Changes in Anti Money Laundering Laws in Mexico being Countered by Cartels

Not many experts in Mexico are willing or brave enough to discuss the country’s recently amendedanti-money laundering laws, designed to hamper the drug cartels from trying to legitimize their ill-gotten gains

The foot-dragging reticence is more understandable when you realize that it's about more than just hard feelings or toes stepped upon. Mexico is the largest transit area for illegal narcotics in the world. Northwards flow the tons of drug shipments into the United States, and southwards return bundles of cash and stacks of guns. This illicit trade which has grown and developed into a booming and highly profitable illicit industry is now annually worth well in excess of $40 billion - and counting.

Yet the days of chucking cash around like confetti to buy luxury goods and haciendas, and using so-called safe houses to stack from basement to rafters piles of high denomination banknotes, are numbered.

The new, more carefully tailored laws, which were designed to detect and curb transactions of illegal proceeds or the financing of terrorism, have some very strict parameters and curbs.

Banned transactions, in national or international currencies, include the sale of real estate or property valued at more than 520,000 pesos ($40,000). Boats, cars or planes over 200,000 pesos are on the list, which also includes anything from jewellery, precious metals, gems, watches to artwork.

Insurance and retail services, credit cards, pre-paid cards or a travellers' checks, when not offered by financial institutions, also fall under this category.

Implementing the law

Those who are charged with identifying what is termed the performance of vulnerable acts have to follow a clear set of obligations. These include: To identify clients or users, to retain documentation related to vulnerable activity for five years from the done deed, and to file relevant data to the finance ministry.

Alberto Elias Beltran has been appointed by the finance ministry to implement these laws. And he points out that they're specifically designed to cover the spectrum of money laundering, illegal funds, drug trafficking, arms trafficking and people trafficking. He explains that the aim is to better detect the operations and financial structures of organized crime to be able to squeeze and impact them.

He concedes that by the very nature of the beast, there isn't a methodology to determine just how much money is being laundered in a region, let alone a country. But the number of denunciations to the Attorney General's Office, arrests, convictions jail sentences and seizures of illegal funds by the state, are a reasonable benchmark to start with.

Mexico's drug cartels have been creative with their illicit trade in the past

Omar Fayad, President of the Mexican Senate's Justice Commission, says the new law does make life easier for law enforcement officials.

"If you watch how the money moves, you can do a lot of things, that's the reason Mexico's Congress approved this anti-money laundering legislation. If you can hit the drug cartels' economic power, then certainly their field of action is affected. But I think that they have the capacity to adapt to these new circumstances. That's why it's so important to modify legislation not just once. The government must be dynamic and willing to modify the legislation constantly. It's the first step combined with others to follow, in order to fight against the drug cartels in Mexico. But the cartels are like viruses. They have the ability to change and transform fast."

Tightening the loopholes

Ramon Garcia Gibson is the CEO of Garcia Gibson Consulting - a Mexican firm specializing in the prevention of money laundering and financing of terrorism. He says the new law tightens loopholes: "It establishes measures and procedures to prevent and detect operations involving resources of illicit origin. And definitely with this law, it's going to make life more difficult for organized crime because Mexican authorities will have information about transactions, which limits the use of cash from their illegal activities."

Accountant Jose Raul Alvarez Flores of ASI Contadores says estimates of how much money slips through the net annually add up to the equivalent of $10 billion. That also includes individuals and companies who avoid paying taxes, but the majority of the gigantic overall swindle boils down to the common denominator of organized crime.

It's not just the drug capo who's slammed down 3 million pesos or considerably more on the table to buy a house outright. This new law filters down as far as buying a quality watch or splashing out on jewellery. And the sanction of not complying, reporting and playing the game by the new rules is: "Go to jail, go directly to jail."

More cohesion

The new law also draws the relevant entities together into a tighter and more cohesive team spearheaded by the finance ministry, combined with the Attorney General's Office and with the closer cooperation of the banking industry.

As Ramon Garcia Gibson says, "it establishes a proper coordination between authorities responsible for preventing but also prosecuting money laundering."

All of this sounds like a good idea and appears to be making life more difficult for the drug cartels. But the cartels themselves count amongst their ranks specialists in finance, logistics, forward planning and business.

The days of focusing on cash transactions may be over as the cartels look for new options

One example is the notorious Arellano Felix drug cartel. Five of the seven brothers who ran it are under lock and key and two have been shot dead. Since the arrest of her brother Eduardo in 2008, Enedina, one of their four sisters and a university trained accountant, has taken over the illicit enterprise with her son Luis Fernando.

Accordingly, the focus is much more strictly applied to prudent business practice, financing and various sophisticated methods of money laundering to generate bigger profits.

Not surprisingly, the new methods do not focus exclusively on antiquated cold, hard cash. And the wanton first option of violence has also been refined and adapted. The new-found expertise is going to be considerably more difficult to disrupt and dislodge.

Michael Hearns an Anti Money Laundering specialist with over 27 years of AML experience can also be found at:www.launderingmoney.com and on twitter at :http://twitter.com/#!/LaunderingMoneyas well as his blog at:http://moneylaunderingworld.blogspot.com

Islamic group tied to Russian money laundering scheme

 

 

 

Russian police said Monday they believe a black market financing ring may have helped support the Islamic political organization Hizb ut-Tahrir, banned since 2003.

Russian police said Monday they arrested seven members of a Central Asian criminal gang suspected of steering funds toward Hizb ut-Tahrir, a political organization banned in Russia since 2003. Russian state news agency RIA Novosti reports authorities seized more than $5 million from the members.

Hizb ut-Tahrir emerged in the 1950s as a Sunni group advocating strict Islamic law. Authorities in Kyrgyzstan told the BBC in 2010 the movement experienced a revival in Central Asia following the collapse of the Soviet Union in the 1990s.

Russian police were quoted by RIA Novosti as saying they suspected the financiers laundered money in Russian through financial channels "in the interests of natives of Central Asia illegally based in Russia."

Voice of Russia, in a separate report Monday, said the ring leaders transferred illegal funds to more than 120 different organizations, including offshore entities. They used so-called shadow bankers to transfer as much as $46 million per month through the illegal accounts.

Russian police provided few details about the arrest, which Voice of Russia said followed an 18-month probe.

