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Australian Federal Police - Platypus Journal/Magazine |
Welcome to the cyber laundry
The purpose of money laundering is to disguise the origin of money gained through illicit means to enable the criminal to enjoy the proceeds of crime with every appearance of legitimacy.1
But to do so, money launderers must increasingly turn to new methods to stay one step ahead of their pursuers.
Leanne Lynch asks whether the Internet is just the latest spin in the rinse cycle, or if regulation and international cooperation will ensure it all comes out in the wash.
Given its difficult policing environment, the Internet — with its instantaneous, worldwide communications ability and burgeoning new payment technologies — is surely an opportunity too tantalising for the money launderer to pass up.
But are the opportunities real or potential? If real, does law enforcement have the tools and knowledge to intercept and successfully prosecute? If merely potential, can governments worldwide anticipate and launch proactive measures?
The potential of the often murky realm of cyberspace to provide ‘aid and comfort' to the money launderer has already been recognised by governments around the world. In particular, the Financial Action Task Force recommended in 1996 that "countries should pay special attention to money laundering threats inherent in new or developing technologies that may favor anonymity, and take measures, if needed, to prevent their use in money laundering schemes".2
Of course, the basics of money laundering remain the same whether they occur in virtual or real time. Money must be placed, layered and then integrated.
Placement is when illicit money enters the regulated financial system. In ‘real time', for example, placement may be accomplished through the process of ‘smurfing' — breaking up transactions into amounts less than that which attract mandatory reporting, then using couriers to deposit the funds into multiple accounts.
Layering is the generic term applied to methods designed to obscure the origins and ownership of money, for example multiple wire transactions or conversion of currency into assets or travellers cheques.
Integration occurs when illicit funds re-enter the mainstream economy — for instance through sham loans or invoices — with the appearance of licit earnings.
One of the drawbacks (for the criminal), of real time laundering is the necessity somewhere along the line of face-to-face contact with third parties. In fact, agencies such as the AFP and the Australian Transaction Reports and Analysis Centre base many of their anti-money laundering activities on this principle.
For example, third party involvement of cash dealers such as financial institutions, bookmakers, TABs and casinos provide AFP investigators with documentary evidence and the opportunity for witness statements, and AUSTRAC with Significant Cash Transaction Reports on all cash transactions of $10,000 or more.
Particularly reliant on third party involvement is AUSTRAC's Suspicious Transaction Report, which can be raised by a cash dealer at any time due to the unusual nature or circumstance of a transaction or the person or group of persons making the transaction, and does not depend on a transaction exceeding the $10,000 limit.3
From the launderer's point of view, of course, the Internet does not provide any new methods of operation at this time. Its main attractions are that it is quicker, more diverse, and disintermediates users from third party involvement and regulatory oversight, while its uncharted nature and growing popularity provide opportunities to pass unremarked among the masses.
In August 1998, for instance, an Australian Bureau of Statistics survey found that 1.245 million households were hooked up to the Internet — 18 per cent more than in May and 46 per cent more than in February.4 While less than one per cent of these had used the Internet for banking purposes, nearly 35 per cent had used the telephone to access their bank accounts in the previous three months.5
Telephone banking, like EFTPOS machines, has given the public a sense of empowerment and control over their financial affairs, and has been adopted with vigour by bank customers because of its convenience and accessibility. Given the enthusiasm of Australians for new technology and of the financial sector to cut costs, it would appear likely that the popularity of similarly convenient Internet banking could soon undergo an exponential growth.
Money launderers have long sought to ‘lose' their transactions among the huge volume of electronic traffic that occurs worldwide each day, mostly in the form of wire transfers. But electronic commerce, or e-commerce, also refers to transactions that take place via telephones, facsimiles, stored value cards or SVCs, and the Internet.
The Internet, in particular, is a growth area for commerce. At the start of 1998, the Department of Industry, Science and Tourism estimated that 43 per cent of regular Internet users have already experienced online shopping, with another 30 per cent willing to try.6
Moreover, the Victorian Government has announced that it will be conducting all Government business electronically by the year 2000, while in 1997 the Queensland Government announced a $23 million boost to e-commerce.7
In the early phases of Internet commerce, however, big ticket items such as real estate, jewellery or ‘serious' art — favoured means of layering or integrating illicit funds — were virtually impossible to purchase online, with most transactions relating to books, CDs and other small mail-order type goods. But this is changing rapidly.
