have been a number of subsequent laws aimed at strengthening the anti-money laundering regulations, including last year's "Patriot Act." Money laundering is not an easy crime to define or detect since an almost infinite number of assets are "fungible" that is, can be readily turned into money and vise versa. As an example, let us say Joe is a drug dealer in London. Every day he collects $10,000 in cash from selling drugs. As a cover, he has a fish-and-chips shop in London that is a cash business, and so he commingles his drug money with his legitimate fish-and-chips receipts and makes a daily bank deposit. To the bank, it appears that Joe has a nicely profitable fish-and-chips business just like thousands of others of profitable cash businesses the bank deals with.

45. FBI PRESS ROOM - FBI DISMANTLES FRAUD AND MONEY LAUNDERING RING EXCEEDING $4 MIL
FBI Dismantles Fraud and money laundering Ring Exceeding $4 Millionin Five States. FBI Agents, along with US Postal Inspectors and
http://www.fbi.gov/pressrel/pressrel03/mueller022603.htm
For Immediate Release
February 26, 2003 Washington D.C.
FBI National Press Office FBI Dismantles Fraud and Money Laundering Ring
Exceeding $4 Million in Five States
FBI Agents, along with U.S. Postal Inspectors and Agents from the INS, today arrested sixteen individuals in five states (Wisconsin, Florida, New York, Tennessee, and Mississippi) involved in a coupon redemption fraud and money laundering scheme that resulted in losses exceeding $4 million. Some of the proceeds of the fraud were sent to the West Bank. The FBI continues to investigate the overseas financial transactions and other aspects of the scheme. The scheme involved over 300 stores and spanned fifteen states, including Alabama, Connecticut, Florida, Illinois, Louisiana, Massachusetts, Mississippi, New Jersey, New York, Ohio, Pennsylvania, Tennessee, Texas, Rhode Island, and Wisconsin. Arrests, interviews, and federal search warrants of businesses and residences were conducted simultaneously today by the FBI and cooperating law enforcement partners in a number of states. This investigation was conducted over a nineteen month period. Three of the persons arrested today are being charged in the Northern District of Mississippi, and thirteen of the individuals arrested today are being charged in a complaint filed in the Eastern District of Wisconsin, for their participation in a conspiracy to violate the following federal statutes: Mail Fraud; Wire Fraud; Money Laundering; Interstate Transportation of Stolen Property; and Receiving Stolen Property that Crossed State Lines

46. Watching For Dubious Dough
Venture capital firms are still absorbing the new antimoney laundering requirementsthat amount to their marching orders in the war on terrorism.
http://www.redherring.com/vc/2002/0805/dubiousdough080502.html
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Decliners Silverline Technologies Orascom Telecom Holding Net One Systems Co
POLICY
Watching for dubious dough
VC firms face a new challenge: compliance with the anti-money laundering provisions of the USA Patriot Act.
By Ted Smalley Bowen
August 5, 2002
You can track key markets and emerging technologies, but these days, if you don't know where your money comes from, you're playing with fire. Venture capital firms are still absorbing the new anti-money laundering requirements that amount to their marching orders in the war on terrorism. They're now obligated to vet their backers thoroughly, and are subject to oversight by Uncle Sam. "We've never been regulated by any kind of federal body. This is not something that we're used to," says Mark Heesen, president of the National Venture Capital Association in Arlington, Virginia.

47. Anti-Money Laundering Software: On Electronic Patrol
White Paper Antimoney laundering Software On Electronic Patrol. February2002. Governments around the world are increasingly deputizing
http://www.aberdeen.com/ab_abstracts/2002/02/02020001.htm
White Paper:
Anti-Money Laundering Software: On Electronic Patrol
February 2002
Governments around the world are increasingly deputizing financial institutions in the fight against money laundering, a criminal and now terrorist activity involving more than $500 billion each year. But the deputy's badge also carries stiff expectations: Financial institutions must now identify and investigate potential money laundering activity; if executives fail to meet the challenge, they face stiff penalties - including fines, incarceration, and bad publicity. Moreover, the USA Patriot Act, signed into law last October, expands the scope of existing anti-money laundering (AML) legislation. The act extends AML's reach to all types of financial institutions, not just banks. As a result, broker/dealers, mutual funds, insurers, and money transfer/payment agencies (among many other types of institutions) are now part of the AML posse.
This Aberdeen Executive White Paper offers an executive-level perspective on money laundering - i.e., a primer on what it is and why it exists - and familiarizes the reader with the AML market dynamics. The paper outlines the conceptual and technological underpinnings of AML software; enterprise buying requirements; the suppliers and their approaches to AML; and the formidable challenges still remaining for suppliers and user organizations alike. In short, this paper aims to educate decision-makers in the selection and implementation of an effective AML software solution.