Hizb ut-Tahrir claims to seek its objectives through peaceful methods

Michael Hearns an Anti Money Laundering specialist with over 27 years of AML experience can also be found at:www.launderingmoney.com and on twitter at :http://twitter.com/#!/LaunderingMoneyas well as his blog at:http://moneylaunderingworld.blogspot.com

C.I.A. Collects Global Data on Transfers of Money

 

 

By Charlie Savage and Mark Mazzetti

New York Times

The Central Intelligence Agency is secretly collecting bulk records of international money transfers handled by companies like Western Union — including transactions into and out of the United States — under the same law that the National Security Agency uses for its huge database of Americans’ phone records, according to current and former government officials.

The C.I.A. financial records program, which the officials said was authorized by provisions in the Patriot Act and overseen by the Foreign Intelligence Surveillance Court, offers evidence that the extent of government data collection programs is not fully known and that the national debate over privacy and security may be incomplete.

Some details of the C.I.A. program were not clear. But it was confirmed by several current and former officials, who spoke on the condition of anonymity because the matter is classified.

The data does not include purely domestic transfers or bank-to-bank transactions, several officials said. Another, while not acknowledging the program, suggested that the surveillance court had imposed rules withholding the identities of any Americans from the data the C.I.A. sees, requiring a tie to a terrorist organization before a search may be run, and mandating that the data be discarded after a certain number of years. The court has imposed several similar rules on the N.S.A. call logs program.

Several officials also said more than one other bulk collection program has yet to come to light.

“The intelligence community collects bulk data in a number of different ways under multiple authorities,” one intelligence official said.

Dean Boyd, a spokesman for the C.I.A., declined to confirm whether such a program exists, but said that the agency conducts lawful intelligence collection aimed at foreign — not domestic — activities and that it is subject to extensive oversight.

“The C.I.A. protects the nation and upholds the privacy rights of Americans by ensuring that its intelligence collection activities are focused on acquiring foreign intelligence and counterintelligence in accordance with U.S. laws,” he said.

Juan Zarate, a White House and Treasury official under President George W. Bush, said that unlike telecommunications information, there has generally been less sensitivity about the collection of financial data, in part because the government already collects information on large transactions under the Bank Secrecy Act.

“There is a longstanding legal baseline for the U.S. government to collect financial information,” said Mr. Zarate, who is also the author of “Treasury’s War,” about the crackdown on terrorist financing. He did not acknowledge the C.I.A. program.

Orders for business records from the surveillance court generally prohibit recipients from talking about them. A spokeswoman for one large company that handles money transfers abroad, Western Union, did not directly address a question about whether it had been ordered to turn over records in bulk, but said that the company complies with legal requirements to provide information.

“We collect consumer information to comply with the Bank Secrecy Act and other laws,” said the spokeswoman, Luella Chavez D’Angelo. “In doing so, we also protect our consumers’ privacy.”

In recent months, there have been hints in congressional testimony, declassified documents and litigation that the N.S.A. program — which was disclosed by Edward J. Snowden, a former N.S.A. contractor — is not unique in collecting records involving Americans.

For example, the American Civil Liberties Union is fighting a Freedom of Information Act lawsuit for documents related to Section 215 of the Patriot Act, the provision that allows the government to compel companies to turn over business records for counterterrorism purposes. After the government declassified the N.S.A. phone records program, it has released many documents about it in response to the suit.

But the government has notified the A.C.L.U. that it is withholding two Foreign Intelligence Surveillance Court rulings invoking Section 215 — one dated Aug. 20, 2008, and the other Nov. 23, 2010 — because they discuss matters that remain classified, according to Alexander Abdo, an A.C.L.U. lawyer. “It suggests very strongly that there are other programs of surveillance that the public has a right to know about,” Mr. Abdo said.

In addition, a Justice Department “white paper” on the N.S.A.’s call records program, released in August, said that communications logs are “a context” in which the “collection of a large volume of data” is necessary for investigators to be able to analyze links between terrorism suspects and their associates. It did not say that call records are the only context that meets the criteria for bulk gathering.

In hearings on Capitol Hill, government officials have repeatedly avoided saying that phone logs — which include date, duration and numbers of phone calls, but not their content — are the only type of data that would qualify for bulk collection under the Patriot Act provision. In a little-noticed exchange late in an Oct. 3 hearing before the Senate Judiciary Committee, Gen. Keith B. Alexander, the N.S.A. director, appeared to go further.

At the hearing, Senator Mazie K. Hirono, Democrat of Hawaii, asked General Alexander and James R. Clapper Jr., the director of national intelligence, a sweeping question: “So what are all of the programs run by the N.S.A. or other federal agencies” that used either Section 215 of the Patriot Act or another surveillance law that allows warrantless wiretapping of phone and emails?

General Alexander responded by describing, once again, the N.S.A.’s call records program, adding, “None of that is hid from you.” Mr. Clapper said nothing.

Then, moments later, General Alexander interjected that he was talking only about what the N.S.A. is doing under the Patriot Act provision and appearing to let slip that other agencies are operating their own programs.

“You know, that’s of course a global thing that others use as well, but for ours, it’s just that way,” General Alexander said.

In September, the Obama administration declassified and released a lengthy opinion by Judge Claire Eagan of the surveillance court, written a month earlier and explaining why the panel had given legal blessing to the call log program. A largely overlooked passage of her ruling suggested that the court has also issued orders for at least two other types of bulk data collection.

Specifically, Judge Eagan noted that the court had previously examined the issue of what records are relevant to an investigation for the purpose of “bulk collections,” plural. There followed more than six lines that were censored in the publicly released version of her opinion.

Lawmakers on the House and Senate Judiciary Committees have been trying to gain more information about other bulk collection programs.

In September, Representative Jim Sensenbrenner, Republican of Wisconsin and an author of the original Patriot Act, sent a letter to Attorney General Eric H. Holder Jr. asking if the administration was collecting bulk records aside from the phone data. An aide said he had yet to get a response. Even lawmakers on the Intelligence Committees have indicated that they are not sure they understand the entire landscape of what the government is doing in terms of bulk collection.

