Money Laundering and Terrorist Financing

Money Laundering and Terrorist
Financing: What are the
Criminals up to Now?
August 27, 2010
12:00PM – 2:00PM EDT
Panel is in Practice Session
1
Welcome to the ACAMS Web Seminar:
Money Laundering and Terrorist
Financing: What are the Criminals
up to Now?
2
Money Laundering and Terrorist
Financing: What are the Criminals up
to Now?
August 27, 2010
3
Dennis M. Lormel
Jeff Breinholt
President & CEO
Counsel for Law & Policy
DML Associates, LLC
National Security Division
U.S. Department of Justice
• Background
• Terrorist Groups and Their
Financial Requirements
• Criminal – Terrorist Nexus
• Current and Emerging Trends
• Money Laundering & Terrorist
Financing
• Right to Financial Privacy
• BSA Information Facilitates
Investigations
4
• Conclusion
Background
5
Current Terrorism Threat in U.S.
On April 15, 2010, Director Robert S. Mueller testified before the
Senate Committee on Appropriations, Subcommittee on
Commerce, Justice, and Related Agencies. Regarding terrorism,
he stated:
“Terrorism, in general, and al-Qaeda and its affiliates in
particular, continue to leverage proven tactics and tradecraft with
adaptations designed to address its losses and the enhanced
security measures of the United States. Al-Qaeda seeks to
infiltrate overseas operatives, who have no known nexus to
terrorism, into the United States using both legal and illegal
methods of entry…”
6
Compliance Concerns
•
Adaptations (adaptability)
– Risk recognition
•
Al-Qaeda seeks to infiltrate overseas operatives, who have no
known nexus to terrorism, into the United States (anonymity)
– Know your customer
•
What if…
– Terrorist group succeeds with attack in U.S.
– You banked them
7
• Potential adverse impact to bank
Importance of Due Diligence
•
Risk recognition
– Mitigation
– Adaptability
• Living process
•
Know you customer program
– Sound process
– Verification
•
•
Investigations
– Consistency
– Documentation
Suspicious activity reporting
– Most serious compliance breakdown
• Comprehensive
• Importance
8
•
Financial intelligence
Terrorist Threats Are Enhanced by…
• Adaptability
– Learning organizations
– Exploitation of systemic vulnerabilities
• Knowledge and learning important
• Anonymity
– Avoiding detection
– Facilitates operational success
9
AML: Current Risk Issues
•
Risk recognition
– Risk assessment
•
Know your customer (KYC) program
•
Risk mitigation
– Non-static process
– Adaptability and exploitation factor
– Cyclical nature
•
Suspicious activity reporting (SAR) process
– Importance of investigations
10
•
Diminished capacity
•
Vigilance
Terrorist Financing
•
Extremely difficult to identify
– Coordination
– Innovation
– Training
•
Not adequately understood
– Four elements must be considered
•
•
•
•
•
Terrorist groups
Funding capacity
Financial mechanisms
Individuals, entities and cells
Perspectives
– Government
– Industry
•
11
Possibility v. probability of detection
– Detection possible but not probable
– Must develop mechanisms to increase probability
Disruption of Funding Flows
•
Back to origin / forward to strike teams
– Funding to networks / organizations from point of origin
– Funding to operations
• International organizational support
• Support of specific activities / operations
– Funding to individuals, cells, or groups
12
KSM
Mohamed
Atta
Terrorist Groups and Their
Financial Requirements
13
Understanding & Disrupting Funding Flows
•
Must understand four dimensions
– Organization
– Funding Capacity
• Source of funds
• Money laundering method
• Availability of funds
Store
– Funding mechanism
• Formal financial system
• Informal system
– Group members
•
14
Raise
Spend
Funding cycle
–
–
–
–
Raise
Move
Store
Spend
Move
Types of Terrorist Groups
FBI assessment issued January 11, 2007, identified the
following groups as threats to the U.S.:
15
•
Al-Qaeda
•
Regional terrorist groups aligned with Al-Qaeda
•
Homegrown cells
•
Shia extremists
•
Palestinian terrorist groups
•
Domestic terrorist groups
Inspire Magazine
• English language online magazine published by
Al Qaeda in the Arabian Peninsula (AQAP)
– First issue July 2010
• Resource manual
– Offers blueprint for planning and executing terrorist
attacks in the West against the U.S.
• Provides explicit detail
16
• Recruitment tool to cultivate homegrown jihadists
Support to Hizballah from U.S.