48. Wolfsberg AML Principles
Eleven of the world's largest international Private Banks have agreedto set of global antimoney laundering guidelines. These 'Wolfsberg
http://www.wolfsberg-principles.com/
Home Wolfsberg Principles Wolfsberg Statement FAQ ... Subscription The Wolfsberg Group of Banks
The Wolfsberg (1) Group consists of the following leading international banks
ABN Amro N.V.

Banco Santander Central Hispano, S.A.

Bank of Tokyo-Mitsubishi, Ltd.

Barclays Bank
...
UBS AG

and became known when they agreed to a set of global anti-money-laundering guidelines for international private banks in October 2000.
The banks collaborated with a team from Transparency International (2) who invited two international experts to participate, Stanley Morris (3) and Prof. Mark Pieth (4).
(1) Wolfsberg is the location in Switzerland where an important working session to formulate the guidelines was held.
(2) Transparency International (TI) is a Berlin based non-governmental organization, dedicated to increasing government accountability and curbing both international and national corruption. TI is active in more than 70 countries. TI was represented by its founder and Chairman of the Board, Peter Eigen and the Chairman of their US chapter, Fritz Heimann. (3) Stanley E. Morris is an international Consultant on Anti-Money-Laundering issues. He was head of FinCEN and a member of the Financial Action Task Force on Money Laundering (FATF).

49. Bank Systems & Technology > U.K. Bank Fights Money Laundering > February 26, 200
UK Bank Fights money laundering Ivan Schneider Feb 26, 2003 Nationwide BuildingSociety, the largest mutual company in the United Kingdom, has seen quick
http://www.banktech.com/story/BNK20030226S0013

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Anti-Money
Laundering Retail Delivery ... Internet Banking Sys. tools RFP Central Telcom Solutions Center TechLibrary IT Career Center ... Resource Guide events 2003 Exec. Tech. Forum services Subscription Cust. Serv. Ad. Index Edit. Calendar Media Kit ... Reprints TechWeb Sites InformationWeek InternetWeek Network Computing Financial Technology ... Ad Info U.K. Bank Fights Money Laundering Ivan Schneider Feb 26, 2003 Nationwide Building Society, the largest mutual company in the United Kingdom, has seen quick results after installing enterprise risk monitoring software from NetEconomy, Netherlands. "It's [detecting] suspicious transactions that we would have been unaware of prior to its installation," said Russell Johnston, head of legal compliance (consumer affairs) and deputy group money laundering reporting officer at Nationwide Building Society. "We are seeing suspicious transactions, and we have [notified] the police of a couple already." NetEconomy's Erase system is being used initially on banking and savings accounts, which comprise 20 million customers, 50 million accounts and 60 million transactions per month. To date, over 240 million transactions have been profiled and stored. Later, Nationwide will deploy the system throughout its lending, mortgage, credit card, unit trust and treasury services businesses.

50. Bank Systems & Technology > Italian Bank Deters Money Laundering > January 07, 2
Banca Monte dei Paschi di Siena licenses antimoneylaundering software from Financial Objects.
http://www.banktech.com/story/internationalNews/BNK20030107S0007

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Anti-Money
Laundering Retail Delivery ... Internet Banking Sys. tools RFP Central Telcom Solutions Center TechLibrary IT Career Center ... Resource Guide events 2003 Exec. Tech. Forum services Subscription Cust. Serv. Ad. Index Edit. Calendar Media Kit ... Reprints TechWeb Sites InformationWeek InternetWeek Network Computing Financial Technology ... Ad Info Italian Bank Deters Money Laundering Jan 7, 2003 Banca Monte dei Paschi di Siena, the fourth largest bank in Italy, has licensed anti-money laundering software from Financial Objects, a London-based supplier of banking software. Banca Monte has installed the IBIS/S2 Financial Sanctions System in its New York office, and plans to roll it out to all its international branches. The Financial Sanctions System integrates with the IBIS/S2 product suite, which the bank was already using in its branch network. Financial Objects was thus an attractive choice once Banca Monte decided to tighten security throughout its payments process in an efficient, cost-effective manner. By introducing additional security checks into the payments process, the Financial Sanctions System will enable Banca Monte to automatically check client details and funds transfers against lists of suspected individuals and organizations published by governments and regulatory authorities.