Senators Dianne Feinstein of California and Saxby Chambliss of Georgia, the top Democrat and Republican on the Senate Intelligence Committee, recently sent a classified letter to Mr. Clapper asking for a full accounting of every other national security program that involves bulk collection of data at home or abroad, according to government officials

Michael Hearns an Anti Money Laundering specialist with over 27 years of AML experience can also be found at:www.launderingmoney.com and on twitter at :http://twitter.com/#!/LaunderingMoneyas well as his blog at:http://moneylaunderingworld.blogspot.com

Mexican Drug Cartels Laundering Money through Horse Stables

By George H Wittman
American Spectator

In recent weeks Mexican cartel money laundering operations in the United States have been exposed as imaginative and daring. In the two principal cases uncovered, very different devices were used by the drug trafficking managers. These cases are an introduction to the breadth of mechanisms available to turn dirty money clean.
Perhaps the operation that had the most elaborate cover, yet a still relatively simple financial structure, was the most forward-looking. One of the top figures in Mexico's Los Zetas drug organization, Miguel Angel Trevino Morales, had a younger brother who liked horses, needed a job, and was available to manage a ranch (bought through an intermediary with drug profits) south of Oklahoma City.

Along with his wife and three children, young José Treviño Morales set about to establish himself as an owner/breeder of quarter horses. He paid for everything in cash or by using false names and accounts of supposed partners. Treviño Morales and his considerable ranch staff of fourteen built a reputation of fair bargaining and quick payment. The 400-plus horse enterprise was the envy of many other breeders with less deep pockets, but any annoyance was quickly salved by the fair and generous business practices of the Treviño Morales operation.

Meanwhile millions of dollars in cash accrued by the drug trafficking operation of the Zetas was "cleansed" in the accounting for the high maintenance quarter horse breeding and racing business. The stable's reputation grew as it began to turn out serious winners on the track and at the auctions in Oklahoma, Texas, New Mexico, and California. The overall operation was incorporated since 2008 as Tremor Enterprises LLC -- and they paid all their bills on time.

The New York Times once again appears to have had an inside source within law enforcement, for when it broke the story on June 12 citing its "investigations lasting months" and anonymous sources, federal authorities, including FBI Special Agents, swooped in on the ranch the same day. They were able to arrest only 7 of the 14 indicted, including José Treviño Morales and his wife. Whether this was due to the Times's early publication has not been surfaced. At this point, however, the U.S. Government has seized 41 of the choicest horses and is arranging for the care of the other 384.

While the Treviño Morales horse breeding operation reportedly successfully "cleaned" tens of millions of dollars -- and won some very large racing purses on the side -- another less romantic money laundering and drug trafficking dance was in process in nearby Western and Midwestern states. Due to the United States' tightening of controls on the production of chemicals used in the making of methamphetamine, the manufacture and shipment of meth from Mexico has grown exponentially.

Many mid-sized American gangs purchase cargos of meth either directly from Mexican cartel producers or intermediaries who have illegally transported the product over the Mexican/U.S. border using both witting and unwitting truck drivers. The meth is then carried from border sites to middlemen in California, Colorado, and elsewhere central to the customer base. One such operation, according to the DEA, owned both a legitimate trucking company and an import/export firm. The latter carried licenses to import goods from China, thus allowing a legal route for money to flow to China and then return in goods or money transfers to Mexico -- and the cycle would begin again.

While there are several versions of the foregoing used in money laundering, one of the most reliable remains the utilization of the real estate market. Purchase and resale of high-end real estate properties (residential or commercial) has been a natural route for cleaning dirty money. Resale at an appropriate price to a bona fide entity creates a cleansed account and money that can be transferred anywhere in the world.

There are many mechanisms now employed by the drug cartels to clean up the cash they obtain through illicit drug sales in the United States and Canada. All that is needed is an intermediary that can maintain the appearance of a legitimate cash flow (such as service and import/export concerns), and careful accounting takes care of the rest. Casinos and high volume restaurants are always an attractive money laundering target. While new and different mechanisms always become available, funneling money into the American stock and commodity markets remains a high priority objective.

The establishment of a legitimate-appearing identity is the sole criterion for creating an investment account allowing considerable sums to be moved around domestically and internationally. Clean identities have evolved through repeated transfers of money from Mexico and other Latin American sources to the Gulf States of the Middle East, China, Southeast Asia and eventually to the usual small countries with discreet banking and taxation laws. It takes quite a bit of imaginative accounting, but it's worth the effort to cover the original sources.

Thus it is the establishment of an acceptable identity that is the key to all illegal money movement. It need not be as elaborate as horse breeding; it can be as simple as what the KGB used to call a "documented legend" that involves a birth certificate, Social Security number -- or equivalent -- and exclusive club membership plus well-distributed cash. This and a few other accoutrements and the money launderer is ready to have a respected friend call his local hard-charging broker with a new client. The securities business swears it's much harder than that, but the Bernie Madoff case showed how social connections and well-covered accounting make a swindle work. The laundering con works the same way



Michael Hearns an Anti Money Laundering specialist with over 24 years of AML experience can also be found at http://www.launderingmoney.com/ and on twitter at : http://twitter.com/#!/LaunderingMoney http://moneylaunderingworld.blogspot.com/   and http://launderingmoney.com/

Regulators hit Miami Gardens credit union with cease and desist order

 

 

By Brian Bandell

South Florida Business Journal

Federal regulators issued a cease and desist order against North Dade Community Development Credit Union for violations of anti-money laundering laws.

Such enforcement actions against credit unions are rare. This is the only cease and desist order issued by the National Credit Union Administration (NCUA) so far this year.

The credit union has only $5.8 million in assets. It was “well capitalized” on June 30, an improved from its “undercapitalized” status a year ago.

The NCUA order on Aug. 29 gave it 30 days to suspend all transactions for money services businesses that aren’t within its geographic area of membership. Credit unions are only allowed to deal with customers in pre-defined geographic areas. In the case of North Dade Community Development, the area is the north-central part of the county.

The regulatory order also told the credit union to stop all business with money service businesses until it implements adequate Bank Secrecy Act, anti-money laundering and Office of Foreign Asset Control (OFAC) compliance. This includes establishing criteria for identifying high-risk members, detecting when transactions involved prohibited countries or individuals, and timely filing suspicious activity reports and currency transaction reports.

It was given 30 days to find an employee responsible for this job, conditional upon approval by regulators

Michael Hearns an Anti Money Laundering specialist with over 24 years of AML experience can also be found at:

http://.launderingmoney.com and on twitter at: http://twitter.com/#!/LaunderingMoney also on http://moneylaunderingworld.blogspot.com

Money Laundering Among Regulators' Top Priorities

      

 

 

 

 

By: Kenneth Corbin

Anti-money laundering policies were identified by both FINRA and the SEC as a top priority for examinations of broker-dealers in 2013. In its exam guidance, FINRA noted "an increase in foreign currency conversion transactions." It also stressed that there are no exemptions from the AML requirement for member firms, even if the company holds no customer funds.