•
•
•
17
Operation Smokescreen
1995 - 2000
– Hizballah fundraising cell led by Mohamed Youssef Hammoud
– Cigarette smuggling from Charlotte to Detroit
• Front / shell companies
• False identifications / fraudulent visas
• Approximately 500 bank accounts and credit cards
– 25 convictions
Four indicted for conspiring to support Hizballah
2008 - 2009
– Six others charged with related crimes
– Philadelphia, Pennsylvania
– Agreed to purchase approximately 1,200 Colt M-4 carbines, sold counterfeit currency, fraudulent
passports and counterfeit goods
Tri-Border Electronics Case
2010
– Four individuals and three freight forwarding companies indicted for illegally shipping electronics
equipment from Miami to a Hizballah controlled shopping center in Ciudal del Este, Paraguay
– Owned by Muhammad Yusif Abdallah, senior Hizballah leader in South America
– Used fake invoices, false addresses and fictitious consignees to conceal true destination of
shipments
Criminal – Terrorist Nexus
18
Terrorist and Criminal Groups
•
Must have continuous stream of funds available
– Must have capacity to raise funds
•
Fraud and money laundering often key
– Nexus between fraud and money laundering
•
Drug trafficking the most lucrative criminal activity
•
Must have immediate access to funds
•
Pose threat to national security and economy
– Importance of disruptive and preventive measures
19
Criminal Activity
•
Terrorists increasingly rely on criminal activity to raise funds
– Makes them more vulnerable
•
Terrorists are adept at exploiting systemic vulnerabilities to
facilitate and commit crimes
– They are only limited by their imagination
•
20
Investigators should remain vigilant for criminal activity which
could be linked to terrorism
OC Traits Adapted by Terrorists
• Terrorists rely on OC techniques
– Corruption
– Intimidation
– Violence
• Greed v. ideology
– Emergence of hybrid organizations
• Reliance on shadow facilitators
21
Drug Trafficking and Terrorism:
A Growing Nexus
•
Nexus between drugs and terror growing at light speed
•
DEA linked 19 terrorist organizations to global drug trade
•
DEA believes up to sixty percent of terrorist organizations
connected to illegal narcotics trade
•
As terrorist organizations become more involved in drug trade,
hybrid organizations are emerging
– Morphed into one part terrorist organization, one part global drug
trafficking cartel
• Taliban
22
• FARC
OC-Terrorism Nexus
• Organized crime groups are incorporating
characteristics and methods of operations from
terrorist groups
• Terrorist groups are adopting strategies learned
from organized crime
• This evolution makes both groups stronger and
more flexible
• Tri-border region example
23
OC – Terrorism Comparison
Terrorist Groups
Organized Crime
24
•
Motivated by profit/greed
•
Motivated by ideology
•
Seek economic ends
•
Seek political ends
•
Engage in corruption
•
Engage in corruption
•
Network and cell based structure
•
Network and cell based structure
•
Require safe-havens
•
Require safe-havens
•
Need to recruit new members
•
Need to recruit new members
•
Requires specialists
•
Requires specialists
•
Group identity important
•
Group identity important
•
Threat of violence
•
Threat of violence
•
Select targets that pose threat to the
group
•
Select symbolic
•
Avoid public attention
•
Seek public attention
•
Money laundering essential operating
tool
•
Money laundering essential
operating tool
targets
Current and Emerging
Trends
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Trends in Financial Market
• Innovation drives opportunity
• Innovation drives vulnerability/exploitation
– Increased use of electronic transfers
– Increased use of technology (advances in technology)
• Internet
• Mobile devices
– Increased use of credit/debit cards
– Decreased use of checks
– Decreased use of currency
26
• Changing regulatory/compliance environment
Rise of Electronic Payments
•
•
•
•
Moving toward elimination of cash and checks
Setting the stage for mobile commerce
Upward Trend
2000
2005
Cash
19%
18%
Check
46%
33%
Debit Card
7%
12%
Credit Card
24%
26%
Electronic Transfer
4%
11%
2010
15%
13%
30%
28%
14%
Where is the forward thinking?
– Law enforcement, regulators and compliance professionals should be
forward thinking
27
• Identify/assess future trends
• Identify areas of vulnerability
• Develop methodologies to minimize exploitation
New Payment Methods
• Services that provide virtual accounts
– Stored value cards
– Online payment services (Paypal)
– Digital currency (e-Gold Ltd.)
