Digital currencies combine the intrinsic value of gold and other precious metals as well as the designated value of national currencies with the worldwide reach of the Internet to create an ideal mechanism for international money laundering. Users can anonymously fund digital currency accounts, send those funds (sometimes in unlimited amounts) to other digital currency accounts worldwide, and effectively exchange the funds for foreign currencies—often while bypassing U.S. regulatory oversight.

This report details key findings of the Financial Crimes Enforcement Network’s (FinCEN) assessment of Suspicious Activity Reports (SARs) filed from May 2, 2007, through April 30, 2008, by insurance companies and includes some preliminary observations about SARs filed from May 2008 through October 2009. It compares the results through April 2008 with a similar study of the first year of required reporting by segments of the insurance industry (May 2, 2006, through May 1, 2007). FinCEN analyzed insurance filings to identify typologies, patterns, and trends related to filing volume, filer location, subject details, characterizations of suspicious activities, insurance products, and other relevant information. Analysis includes summaries of SAR narratives identifying reported money laundering risks and vulnerabilities. In identifying potential trends, FinCEN reached out to representatives of the Bank Secrecy Act Advisory Group (BSAAG) to better understand what the industry is seeing with regard to these trends. That information is summarized in the Significant Findings section.

Bernie Madoff List of Counterparties, February 3, 2009.

MoneyGram Anti-Money Laundering Compliance Guides for the Caribbean and Latin America, United States, and Canada.

A basic legal framework for combating money laundering and terrorist financing is in place in the UAE, but that framework needs further strengthening in a number of areas. The AML law needs to be amended to expand the range of predicate offences and to provide greater powers for the financial intelligence unit. The FIU should also increase its own staffing so that it may operate as an autonomous unit, rather than relying on the resources of the Central Bank’s Supervision Department and other regulatory agencies.

An assessment of the anti-money laundering (AML) and combating the financing of terrorism (CFT) regime of Italy was onducted based on the Forty Recommendations 2003 and the Nine Special Recommendations on Terrorist Financing 2001 of the Financial Action Task Force (FATF) and prepared using the AML/CFT Methodology 2004. The assessment considered the laws, regulations and other materials supplied by the authorities, and information obtained by the assessment team during its mission April 4–20, 2005, and subsequently.

The financial sector in Liechtenstein provides primarily wealth-management services, including banking, trust, other fiduciary services, investment management, and life insurance-based products. There has been significant expansion recently in the non-banking areas, particularly investment undertakings and insurance. Approximately 90 percent of Liechtenstein’s financial services business is provided to nonresidents, many attracted to Liechtenstein by the availability of discrete and flexible legal structures, strict bank secrecy, and favorable tax arrangements, within a stable and well-regulated environment.

This assessment of observance of the Financial Action Task Force (FATF) Recommendations for anti-money laundering and countering the financing of terrorism (AML/CFT) has been completed as part of an evaluation of Panama’s observance of regulatory standards for the financial sector.

Criminal activity in the Czech Republic that generates major sources of illegal proceeds is comparable to criminal activity in other countries in transition. Economic crime (e.g., fraud and asset stripping) that is linked to the privatization process is still a major concern. The authorities also mentioned tax offences as significant crime areas. Organized crime involving drug trafficking and counterfeiting of goods is also active in the Czech Republic with links to the region and Asia.

This assessment of the anti-money laundering (AML) and combating the financing of terrorism (CFT) regime of Bermuda is based on the Forty Recommendations 2003 and the Nine Special recommendations on Terrorist Financing 2001 of the Financial Action Task Force (FATF). It was prepared using the AML/CFT assessment Methodology 2004, as updated in June 2006. The assessment team considered all the materials supplied by the authorities, the information obtained on-site during their mission from May 7 to 23, 2007, and other information subsequently provided by the authorities soon after the mission. During the mission, the assessment team met with officials and representatives of all relevant government agencies and the private sector.

New sources of financial intelligence – all banks are required by law to report suspicious transactions to the SIFIU. Since 2006, banks have reported over [x] Suspicious Transaction Reports. Assisted by SIFIU, banks are required to train staff to recognise and report suspicious transactions and to appoint a Money Laundering Compliance Officer (MLRO). Key new sources of financial intelligence to commence in 2009 include Western Union Money Transfer Service, and Customs and Immigration will commence monitoring and reporting currency movements across the border of $50,000 or more in Solomon Islands Dollars (or foreign currency equivalent).

1 – Do you agree with the proposed limitations on individual, daily and monthly transactions? If not, what limitations would you propose, and what are your justifications for these limitations from an AML/CFT perspective?

Generally, Vodafone supports a risk based approach to transaction limits, with higher limits granted where KYC levels are increased. This has been applied for M-PESA in Kenya.

Article 2.5.12.2 – anti-money laundering/combating the financing of terrorism
The restriction against corporations should be removed. There does not appear to be a valid policy objective behind the restriction and no other jurisdiction of which we are aware has imposed such a restriction. One of DAB’s policy objectives is to increase access to financial services. Banks and micro-finance institutions may use EMI services to provide their services and products to large sections of the Afghan population, thereby increasing access to financial services. Given that banks and financial institutions are corporations, the proposed ban will prevent them from using such EMI services. This totally undermines DAB’s stated objective of increasing financial access. The proposed rule is manifestly disproportionate to the risks arising from EMI practices and is inconsistent with the practices of regulators in other jurisdictions.

Various studies, including those carried out by the Financial Action Task Force (FATF) over the past few years, suggest that advances in technology and the progressive tightening of anti-money laundering (AML) regulations are leading money launderers to make more complex arrangements outside the formal financial services industry, such as the use of various professional services, and in particular the real estate business.

The international community is concerned with the growing incidence of organized crime, corruption, and terrorism and the debilitating effect these problems have on peace, security and development. A successful strategy to address these international threats necessarily involves measures to address money laundering and the financing of terrorism (ML/FT).

Under the headline “Bernie’s Cancer Cell,” the New York Post reported Monday that Madoff, who was sentenced to 150 years in prison for swindling investors out of as much as $65 billion, wrote: “Bernie Madoff had little to lose by confessing to masterminding the world’s biggest Ponzi scheme — he’s dying of cancer, sources told The Post.”

The mayors of Hoboken, Ridgefield and Secaucus, New Jersey, and five rabbis were among 44 people charged by the U.S. with public corruption and money laundering. Hoboken Mayor Peter Cammarano, 32, Secaucus Mayor Dennis Elwell, 64, and Ridgefield Mayor Anthony Suarez, 42, all Democrats; Jersey City Council President Mariano Vega Jr., 59; State Assemblyman Daniel Van Pelt, 44, a Republican from Ocean Township; and Assemblyman L. Harvey Smith, a Jersey City Democrat, were charged yesterday in an FBI complaint.

Stanford Financial Group was a privately held international group of financial services companies controlled by Allen Stanford, until it was seized by United States authorities in early 2009. Headquartered in the Galleria Tower II in Uptown Houston, Texas, U.S. , it had 50 offices in several countries, mainly in the Americas, and said it managed $8.5 billion of assets for more than 30,000 clients in 136 countries on six continents.

Stanford Financial Group (SFG) was the parent company of Stanford International Bank, Ltd. and a web of other affiliated financial services entities, including Stanford Group Company. SFG maintained offices in several locations, including Houston, Texas, Memphis, Tennessee, and Miami, Florida.

Bernard Madoff, the self-confessed author of the biggest financial swindle in history, was sentenced to the maximum 150 years behind bars for what his judge called an “extraordinarily evil” fraud that shook the nation’s faith in its financial and legal systems and took “a staggering toll” on rich and poor alike.