What this means for advisors is clear. Although, by statute, an advisor isn't required to have his or her own individual AML policy, all advisors are covered by—and expected to uphold—their firm's AML policy. And FINRA is paying close attention to how well advisors execute the task.

"Anybody who works at a broker-dealer will have an obligation to implement the policies that the firm is under," says Sarah Greene, senior director of AML compliance with FINRA's enforcement division. "An employee of a firm cannot ignore their responsibilities under this rule. For a firm to comply, its people have to comply."

Broker-dealers came under the Bank Secrecy Act's AML framework under the provisions of the 2001 Patriot Act aimed at curbing money laundering and terrorist financing. The SEC's authority is limited to firms' reporting and record-keeping, while FINRA has a broader enforcement mandate that covers a complete AML program and generally operates as the lead regulator.

At a minimum, FINRA expects firms to set policies and procedures to detect and report suspicious transactions. They must also conduct independent testing of the program, designate an AML officer and provide advisors, broker-dealers and other personnel with ongoing training.

Although advisors aren't likely to be the focal point of an AML enforcement action by FINRA, it does happen. A recent case involving Raymond James Financial Services suggests that regulators are taking a broader view of money laundering cases and raising their expectations that financial firms establish a culture of vigilance.

The case, which Raymond James settled without admitting guilt, involved an investor who was moving large volumes of funds through his brokerage account and then writing checks for round dollar amounts from a money market account. It was a Ponzi scheme that amounted to losses of $17.8 million for investors, and the account holder received a prison sentence of 20 years.

FINRA cited Raymond James for failing to maintain an adequate AML policy, and while the company's AML officer and legal team were not exempt from blame, some of the sharpest criticism was leveled at staffers in an Ohio branch office. The letter described a string of inquiries from the AML officer asking about suspicious transactions that were not addressed by a registered representative and office manager. At one point late in the game, the investor told branch staffers that he had committed fraud and was headed to jail. No one relayed that information to Raymond James' AML officer.

Know Your Laundry
Experts stress that advisors' obligations under AML policies vary from firm to firm.Each company's policy must be tailored to the nature of the practice, accounting for the risks associated with clients, geographic footprint and business model.

For advisors, much of the risk involved with money laundering sits at the front end, in the process of onboarding new clients. Advisors must adhere to the procedures in their firm's customer identification program, a required element in FINRA's AML program template. Advisors should ask prospective clients for representations about their identity and assets and then do their own background checking based on the information provided.

Advisors should be checking prospective clients against the Treasury Department's Office of Foreign Assets Control list of foreign countries, terrorists, drug traffickers and others barred from trade with U.S. firms, as well as other relevant overseas databases. Commonly firms will engage a third-party vendor to perform those onboarding cross-checks.

Then, too, an AML program should aim to ensure the investor is not moving money through a shell bank, which can sometimes be verified by obtaining a foreign bank certificate. Likewise, advisors might probe investors' political connections to determine whether a prospective client may be deemed a "senior foreign political figure" under the Patriot Act.

Much of that monitoring can be automated, with reports of high-volume trades, large cash transfers and other exceptional activity routinely delivered to the firm's AML officer. But any effective AML program also counts a strong human element provided by advisors who often know their customers and their investment objectives best. This is a crucial line of defense in flagging suspicious activity.

Look for Danger Signs
Advisors have a fair amount of discretion in how they handle dubious activity, although experts note that some flags are redder than others. "If they are asked to facilitate sending a wire out of the account to an Iranian bank, that's clearly some suspicious activity," says Byron Bowman, general counsel at consulting firm fi360.

Other potential warning signs include investors who move large volumes of cash equivalents through their accounts and do so frequently.

Call for Backup
That's not to say that there aren't false positives. What if a customer puts in an order to liquidate all of his or her assets and arrange for a wire transfer to Costa Rica? Although this might appear to be an unusual transaction, it's not necessarily one to send the advisor running to the Feds. Often, the first call will be to compliance.

Compliance, in turn, might tell the advisor to get in touch with the client and find out what's going on. After all, the client requesting the wire transfer could have just bought a house in Costa Rica, where he or she plans to retire.

If an advisor can't obtain a reasonable explanation and concludes that the matter should be escalated—often a wrenching decision when a longstanding client is involved—the next stop will be back at the compliance department. At that point, compliance would determine whether the case warrants the firm filing a suspicious activity report with the Treasury Department's Financial Crimes Enforcement Network.

Once the matter is in the hands of compliance, the advisor is often shut out of the process due to the highly sensitive nature of filing a report. Then the firm must make the call, often in consultation with law-enforcement authorities, about whether to keep the account open or cut ties with the client.

Michael Hearns an Anti Money Laundering specialist with over 24 years of AML experience can also be found at http://www.launderingmoney.com/ and on twitter at : http://twitter.com/#!/LaunderingMoney also http://moneylaunderingworld.blogspot.com/   and http://launderingmoney.com/

HSBC still in crosshairs of intrest group

By The Huffington Post

Everett Stern didn't realize that becoming a whistleblower would change his life. Not only did he lose his job and career at HSBC, and become blacklisted from the banking industry, he now sleeps with a gun by his bed after receiving death threats on a regular basis. He can barely afford a ticket to New York City to speak at a press conference this Thursday Aug. 29, at noon on the steps of the New York Public Library. But he isn't worried. According to the former bank employee, he will stop at nothing to expose HSBC's continued actions of laundering money for terrorists groups. Although the  bank paid a 1.9 billion penalty in 2009,Stern claims he has evidence that HSBC continued to launder money during his tenure after they admitted that they had stopped in 2010.

"The public needs to know that money is still being funneled through HSBC to directly buy guns and bullets to kill our soldiers. Fines are not acceptable. I want a criminal indictment of HSBC executives," he asserts. "And if I die because of this, my life will have been worthwhile."

A noble cause doesn't mean people will listen to you. During his employment with HSBC as an AML (Anti-Money Laundering officer), Stern found discrepancies and brought them to the attention of his supervisors. Through an Internet search, Stern found a Saudi fruit company was sending millions to a high-ranking figure in the Yemeni wing of the Muslim Brotherhood. Stern also uncovered that HSBC was allowing millions of dollars to be moved from the Karaiba chain of supermarkets in Africa to a firm called Tajco, a company that had been singled out by the US Treasury Department as major financiers of the Lebanese Shiite group, Hezbollah. Stern's supervisors, however, told him to not make waves and keep "clearing the quota of 72 alerts per week."