– Mobile payments
– Online virtual world transactions
28
The Threat
• Anonymous
• Untraceable
• Reusable
• Universally accepted
• Requires no intermediary
• Instant settlement
29
– The closer an electronic payment method comes to
mimicking cash, the greater the money laundering and
terrorist financing threat
Terrorist Exploitation of the Internet
• Psychological warfare
• Propaganda
– Recruitment
• Fundraising
• Communications
• Information gathering
– Training
30
Internet / Cyberfraud
•
Ranging from credit card fraud to money laundering
•
Terrorists can be extremely internet savvy
– Imam Samudra
• Mastermind of Bali bombing
• Jailhouse manifesto “Hacking, Why Not”
– Ali Al Marri
• Al-Qaeda facilitator for post 9/11 activity in U.S.
• Internet expert
– Younes Tsouli aka Irhabi (Terrorist) 007
• Used email and radical websites for propaganda and
communications
• Committed massive cyber crime and credit card fraud
31
Future Trends
• As society moves away from cash/checks so will
the bad guys
– Will gravitate to electronic mechanisms
– Will identify new vulnerabilities to exploit
• Law enforcement, regulators and compliance
professionals must identify and implement
mechanisms to mitigate areas of vulnerability rife
for exploitation
• Proactive vs. reactive
– Communication, cooperation, coordination
32
Mexico’s Dollar Deposit Restrictions
•
On June 10, 2010, Mexico established rules to limit U.S. dollar
deposits in Mexican banks
– Individual and corporate customers Æ USD $4,000 per month
– Non-account holders Æ USD $300 per day and $1,500 per month
•
•
•
Intended to stem flow of narcotics trafficking funds into
Mexican financial institutions
Supposed to be enforced in September, 2010
Will cause surge in deposits in U.S. and South America
– Surge in U.S. will not just be along Southwest border
– Will include money funneling points in big cities and regional
centers
•
33
Could serve as catalyst for Mexican Drug Cartels to move from
cash to new payment methods
Exploitation of Systemic Vulnerabilities
•
Terrorist and criminal organizations constantly exploit
systemic vulnerabilities
•
Vulnerabilities or high risk areas in the financial services sector
October 3, 2001*
▫ Wire Transfer
▫ Fraud
▫ Correspondent banking
▫ Money Laundering
▫ Fraud
x Wire transfer
▫ MSBs
x Correspondent banking
* Lormel testimony before House
Committee on Financial Services
34
August 27, 2010
x Illegal money
remitters/hawalas
x Shell companies
Lloyds TSB “Stripping” Case
•
Lloyds entered deferred prosecution agreement with Manhattan District
Attorney and U.S. Department of Justice on January 9, 2009
– Had correspondent relationships with banks on OFAC sanctions list to
include banks from Iran and Sudan
– Established policies and procedures to systematically “strip” (remove)
SWIFT messaging instructions to ensure U.S. banks did not identify
institutions on OFAC list
• U.S. banks led to believe bank of origination was Lloyds and not Iranian or
Sudanese banks
▫
Evaded OFAC monitoring filter
– “Stripped” out identifying features allowing Iranian banks and their
customers to wire transfer more than $530 million from 2001 to 2004
35
•
Violation of the International Emergency Economic Powers Act (IEEPA)
and New York state law
•
Lloyds paid a $350 million fine
•
Nine other international banks under investigation
Credit Suisse Case
•
Credit Suisse entered deferred prosecution agreement with Manhattan
District Attorney and U.S. Department of Justice on December 16, 2009
– Beginning as early as 1995, and continuing through 2006, Credit Suisse in
Switzerland and the U.K., altered wire transfers involving U.S. sanctioned
countries or persons
• Deliberately removed material information, such as customer names, bank
names, and addresses from payment messages so that wire transfers would pass
undetected through filters at U.S. financial institutions to evade OFAC monitoring
• “Stripped” out identifying features allowing Iranian banks and their customers to
wire transfer more than $530 million from 2001 to 2004
• Trained its Iranian clients to falsify wire transfers so that such messages would
pass undetected through the U.S. financial system
• Moved hundreds of millions of dollars through the U.S. financial system
36
•
Violation of the International Emergency Economic Powers Act
(IEEPA) and New York state law
•
Credit Suisse paid a $536 million fine
Barclays Bank
• August 16, 2010: Barclays entered into a deferred
prosecution agreement with the government,
agreeing to pay $149 million each to U.S. and State
of New York.