Online travel agencies are already booming, and real estate agencies are fast catching on. Similarly, Internet auction houses have taken off, with one entrepreneur, who set up his site three years ago to enable his girlfriend to trade ‘Pez' dispensers online, now a billionaire.8
But transfer of value over the Internet was initially a concern. Systems were neither user-friendly nor secure, and several high profile hacking cases — including the case of an Australian who threatened to expose the credit card details of an ISP's customers to hackers worldwide9 — made for poor publicity for the infant e-commerce.
Now, there are about 65 systems for making transactions on the Internet.10 They range from sophisticated digital coin systems to Secure Electronic Transaction credit card facilities to software that allows same-day processing of on-line cheques.
There were 1.5 billion electronic transactions in Australia in 1997. While this represents only a small proportion of the 21 billion transactions in total, in dollar terms those 1.5 billion transactions actually translated to 65 per cent of the total value of transactions — a staggering $16 trillion in Australia alone.11
While Internet transactions accounted for only $0.000055 trillion of that amount, it is estimated that such transactions will grow from US$518 million in 1996 to US$6.6 billion in the year 2000.12 And if growth forecasts are right, Internet e-commerce will soon provide similar opportunities to wire transfer in terms of volume, but with anonymity features that may enable launderers to operate without leaving a trail of evidence.
Reputable Internet Service Providers, or ISPs, keep detailed customer information files. But free, non-ISP e-mail addresses such as usa.net or wowmail.com exist at a remove from their customers, allowing the input of little or even false information in the creation of accounts, making tracing impossible.
Even e-mail forwarding addresses such as replay@rewinder.com often can't be traced back to the real owner; it usually takes a court order to get these services to disclose customer information and jurisdictional issues further complicate the problem.
There are also services such as Anonymizer, which prevents a user's system from being probed for security holes or cache histories. Along with programs like CookieCrusher, Anonymizer also eats all cookies13 without allowing them onto your computer.
Then there is the ‘geek factor'. Telnet and its close cousins rlogin and tn3270, are methods of connecting to a remote computer over the Internet that lets you use programs and data as if you were using the computer locally. Using telnet, it is possible to ‘hire' an IP number and phone in to another computer, transferring funds and generally muddying up the waters.
The truly paranoid have found even greater promise of anonymity in sites that issue a random IP address, creating a smokescreen which is impossible to penetrate.
The new payment technologies — electronic cash,14 smartcards and SVCs — generally provide at least some degree of anonymity.
Smartcard or SVC technology may involve memory-only chips such as those contained in Telstra phone cards. Others have a programmable chip which can perform multiple functions such as storing value in different currencies or transferring value between cards or functions on the same card.
The founder of DigiCash, cryptographer David Chaum, puts little faith in the electronic princes of this world.
"If the whole click-stream of everything you do in cyberspace is captured not simply in a big database, but as statements signed by you — this is something unprecedented and really scary . . . In other words, someone could falsely incriminate you."15
The result was ‘eCash' — an untraceable online payments system which uses a ‘blind signature protocol' designed to be as foolproof and anonymous as cash — which is currently in use by leading banks in Europe and Australia. Just like cash, eCash can be freely transferred between individuals or merchants.
"All other viable technologies require the consumer to trust the system providers, and even other parties, to effectively protect and never misuse information," Mr Chaum said.
"Already many people suspect government can break a lot of codes. This kind of worry reduces consumer confidence; it's so much better if consumers are able to protect their own interests."16
As already noted, this notion of ‘empowerment' is seen as one of the positives of the Internet and e-commerce from the consumers point of view, enabling them to take control out of the hands of big banks and big organisations and become ‘masters' of their own destinies.
From a regulatory point of view, balancing consumer empowerment with the need for methods to ensure the Internet does not become a modern-day Sherwood Forest is probably the biggest challenge confronting law enforcement.
Using the Internet and new payment technologies to avoid regulations and even taxes is already possible, even for the Internet ‘newbie'.
Until recently, the Internet and SVC technology were disparate, meaning that the transfer of value stored on one to the other was subject to third-party involvement. However, advances in technology now mean that value can be transferred directly from an SVC to a computer.