Stern then took his evidence further, notifying appropriate government agencies such as the FBI, CIA and SEC, about violations of US money laundering laws. All efforts fell on deaf ears -- the excuse being that prosecuting the Too Big To Fail bank would precipitate a financial collapse. Frustrated with the lack of action, Mr. Stern recently decided to take the case public, approaching various media outlets, in addition to Occupy Wall Street. By doing so, he has given up a multi-million dollar whistleblower award.

"This is not a Democrat or Republican issue," he said. "Banks financing drug cartels and terrorists affects every single American. I went to Occupy not because I am a major supporter of the movement. I went because they care enough to hit the streets, carry signs and send a message that I also believe in."

The OWS Alternative Banking Working Group, working in conjunction with Stern for tomorrow's protest, agrees. "Everett Stern is able to give us a mountain of information and point us in the right direction to apply effective pressure," says Cathy O'Neil, the Alternative Banking lead organizer. "In turn, we are able to give him an army of supporters and a populist megaphone with a proven ability to get the public's attention." 

Michael Hearns an Anti Money Laundering specialist with over 24 years of AML experience can also be found at http://www.launderingmoney.com/ and on twitter at : http://twitter.com/#!/LaunderingMoney  and http://moneylaunderingworld.blogspot.com/   and http://launderingmoney.com/

Money is oxygen for terrorism

 

 

By bdnews24.com

The US Ambassador to Bangladesh, Dan Mozena, has stressed the need to cut off money supply to terrorists, saying it acts like oxygen for terrorism. “Money and terrorism can be two sides of the same coin. Money [is] the facilitator of terrorism. Money [is] the enabler of terrorism. Money [is] the oxygen of terrorism,” he said on Monday.Mozena was speaking at the inauguration of a three-day SAARC Regional Judicial Conference on ‘Money Laundering and Terrorist Financing’ being held in a hotel in capital Dhaka. The conference has been organised in collaboration with the Counter-terrorism Bureau of the US State Department.

“To defeat terrorism, we must cut off the oxygen supply. We must cut off the flow of money, and that is where you come in,” he told attending judges. He said, “You [are the] brave judges from across South Asia. Your critical task is to suffocate terrorism, to deprive terrorism of the money. It’s needed for the people, our societies and our countries. Nobody said this is easy, it is not. Nobody said this is without risk.”
But he emphasized the importance of attacking and stopping the flow of money to terrorists to enable “the people of our respective countries to live in peace, in harmony. So they can build better lives for themselves and for their children”.

The US Ambassador, however, said judges were not the only players in this battle against money laundering.

He said, “Parliament must enact robust laws targeting financial crimes and money laundering, and bringing these laws up to international standards.” He said the US and Bangladesh had partnered to craft powerful laws, providing the tools needed to put money launderers behind bars.

Parliament had enacted them, and they were now being enforced, he said.

“Parliament must provide law enforcing agencies and the judiciary the resources needed to defeat money laundering,” he observed. He said the police, other law-enforcing agencies, intelligence agencies, and the military must play their part in apprehending money launderers and in gathering evidence needed for conviction.
He said as money launderers and terrorists became more sophisticated, security agencies, too, were expected to develop new skills and adopt new technologies.

“Countries of the region and beyond must better cooperate with each other, must better share information, must better appreciate that while borders and questions of sovereignty have historically constrained nation’s ability to work together, criminal and terrorists are not limited by such thinking,” he emphasized.
He said the nations of the region and beyond, must commit themselves to deeper cooperation in fighting money laundering and terrorism. He felt it was important for prosecutors to be professionals of integrity, capable of effectively presenting their case in court.

“And that brings us full circle back to you,” he said, referring to the judges, whom he described as linchpins in bringing money launderers and terrorists to justice. “You may have the toughest role to play,” he said, pointing out that judges had to ensure fairness, prevent violation of rights, and make sure that anti-terrorism and money-laundering laws were not used a political tools. He appealed to judges to encourage international cooperation “in this battle and admit into court evidence from international partners, to the fullest extent of law”. Judges should also ensure that their sentences, aimed at protecting people and deter criminals, were properly executed, he added

Michael Hearns an Anti Money Laundering specialist with over 24 years of AML experience can also be found at http://www.launderingmoney.com/ and on twitter at : http://twitter.com/#!/LaunderingMoney  and http://moneylaunderingworld.blogspot.com/  and  http://launderingmoney.com/

Chinese-Canadian refugee admits laundering $12m in four years; He used three different passports to open bank accounts

 

 

By Province News Services

 

A Chinese-Canadian man admitted laundering more than HK$95 million (about $12.8 million) over four years through bank accounts he had opened using three different passports. Xie Jing-feng, also known as David Chow, 56, pleaded guilty in the Hong Kong District Court to one count of money laundering, the South China Morning Post reported.
Prosecutor Leslie Parry told the court that Xie was born on the Chinese mainland. He entered Canada in 1997 as a refugee and was granted citizenship after five years. Xie and his wife, Zhu Li-chang, both hold Canadian passports, the paper said. Xie, who is not resident in Hong Kong, used a Canadian passport to open an integrated account at HSBC in June 2005, the court heard. The following year, he opened a savings account at Hang Seng Bank using a second Canadian passport that was also in his name but with a different number.
In May 2007, Xie produced a third Canadian passport to open two accounts at Standard Chartered Bank for his company, Civil Finance Limited. He stated that he was a director of the company. Between June 2005 and April 2009, the court heard, Xie used the four accounts — along with five others that were held by his companies or wife — to launder more than HK$95 million.
No tax returns were submitted to the Inland Revenue Department by either Xie or his companies during this period, The South China Morning Post said. Police began investigating Xie in 2008. He was jailed for eight months in November 2011 after being stopped at the mainland border for using a fake Malaysian passport. He pleaded guilty to the charge in Sha Tin Court. After further investigation, Xie was arrested for money laundering when he was released from jail on April 30 last year. Judge David Dufton adjourned sentencing until Thursday.