• Acknowledged violating U.S. financial sanctions
imposed on Cuba, Iran, Sudan and Burma.
37
650 Fifth Avenue
•
36 story office building located in upscale section of New York City
•
Built in 1970s by Pahlavi Foundation
–
Non profit charitable organization associated with Shah of Iran
–
Bank Melli (Iran) provided $42 million in financing
–
Alavi Foundation successor to Pahlavi Foundation
• Alleged links to Iran
•
Building valued at $560 million
•
Alavi Foundation transferred an ownership interest in building to Assa Corporation in
conjunction with Bank Melli cancelling building loan
•
Assa Corporation owned by Assa Company Limited a Jersey, Channel Islands shell
company
•
Assa Company Limited owned by Bank Melli
•
In December 2008, Alavi Foundation owned 60% of building and Bank Melli owned 40%
through Assa Corporation
•
On December 17, 2008, FBI seized 40% of 650 Fifth Avenue
–
38
In accordance with International Emergency Economic Powers Act (IEEPA)
Iranian Fronts
•
Alavi Foundation
– Controlled and operated by Iranian Government
• Provided numerous services to Iranian Government
• Ran a charitable organization for the Iranian Government
• Transferred funds from 650 Fifth Avenue Company to Bank Melli
•
Assa Corporation and Assa Company Limited
– Shell companies owned by Bank Melli
• Provided numerous services to Bank Melli in contravention of IEEPA
and Iranian Transactions Regulations
•
39
On December 19, 2008, Farshid Jahedi, then President of the
Alavi Foundation, was arrested for obstruction of justice.
– Allegedly destroyed documents required to be produced under
Grand Jury Subpoena concerning the Alavi Foundation’s
relationship with Bank Melli and the ownership of 650 Fifth Avenue.
Amended Charges
•
On November 12, 2009, the U.S. Attorney’s Office, Southern
District of New York, filed an amended civil complaint to forfeit
the remaining 60% ownership interest in 650 Fifth Avenue held
by the Alavi Foundation
•
In addition to the building, the amended complaint seeks
forfeiture of
– All other assets of the Alavi Foundation and Assa
Corporation
• Bank accounts owned by 650 Fifth Avenue Company, the
Alavi Foundation and Assa Corporation
40
• Real properties owned by the Alavi Foundation in New
York, Maryland, Virginia, Texas and California
Illegal Money Remittance Business
•
Abad Elfgeeh
– American citizen born in Yemen
•
Carnival French Ice Cream Shop
– Annual average revenue about $185,000
– Illegally wired $22 million overseas
• Mostly to Yemen
•
Used account with a major bank to wire money
overseas
•
Illegally transferred money for Sheik Mohammed Ali
Hassan al-Moayad
– Al-Qaeda and Hamas fundraiser/supporter
– Ties to Osama bin Laden
•
41
Elfgeeh claimed he was not running unlicensed
money transfer business but providing a
“community service”
Money Laundering
&
Terrorist Financing
42
Money Laundering:
Understanding the Enemy
• Terrorists
– Threat to National
Security
– Motivated by ideology
• Criminals
– Threat to the Economy
– Motivated by greed
43
•
Profit
•
Power
The Process
Terrorist Financing
Money Laundering
Legitimate Funding OR
Illegitimate Funding
Illegitimate Funding
Placement
Funds deposited into financial system
Layering
Funds moved to other institutions to obscure origin
Integration
44
Funds used to acquire legitimate
assets
Funds distributed to finance
terrorist activities
Money Laundering and Terrorism
Finance Comparison
Terrorism Finance
Money Laundering
• Motivation is profit
• Circular funding flow
– Vlademiro Montesinos
• PEP
– Abused his trust
45
•
•
Motivation is ideological
Linear funding flow
– Shawqi Omar
• Terrorist
– Abu Musab al-Zarqawi
• Laundered over 400 million
globally (80 million in U.S.)
• Beneficiary of multiple frauds
involving family members in U.S.
• SARs instrumental to
investigation
• SARs instrumental to investigation
Targeting the Money Launderer
• Key vulnerabilities in the money laundering
process
▫ Cash
▫ Wire transfers
▫ Fixed assets
• Identifying money laundering mechanisms
• Intelligence gathering and exploitation
• Disrupting illicit money flows
46
Right to Financial Privacy
47
The Bank Secrecy Act
31 U.S.C. § 5311 et seq.
• Originally enacted in 1970 with the addition of nine
sections to Title 12.