51. General Electric : Our Commitment : GE Integrity
money laundering Prevention Policy Overview People who are involved in criminalactivity (for example, narcotics trafficking, bribery, fraud) may try to
http://www.ge.com/en/commitment/social/integrity/laundering.htm
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Our Commitment Social Performance : GE Integrity
Social Performance
GE Integrity Diversity From the Podium Financial Responsibility Resource Room ... GE Hudson River Efforts Integrity editor's note:
No matter how high the stakes, no matter how great the "stretch", GE will do business only by lawful and ethical means. When working with customers and suppliers in every aspect of out business, we will not compromise our commitment to integrity. Money Laundering Prevention Policy Overview
GE's integrity and reputation can be severely damaged by failing to detect those customer relationships and transactions that place us at risk. Core Requirements
Comply with all applicable laws that prohibit money laundering and that require the reporting of cash or other suspicious transactions. Understand how both types of laws apply to your business. Follow your business' rules concerning acceptable forms of payment. Learn how to identify the types of payments that have become associated with money laundering activity (for example, multiple money orders or travelers checks, large amounts of cash, or checks on behalf of a customer from an unknown third party) and follow the rules that restrict or prohibit acceptance of them. Learn to identify and carefully watch for warning signs that may indicate money laundering or other illegal activities or violations of GE policies.

52. Spotlight On: Anti-Money Laundering Rules
In spring 2002, the President ordered law enforcement to aggressively enforceour nation's money laundering laws with coordination and accountability.
http://www.sec.gov/spotlight/moneylaundering.htm
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Spotlight on
Anti-Money Laundering Rulemaking

53. SEC-SIA Anti-Money Laundering Webcast
SECSIA Anti-money laundering Webcast. Monday, November Eastern Time. AskSEC Staff your questions about anti-money laundering compliance issues.
http://www.sec.gov/spotlight/moneylaunder/webcast1102.htm
Home Previous Page
SEC-SIA Anti-Money Laundering Webcast
Monday, November 25, 2002
1:00 p.m. U.S. Eastern Time
Ask SEC Staff your questions about anti-money laundering compliance issues
Instructions for Accessing the Webcast
To access the webcast simply go to www.sec.gov and click on the " " link. From there, click on the " Other Webcasts " link and look for "SEC-SIA AML Webcast" link. You may need to download either Real Player or Windows Explorer to access the webcast.
Answers to Your Questions
Only pre-submitted questions will be addressed during the webcast. To submit questions for the webcast, simply send an email containing the question to ocieaml@sec.gov by November 15, 2002. http://www.sec.gov/spotlight/moneylaunder/webcast1102.htm
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54. PracticePRO -- Practice Aids
Background On June 29, 2000, the federal government passed the Proceeds of Crime(money laundering) Act, which was subsequently renamed Proceeds of Crime
http://www.practicepro.ca/practice/mlguide.asp
In Most Circumstances Clients, Not Lawyers, Must Report Cross-Border Transactions Reportable Under The Proceeds Of Crime Legislation Updated Jan.16, 2003 This information updates information posted on the Federation of Law Societies Web site on January 7, 2003, and this site on January 13, 2003. The Federation of Law Societies has sought and received a clarification from the Attorney General for Canada on who is obligated to file reports on reportable cross-border transactions. The final set of regulations on the cross-border movement of currency and monetary instruments under Part 2 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) took effect January 6, 2003. These regulations require specified persons to report the importation or exportation of amounts of $10,000 or more of currency or monetary instruments in bearer form. There are several parts to section 12(3) of the PCMLTFA, the section that indicates who is required to submit cross-border transaction reports on reportable cross border transactions. The different parts of this section deal with the different ways in which currency or monetary instruments can exported or imported from Canada (by mail or courier, physically carried etc.). The advice provided to the Federation indicates that where a lawyer is involved in a reportable cross-border transaction on behalf of a client, under ss. 12(3)(b)-(e), it is the client that is obligated to report the transaction, not the lawyer. This is the case as under these parts of s. 12(3) it is the client, not the lawyer, that is considered the exporter or importer, and it is the exporter or importer that is specified as the person who is obligated to report. While it is the client who has the obligation to file the report in these circumstances, the lawyer may do so as a service to the client if so instructed.