 

Michael Hearns an Anti Money Laundering specialist with over 24 years of AML experience can also be found at http://www.launderingmoney.com/ and on twitter at : http://twitter.com/#!/LaunderingMoney  and http://moneylaunderingworld.blogspot.com/   and http://launderingmoney.com/

Armenian gets 6 years, 4 months for laundering money from phony Medicare claims

By Terry Dickson
Florida Times Union

A Los Angeles man will serve six years, four months in prison for laundering money through a Brunswick storefront in a nationwide Medicare fraud scheme and will face deportation to Armenia when he is released.
Chief U.S. District Judge Lisa Godbey Wood also ordered Avetik Moskovian to pay nearly $309,000 in restitution and to serve three years on probation. Moskovian pleaded guilty in April to conspiring to launder money with Shahak Tumanyan and others in a scheme that was based in Los Angeles and operated shell corporations in Brunswick, Savannah, Buffalo, N.Y., Albuquerque and Chicago among other places.
Moskovian begged Wood for mercy.

“I plead with you not to destroy my family. I have children. This will have a great impact on their future,’’ he said.

But Wood went well above the 20-month sentence that Moskovian’s lawyer, George M. Mgdesyan asked for and said she went toward the top of the advisory sentencing guidelines. Wood noted Mgdesyen’s assertion that Moskovian had worked hard.

“He worked very hard at laundering money,’’ she said.

The mastermind of the scheme, Arthur Manasarian, is serving 14 years in prison and must repay $1.8 million of the more than $7 million that he and others gained by submitting and collecting on false Medicare claims for medical devices. The defendants stole the Medicare identities of patients and providing physicians and used them to bill the government for wheelchairs, canes, walkers and other devices that were never delivered to anyone. In Brunswick, the bills were submitted from a company called Brunswick Medical Supplies, which was nothing more than a storefront with a phone.

During Moskovian’s sentencing hearing Monday, FBI Special Agent Tony Alig testified that the FBI and Department of Health and Human Services investigators had identified 15 businesses that Moskovian had created solely to launder money. Mgdesyan, also of Los Angeles, said that Moskovian had come to the country in 1988 and had worked ever since to support his family. Moskovian told the court when he pleaded guilty in April that he had driven a cab and limousine and had owned a service station, a cell phone business and recycling business.

Wood said the government had trouble verifying some of his work history. It appeared that a lot of his employment was on a cash basis, she said. Mgdesyan said that unlike Tumanyan, who had fled from the government, Moskovian had admitted his guilt and that he was worried about supporting his wife and their three daughters, two of whom will be in college in a few days.

“He feels embarrassed he’s let them down,’’ Mgdesyan said.

Moskovian did not hide anything and laid out all he knew to investigators, Mgdesyan said. Although Moskovian’s admissions made the government’s case stronger, Assistant U.S. Attorney Brian Rafferty told Wood, the case resulted from five years of hard work by government agents.

“The truth is, we were going to be here anyway,’’ Rafferty said.

The money laundering scheme that Moskovian set up was very sophisticated with multiple bank accounts and shell businesses: Once the Medicare checks came in, Moskovian began moving the money between accounts until it came out as cash, Rafferty said. Mgdesyan asked that he be allowed to go home to Los Angeles for two weeks before reporting to the Bureau of Prisons, but Wood remanded him immediately to the U.S. Marshals Service.


Michael Hearns an Anti Money Laundering specialist with over 24 years of AML experience can also be found at http://www.launderingmoney.com/ and on twitter at:  http://twitter.com/#!/LaunderingMoney  and http://moneylaunderingworld.blogspot.com/   and  http://launderingmoney.com/

Former SWAT team member and Officer Survival Instructor Michael Hearns offers school survival tips for educators and students faced with a deadly scenario

Many people who read this blog know of me as a former undercover police detective who worked within the Medelin and Cali drug cartels. Among other things I am a certified Officer Survival Instructor and a former lead penetrator on the SWAT team. Below are my suggestions to make a school enviornment safer for educators and students,
and what to do if a Newtown/Columbine situation should arise:


1.     Office gossip is a mess and we all  understand that but if a
co worker is having marital problems or other domestic issues that
can be transcended to work just keep abreast of it all. Bring some wooden
 wedges (no not the shoes ....the little triangle pieces of wood) to the office
 and keep them in your desk.  Something breaks bad you can
wedge the door as well as lock it.  If the lock gets opened or broken
they still can't open the door. When I was on the entry team
with SWAT I carried 3-4 of them in my cargo bdu's and there were times
when we as a team had to keep moving and could not check every
 door, so I would wedge them and then we would come back and check them.

2.     Know your exits, and know the alternative exits as well.
Count the steps to the exits so that in a smoke filled environment
you can count your way to the door.

3.     Know your fire extinguishers too...a blast of CO2 smoke can
maybe be enough to get you out in the concealment. Plus those
exstinguishers  hurt when you clang someone with them. Keep a
good large can of aerosol Lysol in the classroom, it blends in
well, so no one will question it being there but stings the crap
out of eyes when sprayed into them

4.    Be cognizant of your reflection in glass, aquariums, coffee pots
etc..you could be hiding and not know that you are being reflected
in the glass to the bad guy.

5.   Phone lines can be cut. Keep a cell in the classroom. put it on
silent but keep it on. It will take too long to boost up if you
have to turn it on.

6.   If your classroom door has a window have a ready to use
shade.piece of paper, contact paper, shelf liner etc precut and
ready to sticky tack up to cover the window so that an offender
can't look in and see you and your students.

7.   Keep 5-6 good size unopened soup cans in the classroom. Once
again it blends nicely no one will suspect anything. Put the cans
in a pillowcase and twist the case, makes a heck of a swing type
weapon or you can throw the cans  at either an offender or a stuck
window to break it open.


Michael Hearns an Anti Money Laundering specialist with over 24 years of AML experience can also be found at http://www.launderingmoney.com/ and on twitter at : http://twitter.com/#!/LaunderingMoney http://moneylaunderingworld.blogspot.com/   and http://launderingmoney.com/