• Title II - imposes recordkeeping and requirements on
financial institutions
(The name is a misnomer!)
48
Is this a good policy?
•
•
•
•
•
49
4th Amendment
5th Amendment
1st Amendment
Privilege?
Due Process?
Early Challenges
California Banker’s Association
v. Schultz
94 S.Ct. 1494 (1974)
Bank customers, bank,
bankers' association and
organization suing on behalf
of itself and its bank
customer members brought
action to enjoin Secretary of
Treasury and head of other
federal agencies from
enforcing provisions of BSA
50
Early Challenges
(cont’d)
U. S. v. Miller , 96 S.Ct. 1619 (1976)
51
Mitchell Miller was convicted of possessing an
unregistered still, carrying on the business of a
distiller without giving bond and with intent to
defraud the Government of whiskey tax, possessing
whiskey upon which no taxes had been paid and
conspiring to defraud United States of tax revenues.
He claimed that the evidence – microfilms or checks,
deposit slips and other records relating to his
accounts at two banks, obtained by subpoenas –
should have been suppressed.
Impact of Lists
Drives Terrorist
Supporters
Underground
- Requires shift in
investigative orientation
& focus
52
“Overinclusive” Targeting
MISCHIEF
53
CRIME
Money Laundering
Financial transactions designed to make
illegal (or “dirty”) proceeds appear to
be legitimate (clean).
54
Al-Haramain Islamic Foundation, Inc.
(D. of Oregon)
Pirouz Sedaghaty, a/k/a Pete Seda, Perouz
Seda Ghaty and Abu Yunus
Š18 U.S.C. § 371 –
Conspiracy to Defraud the United States
Š26 U.S.C. § 7206(1) –
False IRS Return by Tax Exempt Organization
Š31 U.S.C. § 5316(a)(1)(A) –
Failure to File Report of International
Transportation of Currency or Monetary Instrument
55
The American Experience with
International Terrorists
The “Non-BombThrowers”
-- the use of United States as a
financial staging grounds
56
“Overinclusive” Targeting in
Counterterrorism Enforcement
TERRORISM
TERRORISTS’
SUPPORTERS
57
18 U.S.C. § 2339B
Providing Material Support to Terrorist
Organizations
(a) Prohibited activities.-(1) Unlawful conduct.--Whoever knowingly provides
material support or resources to a foreign terrorist
organization, or attempts or conspires to do so,
shall be [guilty of a felony]. To violate this
paragraph, a person must have knowledge that the
organization is a designated terrorist organization
[or] that the organization has engaged or engages in
[terrorist activity.]
58
U.S. Lists relevant to counterterrorism
enforcement
(1) State Department designated “Foreign
Terrorist Organizations” (FTOs)
•
•
•
•
59
46 groups, including their aliases
groups only, no individuals
all are “foreign”
§ 2339B crime
The Right to Financial Privacy Act
12 U.S.C. § 3403
• (a) Release of records by financial
institutions prohibited
No financial institution, or officer, employees, or agent
of a financial institution, may provide to any
Government authority access to or copies of, or the
information contained in, the financial records of any
customer except in accordance with the provisions
of this chapter.
60
RFPA Litigation History
RFPA Cases Over Time
20
# Cases
15
10
# RFPA
5
0
1979 1983 1987 1991 1995 1999 2003 2007
Year
61
RFPA Litigation History
• 56 cases vs. Bank
• 78 cases vs. Government
# Cases
Government
# Cases
Banks
0
62
20
40
60
80
RFPA Litigation History
40
35
30
25
20
Banks
15
Government
10
5
0
1970s
63
1980s
1990s
2000s
Sample RFPA Lawsuit vs. Bank
• Young v. Chemical Bank, 1988 WL 130929 (S.D.N.Y. 1988)
“it would be absurd to hold that Chemical disclosed Sybil
Young's records in violation of the Privacy Act. Chemical
was served with a subpoena, regular on its face,
requiring testimony and production of all records at
Chemical pertaining to Roderick Young and/or Sybil
Young. The subpoena contained an order prohibiting
Chemical from disclosing to any person the existence of
and Chemical's compliance with the subpoena. Failure to
comply with the subpoena would have subjected
Chemical to an order of contempt. This Court cannot
penalize compliance with a subpoena where such
compliance did not violate any federal statute .”