55. Anti-money Laundering Investigations And Due Diligence By LexisNexis
LexisNexis™ Antimoney laundering Solutions is a convenient and authoritative web-basedtool for anti-money laundering investigations and due diligence in a
http://www.lexisnexis.com/antimoneylaundering/
Sign on to your service LexisNexis at lexis.com LexisNexis at nexis.com LexisNexis by Credit Card LN Academic Anti-Money Laundering Solutions Authority On Demand Automated Forms Collection Solutions LN Company Analyzer LN Congressional Corporate Legal Courtlink eAccess Courtlink eFile LN Document Solutions LN Environmental LN Europe Web Product Gov Periodicals Index Primary Sources in U.S. Hist. Insurance Solutions Intranet Solutions LN for Law Schools Law Enforcement Solutions lexisONE Mealey's Online PeopleWise.net PRanywhere PowerInvoice reQUESTer Risk Management Solutions Scholastic Edition LN State Capital LN Statistical Telnet Connection LN Development Pro Web Publisher Home LexisNexis Anti-Money Laundering Solutions
If you already subscribe to LexisNexis Anti-Money Laundering Solutions , sign on here
LexisNexis™ Anti-Money Laundering Solutions is a convenient and authoritative web-based tool for anti-money laundering investigations and due diligence in a single easy-to-use resource. LexisNexis™ Anti-Money Laundering Solutions combines several powerful tools into a single easy-to-use web page that helps you investigate money laundering and perform due diligence
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56. EUROPA - Internal Market - Banks
money laundering Commission welcomes Council adoption of new Directive(19 November 2001); money laundering Commission welcomes
http://europa.eu.int/comm/internal_market/en/finances/banks/
IMPORTANT LEGAL NOTICE - The information on this site is subject to a and a
Financial Services
Banks Overview
BANKS
Working document of the commission services on capital requirements for credit institutions and investment firms (18 November 2002)

57. Money Laundering: EU Directive To Be Extended
money laundering EU Directive to be extended. Work has thereforestarted on a proposal for a second money laundering Directive.
http://europa.eu.int/comm/internal_market/en/finances/general/launden.htm
IMPORTANT LEGAL NOTICE - The information on this site is subject to a and a
Financial Services
General Matters Banks
Full text for downloading (PDF and Word files, 115-410 KB)
Money laundering: EU Directive to be extended see below, Situation in the Member States "I am pleased that the Directive has been effective at countering money-laundering and has proved to be a landmark in international efforts to combat this scourge", commented Financial Services Commissioner Mario Monti. "But to guard against the Single Market being exploited by organised crime, we will be coming forward with proposals to extend and improve the current rules. These stronger safeguards will be all the more necessary with the single currency, which will serve to further increase the process of integration within the Single Market as a whole and the financial services sector in particular". The money laundering Directive (91/308/EEC) has provided the basis for Member States' efforts to prevent criminal money entering the financial system, which is a crucial part of the campaign against drugs trafficking and organised crime in general. Indeed, the Directive serves as a reference at the world level for other countries' measures to counter money laundering. The cornerstone of the Directive is the obligation on credit and financial institutions (including 'bureaux de change') to require identification of all their customers when beginning a business relationship (particularly the opening of an account or offering safe-deposit facilities), when a single transaction or linked transactions exceed ECU 15,000 or when they suspect laundering (even where the transaction is below the threshold).