Scott Rothstein’s wife, others charged in money-laundering plot to sell jewelry

By Jay Weaver
Miami Herald

The wife of imprisoned Ponzi schemer Scott Rothstein and two other people were charged Thursday with plotting to hide and sell more than $1 million worth of jewelry from the former Fort Lauderdale lawyer’s waterfront home before federal agents seized his assets three years ago.Kimberly W. Rothstein, her friend, Stacie Weisman, and the wife’s lawyer, Scott F. Saidel, were charged with money-laundering conspiracy, obstruction of justice and tampering with a witness in federal court.
Prosecutors said that by concealing the valuable jewelry, the three defendants prevented Internal Revenue Service agents from confiscating the property when they searched Rothstein’s home in November 2009. His wife and Weisman are accused of selling some of the jewelry to others, including Eddy Marin and jeweler Patrick Daoud, who were indicted on separate charges Thursday.
Among the jewelry items: a 12.08-carat diamong ring, according to federal prosecutors.
Kimberly Rothstein, Weisman and Saidel are also accused of seeking to have Scott Rothstein testify falsely during his deposition in a related civil bankruptcy proceeding involving his defunct law firm, Rothstein Rosenfeldt & Adler.
All five defendants are also accused of concealing the true location of certain items of jewelry during the bankruptcy proceeding to prevent the former law firm’s trustee from recovering them for victims of Rothstein’s $1.2 billion scheme. Marin and Daoud are separately accused of commiting perjury during depositions in the bankruptcy case.
“When a witness lies under oath or conspires to obstruct justice, the integrity of our system of justice is undermined,” U.S. Attorney Wifredo Ferrer said.
Rothstein is serving a 50-year sentence after pleading guilty to racketeering and other fraud charges involving the sale of purported legal settlements to investors from Florida to New York. Eight other people have been convicted on charges related to his scheme, among the largest in Florida history.
Kimberly Rothstein’s defense attorney, David Tucker, issuing a statement, saying while she claims she was not aware of her husband’s racketeering activities, “She takes full responsibility for her actions in regard to the charge filed today.”

Read more here: http://www.miamiherald.com/2012/09/06/v-print/2987970/scott-rothsteins-wife-others-charged.html#storylink=cp
y

Michael Hearns an Anti Money Laundering specialist with over 24 years of AML experience can also be found at http://www.launderingmoney.com/ and on twitter at : http://twitter.com/#!/LaunderingMoney  and http://moneylaunderingworld.blogspot.com/ 

Griselda Blanco Queen of Cocaine....hardly!

By Michael Hearns
http://launderingmoney.com


The recent murder of Griselda Blanco in Medellin Colombia closes a sad a and tragic chapter on the brutality of the cocaine trade. At least that is what many would like for you to believe.  Griselda Blanco's murder should be viewed for exactly what it is; another violent end to marginalized sociopath who has been given undeserved iconic status by the print and visual media.

Griselda Blanco was a sociopathic remorseless entrepreneur who slithered through a crevice in American law enforcement that was unprepared and without capable resources and foresight to recognize the tsunami of illicit dollars and power that was being ushered in through the cocaine trade of the 1980's and 90's. Griselda Blanco was an opportunistic individual who used her guile and sociopathology to insulate her as she trampled across the boundaries of decency in what we know to be an indecent business; drug trafficking. She has been given demigod status  for her harsh, abrasive, quick tempered, ruthless, conniving ways and her fast penchant for ordering the execution of those she opposed by her spineless groveling minions.  For all the bluster and for all the talk that that her hired henchmen now spout from the confines of this nation's penitentiaries they themselves had plenty of opportunity to dispatch Griselda Blanco but for either lack of conviction or lack of cerebral mass they  continued to carry out her murderous ways helping to support the fallacy of  Griselda Blanco as a Godmother of Cocaine.

Lets face facts. Griselda Blanco was an integral cocaine trafficker within the Medellin Cartel and she sanctioned, paid for, and demanded that many of her competitors, those who crossed her, and those who stood in the way of her ascension for wealth be murdered. Her distinction from her contemporaries was simply gender. Aside form that she is no different than many of the male drug traffickers who partook in their craft in the 1980's and 90's. As a society we lionize women villains because it grates against the American psyche of women being maternal, nurturing, and a source of comfort. Ma Barker, Bonnie Parker, Aileen Wournos, and Annie Palmer have all ascended to a folklore like status as queens or godmothers of crime and murder.

It is easy to view the life of Griselda Balnco from the viewfinder of a movie camera or the soft glow of a computer monitor and surmise she was the "Queen of Cocaine" or "The Godmother of Cocaine."  Not having the privilege of either but being one of the few who actually had his feet on the ground in the cocaine world for a long time  it is apparent to me that the reality is she was a large scale cocaine trafficker who clawed, cheated, and murderously existed in a business that rewards the victor regardless of the method.

Nothing more.
Nothing less.

The biggest current mistake being made is the assumption that Griselda Blanco was murdered  to settle an old score or to appease a long time  former adversary. More than likely it is because the criminal element of Medellin has been able to exist quietly in the shadow of the Mexican Cartel and Griselda Blanco's notoriety was becoming troublesome. Talks of more movies and books have filled the air. Crime and notoriety usually never mix well. In this case the celluloid film and the pen may have actually been stronger the sword.


Michael Hearns an Anti Money Laundering specialist with over 24 years of AML experience can also be found at http://www.launderingmoney.com/ and on twitter at : http://twitter.com/#!/LaunderingMoney  and http://moneylaunderingworld.blogspot.com/  

Where the Mob Keeps Its Money

By Roberto Saviano

New York Times

The global financial crisis has been a blessing for organized crime. A series of recent scandals have exposed the connection between some of the biggest global banks and the seamy underworld of mobsters, smugglers, drug traffickers and arms dealers. American banks have profited from money laundering by Latin American drug cartels, while the European debt crisis has strengthened the grip of the loan sharks and speculators who control the vast underground economies in countries like Spain and Greece.

Mutually beneficial relationships between bankers and gangsters aren’t new, but what’s remarkable is their reach at the highest levels of global finance. In 2010, Wachovia admitted that it had essentially helped finance the murderous drug war in Mexico by failing to identify and stop illicit transactions. The bank, which was acquired by Wells Fargo during the financial crisis, agreed to pay $160 million in fines and penalties for tolerating the laundering, which occurred between 2004 and 2007.

Last month, Senate investigators found that HSBC had for a decade improperly facilitated transactions by Mexican drug traffickers, Saudi financiers with ties to Al Qaeda and Iranian bankers trying to circumvent United States sanctions. The bank set aside $700 million to cover fines, settlements and other expenses related to the inquiry, and its chief of compliance resigned.

ABN Amro, Barclays, Credit Suisse, Lloyds and ING have reached expensive settlements with regulators after admitting to executing the transactions of clients in disreputable countries like Cuba, Iran, Libya, Myanmar and Sudan.

