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Global Money Laundering

Global Money Laundering. Masseh Tahiry April 2013. 2%-5% of global GDP $800 billion to $2 trillion U.S. banks involved Riggs Bank and 9/11 hijackers Citi and Charles Taylor HSBC and cartels ($881 mil) Undermines economy Facilitates illicit activity Unfair advantage Good guys lose.

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Global Money Laundering

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  1. Global Money Laundering Masseh Tahiry April 2013

  2. 2%-5% of global GDP • $800 billion to $2 trillion • U.S. banks involved • Riggs Bank and 9/11 hijackers • Citi and Charles Taylor • HSBC and cartels ($881 mil) • Undermines economy • Facilitates illicit activity • Unfair advantage • Good guys lose Overview

  3. Bank Secrecy Act (BSA/AML) • 31 U.S.C. 1051 et seq. • Assist USG to detect and prevent money laundering (ML) • Keep record of cash purchases • File reports of transactions greater than $10k • Report suspicious activity that might signify ML, tax evasion, other criminal acts U.S. Efforts

  4. Customer Due Diligence • PEPs, Corrupt Regime Officials, etc. • Beneficial Ownership • Front companies • Implementation Gap • No Risk identified for complicit banks • Correspondent banks • Burdensome • Prosecuting • “Too big to Jail” Problems

  5. Financial Action Task Force (FATF) http://www.fatf-gafi.org/media/fatf/documents/reports/mer/MER%20US%20full.pdf • Financial Crimes Enforcement Network (FinCEN) http://fincen.gov/statutes_regs/bsa/ • Global Witness http://www.globalwitness.org/sites/default/files/pdfs/undue_diligence_lowres_0.pdf • Terrorism, Transnational Crimea and Corruption Center (TraCCC-GMU) http://traccc.gmu.edu/links-to-internet-resources-on-human-trafficking/#money • United Nations Office on Drugs and Crime (UNODC)—International Money Laundering Information Network (IMoLIN) http://www.imolin.org/ • World Economic Forum http://reports.weforum.org/organized-crime-enablers-2012/#chapter-enablers-of-money-laundering References

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