58. Anti-Money Laundering And Terrorist Financing
Antimoney laundering and Terrorist Financing. Printable Version, Searchfor. Anti-money laundering and Terrorist Financing. The Patriot
http://www.cftc.gov/cftc/cftcaml.htm
Anti-Money Laundering and Terrorist Financing Printable Version Search for   Commitments of Traders
Customer Protection

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Before You Trade
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Filing a Customer Complaint

Anti-Money Laundering and Terrorist Financing The Patriot Act , which amends the Bank Secrecy Act (BSA), was adopted in response to the September 11 terrorist attacks. The Patriot Act is intended to strengthen U.S. measures to prevent, detect, and prosecute international money laundering and the financing of terrorism. These efforts include new anti-money laundering (AML) tools that impact the banking, financial, and investment communities. Under the Patriot Act, persons who are or are required to be registered as futures commission merchants (FCMs), introducing brokers (IBs), commodity pool operators (CPOs), and commodity trading advisors (CTAs) are subject to new requirements for establishing AML programs, reporting suspicious activity, verifying the identity of customers, and dealing with certain types of accounts involving foreign persons. Establishing AML Programs
Reporting Suspicious Activity

Verifying the Identity of Customers

Due Diligence Measures for Certain Accounts Involving Foreign Persons
...
Transactions in Excess of $10,000 in Currency

59. International Fact Sheet - ONDCP
ONDCP FACT SHEET International money laundering and Asset Forfeiture.Overview The The 2001 National money laundering Strategy The
http://www.whitehousedrugpolicy.gov/publications/international/factsht/launderin

International

Fact Sheets

Bolivia

Mexico
...
Operations

Money Laundering
Democracy and

Human Rights

Regional Drug

Control
... Resources ONDCP FACT SHEET International Money Laundering and Asset Forfeiture Overview: The United States supports global and domestic efforts to disrupt the flow of illicit capital, track criminal sources of funds, forfeit ill-gained assets, and prosecute offenders. Money laundering plays an integral role in the illicit narcotics industry in that it enables the organizations that supply drugs to finance their ongoing operations and conceal their enormous profits from the reach of law enforcement. These profits are the motivating force behind the supply side of the narcotics equation, and money laundering provides the protective shield for these profits against detection and confiscation. To help direct the United States anti-money laundering effort, the Departments of Treasury and Justice collaborate on an annual National Money Laundering Strategy-as called for in the Money Laundering and Financial Crimes Strategy Act of 1998. The 2001 National Money Laundering Strategy: The first National Money Laundering Strategy (NMLS) under the Bush Administration was released in the fall of 2001. This strategy calls for renewed efforts against major money laundering organizations through the development of multi-agency task forces to exploit the information supplied by the financial services industry through the filing of Suspicious Activity Reports (SARs) with The Treasury Department's financial intelligence agency, FinCEN. The centerpiece of this effort will be the High Intensity Financial Crime Area (HIFCA) Task Forces. There are currently four HIFCAs, New York/Northern New Jersey, Los Angeles, San Juan, Puerto Rico, and a new HIFCA targeting currency smuggling along the southwest border of the United States. The NMLS also calls for the designation of additional HIFCAs as well as the establishment of similar task force groups in every judicial district in the United States.

60. Ernst & Young - Taking Action Against Money Laundering
Taking Action Against money laundering. Global Home Issues Perspectives Library Taking Action Against MoneyLaundering. by Alvin James
http://www.ey.com/GLOBAL/content.nsf/International/Taking_Action_Against_Money_L
Global Home Library Taking Action Against Money-Laundering
by Alvin James
As James K. Robinson, Assistant U.S. Attorney General, Criminal Division, put it: "Companies, especially those that have international business ..., should have a specific anti-money laundering component in their compliance programs. In addition, the Board of Director's Audit Committee should specifically review money laundering issues with the compliance officer, especially looking at foreign agent contracts and sales figures to look for anomalies." (The US is not alone in policing these matters. Government agencies around the world are playing their parts in putting a stop to money-laundering operations.) Big Business. But the worst-case scenario doesn't have to happen. The first step in protecting your company's most valued assets, its name and reputation, is to acknowledge potential vulnerabilities. The second step is to take action. The Modus Operandi of the Underground Systems. If you think that your organization is safe from these kinds of improprieties, consider this: A significant portion of these funds come from underground financial systems, also referred to as "parallel payment systems." These systems, such as the Black Market Peso Exchange (Latin America), the Chinese Underground Banking System (East Asia/China) and the Hawala/Hundi System (India/Middle East), are culturally accepted and often used by businessmen worldwide, even though they operate outside a nation's regulatory control.

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