Many of the illicit transactions preceded the 2008 crisis, but continuing turmoil in the banking industry created an opening for organized crime groups, enabling them to enrich themselves and grow in strength. In 2009, Antonio Maria Costa, an Italian economist who then led the United Nations Office on Drugs and Crime, told the British newspaper The Observer that “in many instances, the money from drugs was the only liquid investment capital” available to some banks at the height of the crisis. “Interbank loans were funded by money that originated from the drugs trade and other illegal activities,” he said. “There were signs that some banks were rescued that way.” The United Nations estimated that $1.6 trillion was laundered globally in 2009, of which about $580 billion was related to drug trafficking and other forms of organized crime.

A study last year by the Colombian economists Alejandro Gaviria and Daniel Mejía concluded that the vast majority of profits from drug trafficking in Colombia were reaped by criminal syndicates in rich countries and laundered by banks in global financial centers like New York and London. They found that bank secrecy and privacy laws in Western countries often impeded transparency and made it easier for criminals to launder their money.

At a Congressional hearing  in February, Jennifer Shasky Calvery, a Justice Department official in charge of monitoring money laundering, said that “banks in the U.S. are used to funnel massive amounts of illicit funds.” The laundering, she explained, typically occurs in three stages. First, illicit funds are directly deposited in banks or deposited after being smuggled out of the United States and then back in. Then comes “layering,” the process of separating criminal profits from their origin. Finally comes “integration,” the use of seemingly legitimate transactions to hide ill-gotten gains. Unfortunately, investigators too often focus on the cultivation, production and trafficking of narcotics while missing the bigger, more sophisticated financial activities of crime rings.

Mob financing via banks has ebbed and flowed over the years. In the late 1970s and early 1980s organized crime, which had previously dealt mainly in cash, started working its way into the banking system. This led authorities in Europe and America to take measures to slow international money laundering, prompting a temporary return to cash.

Then the flow reversed again, partly because of the fall of the Soviet Union and the ensuing Russian financial crisis. As early as the mid-1980s, the K.G.B., with help from the Russian mafia, had started hiding Communist Party assets abroad, as the journalist Robert I. Friedman has documented. Perhaps $600 billion had left Russia by the mid-1990s, contributing to the country’s impoverishment. Russian mafia leaders also took advantage of post-Soviet privatization to buy up state property. Then, in 1998, the ruble sharply depreciated, prompting a default on Russia’s public debt.

Although the United States cracked down on terrorist financing after the 9/11 attacks, instability in the financial system, like the Argentine debt default in 2001, continued to give banks an incentive to look the other way. My reporting on the ’Ndrangheta, the powerful criminal syndicate based in Southern Italy, found that much of the money laundering over the last decade simply shifted from America to Europe. The European debt crisis, now three years old, has further emboldened the mob.

IN Greece, as conventional bank lending has gotten tighter, more and more Greeks are relying on usurers. A variety of sources told Reuters last year that the illegal lending business in Greece involved between 5 billion and 10 billion euros each year. The loan-shark business has perhaps quadrupled since 2009 — some of the extortionists charge annualized interest rates starting at 60 percent. In Thessaloniki, the second largest city, the police broke up a criminal ring that was lending money at a weekly interest rate of 5 percent to 15 percent, with punishments for whoever didn’t pay up. According to the Greek Ministry of Finance, much of the illegal loan activity in Greece is connected to gangs from the Balkans and Eastern Europe.

Organized crime also dominates the black market for oil in Greece; perhaps three billion euros (about $3.8 billion) a year of contraband fuel courses through the country. Shipping is Greece’s premier industry, and the price of shipping fuel is set by law at one-third the price of fuel for cars and homes. So traffickers turn shipping fuel into more expensive home and automobile fuel. It is estimated that 20 percent of the gasoline sold in Greece is from the black market. The trafficking not only results in higher prices but also deprives the government of desperately needed revenue.

Greece’s political system is a “parliamentary mafiocracy,” the political expert Panos Kostakos told the energy news agency Oilprice.com earlier this year. “Greece has one of the largest black markets in Europe and the highest corruption levels in Europe,” he said. “There is a sovereign debt that does not mirror the real wealth of the average Greek family. What more evidence do we need to conclude that this is Greek mafia?”

Spain’s crisis, like Greece’s, was prefaced by years of mafia power and money and a lack of effectively enforced rules and regulations. At the moment, Spain is colonized by local criminal groups as well as by Italian, Russian, Colombian and Mexican organizations. Historically, Spain has been a shelter for Italian fugitives, although the situation changed with the enforcement of pan-European arrest warrants. Spanish anti-mafia laws have also improved, but the country continues to offer laundering opportunities, which only increased with the current economic crisis in Europe.

The Spanish real estate boom, which lasted from 1997 to 2007, was a godsend for criminal organizations, which invested dirty money in Iberian construction. Then, when home sales slowed and the building bubble burst, the mafia profited again — by buying up at bargain prices houses that people put on the market or that otherwise would have gone unsold.

In 2006, Spain’s central bank investigated the vast number of 500-euro bills in circulation. Criminal organizations favor these notes because they don’t take up much room; a 45-centimeter safe deposit box can fit up to 10 million euros. In 2010, British currency exchange offices stopped accepting 500-euro bills after discovering that 90 percent of transactions involving them were connected to criminal activities. Yet 500-euro bills still account for 70 percent of the value of all bank notes in Spain.

And in Italy, the mafia can still count on 65 billion euros (about $82 billion) in liquid capital every year. Criminal organizations siphon 100 billion euros from the legal economy, a sum equivalent to 7 percent of G.D.P. — money that ends up in the hands of Mafiosi instead of sustaining the government or law-abiding Italians. “We will defeat the mafia by 2013,” Silvio Berlusconi, then the prime minister, declared in 2009. It was one of many unfulfilled promises. Mario Monti, the current prime minister, has stated that Italy’s dire financial situation is above all a consequence of tax evasion. He has said that even more drastic measures are needed to combat the underground economy generated by the mafia, which is destroying the legal economy.

Today’s mafias are global organizations. They operate everywhere, speak multiple languages, form overseas alliances and joint ventures, and make investments just like any other multinational company. You can’t take on multinational giants locally. Every country needs to do its part, for no country is immune. Organized crime must be hit in its economic engine, which all too often remains untouched because liquid capital is harder to trace and because in times of crisis, many, including the world’s major banks, find it too tempting to resist

Michael Hearns an Anti Money Laundering specialist with over 24 years of AML experience can also be found at http://www.launderingmoney.com/ and on twitter at : http://twitter.com/#!/LaunderingMoney http://moneylaunderingworld.blogspot.com/   and http://launderingmoney.com/