64
Best Resource for
Description of FTOs
• www.state.gov/s/ct/
• Does not describe
American legal
history of them,
except in passing
65
Supplemental Resources
The Prosecutor’s Guide
to the FTOs
(DOJ NSD December 2009)
The FTO Litigator
(DOJ NSD February 2010)
66
BSA INFORMATION FACILITATES
INVESTIGATIONS
67
GAO Report February 2009
•
Bank Secrecy Act: Suspicious Activity Report use is
increasing...
– Automated monitoring systems can flag multiple indicators of
suspicious activities and identify significantly more unusual
activity than normal monitoring
– Public enforcement actions against depository institutions
prompted other institutions to look more closely at client and
account activity
– Greater awareness of and training on BSA requirements
– More regulator guidance for BSA examinations
– Federal agencies have taken actions to more effectively analyze
SAR data
68
• Better integration of BSA data with law enforcement data
Value of Financial Institution Records
Financial institutions are gatekeepers of information
about terrorists’ financial activity in the regulated sector
• Investigations rely on bank financial data
• Compliance with subpoenas and regulatory reporting
requirements absolutely vital
• Financial records have potential value as evidence of
financial crime or transactions, or to enhance other
parts of an investigation
69
▫
Bank records: transaction records, loan applications,
signature cards, etc.
▫
Reporting records: SARs, CTRs, etc.
FBI Investigative Data Warehouse
• Implementation of data sharing / data mining
technology
▫ Time sensitive and meaningful data exploitation
• Importance of Suspicious Activity Reports
▫ Thorough completion of forms to include as much
identifying data as possible
• Importance of Know Your Customer and Customer
Identification Programs
▫ Proliferation of false identity documents
70
BSA Data: Enhancing Investigations
•
Every FBI terrorism investigation must include a financial subfile
– First check on sub-file checklist is FinCEN BSA database
•
SARs & CTRs in concert provide significant data to construct a
financial intelligence picture
– SARs: point to potential criminal activity
– CTRs: provide almost sole opportunity for visibility on cash
movement, capture objective data on financial activity and patterns
•
Total number of terrorism subjects in FBI investigations with
positive hits in Investigative Data Warehouse/BSA data sets:
41.7%
Source: FBI
71
Yemeni Shopkeepers
•
Three Yemeni shopkeepers in Rochester, New York engaged in a scheme to
launder money for undercover operatives from ICE
– Seleh Mohamed Takei Saeed
– Yehia Ali Ahmed Alomari
– Mohamed Al Huraibi
•
Durnan Mini Mart
Short Deli & Grocery
MOJO’s Stars Restaurant
Investigation predicated on analysis of Currency Transaction Reports (CTRs)
– Saeed’s social security number associated with 324 CTRs totaling
approximately $12.3 million dollars between October 2002 and November 2004
– Alomari’s social security number associated with multiple CTRs totaling
approximately $2.6 million dollars during the same time period
•
ICE conducted two year undercover investigation
•
Subjects transferred approximately $200,000 outside the U.S. after the money
was represented to be proceeds of specified unlawful activity, and intended for
Hizballah
72 •
Saeed, Alomari and Huraibi plead guilty in August 2009
Conclusion
73
Keys to Effective AML / TF Programs
• Time sensitivity
• Risk recognition
• KYC program
• Adaptability
• Thoroughly completed SARs
• Financial Intelligence
• Proactive AML program
– Terrorist financing specific training
• Vigilance
74
• Communication, cooperation & coordination
Improving Possibility v. Probability
•
Internal measures
– Break down fraud and money laundering silos
– Understand the problem
– Vigilance
– Communication, cooperation, coordination
•
External measures
– Terrorist financing specific training
– Security clearances for select bankers
– Feedback mechanisms regarding importance of BSA
– Assessment of all SARs identifiable with terrorism cases
– Case studies of terrorist financing investigations
75
– Combining BSA data with other data to include empirical and
anecdotal information for trend analysis
Questions
?????s
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76
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77
2010 Web Seminar Series
Tuesday, September 7
12:00- 2:00PM
Suspicious Transaction Reporting: Going Beyond the Form
Visit www.acams.org for full schedule
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78
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79
DML Associates, LLC
19309 Winmeade Drive, #110
Lansdowne, VA 20176
571.333.0300
Dennis M. Lormel
President & CEO
[email protected]
80
Jeff Breinholt
Counsel for Law & Policy
National Security Division
U.S. Department of Justice
[email protected]
202-305-1443