Mondex, for example, is a global electronic cash scheme which uses a smartcard platform that allows value to be uploaded from card to PC or from card to card.
So in theory, even the humble phone card could have a place in laundering the proceeds of crime, with dealers able to accept payment for drugs in smartcards which are then smuggled out of the country and converted to cash in a foreign bank, or uploaded via the Internet and transferred to e-cash which is then sent off-shore.
Security standards and oversight rules which vary from country to country, used in concert with the availability of information on the Internet, provide perhaps the best opportunities for money launderers at the present time. And the Net abounds with information and advice on how to avoid the clutches of ‘big brother' — providing pointers to everything from tax havens to phone tapping.
Of course, the use of tax havens per se is not illegal. What attracts the money launderer, however, is the bank and corporate secrecy laws of offshore centres once used only by the rich and privileged — in particular, the ‘flee clause' contained in many offshore trusts that permits the domicile of a trust to be shifted should it be threatened.17
In fact, there are now more than one million anonymous corporations with more than $US5 trillion in assets estimated to be held in the name of offshore entities — some of which are legitimate, but a substantial portion of which are not.18
Again, the Internet is not providing any new opportunities for money launderers, merely enhancing the speed, choice and convenience of tried and trusted methods — its global nature allowing anybody with the know-how (and cash) to set up accounts and buy companies in countries which conceal the transfer of illicit funds and do not facilitate the investigation of their activities.
For the enthusiast, the Internet offers the writings of J. Orlin Grabbe, former Professor at the Wharton School, University of Pennsylvania and author of International Financial Markets 3rd Ed.
Claiming to "inspect the global underbelly", Mr Grabbe's site offers virtual ‘how-to' articles on money laundering and espionage as well as ‘do-it-yourself' information on investigating the private financial affairs of politicians, government officials and law enforcement officers.
While much of this is applicable only in the US, there are plenty of ideas for those with a fertile imagination and a little time on their hands.
The entrepreneur has even more scope for creativity. For the gullible beginner, there is always the originally-named No 1 Absolute Money Laundering, offering "Reliable money laundering schemes by professional launderers. Clients and partners from any country welcome".
At last count, 1AML was viewable at six locations on the Net, residing in the free web space offered on many servers.
The more sophisticated learner-launderer may wish to avail themselves of the services of online ‘advisers' such as Cybernetic Associates Ltd.
For just US$3990 and then US$2000 annually, Cybernetic's ‘Turn-Key Structure' promises to "set up your Offshore company in only political stable countries, within our range of choises [sic]!"
This includes company documents, trust documents, bearer share certificate, bank mandate and local domiciliation address, as well as mail and fax forwarding. Cybernetic requires that clients provide a minimum account balance of US$5000, access to which is provided worldwide via a Visa Gold card.
More advanced again (and with less typographical errors on their website) are Offshore Incorporations Limited and the Offshore Banker.
OIL offers an extensive stock of shelf companies from the "more popular jurisdictions" such as Hong Kong, Singapore, Caymans, Bahamas, Nevis and Samoa, including shelf companies available solely for Internet customers. Prices start at US$465.
The Offshore Banker specialises in high volume credit card processing and eCash accounts — up to a staggering $10 million per month — setting clients up off-shore in "corporate friendly discreet countries away from prying eyes".
OB's service includes merchant identification numbers, hardware and software, secure online processing and an office presence, as well as the ability to withdraw funds via wire, Visa, and fedex from any country in the world.
With an upfront fee of US$12,000 and maintenance fees of US$500 per month, the Offshore Banker is not for the faint hearted, but then the canny launderer knows that if you pay peanuts you get monkeys.
In fact, Norman Inkster, a former president of Interpol, believes that money launderers are happy to accept losses of up to 35 per cent on their money simply to make it legal.19
Of course, the academically inclined or self-sufficient may wish to do the leg work themselves. A brief tour of the Net provides all sorts of information on tax havens, including their Net access, currency controls, taxes and tax treaties, as well as address and phone numbers, the main language spoken, and the type of customers they prefer.
Finally, for the particularly sneaky, there is the Internet ‘charity' or the online casino. By setting up a virtual charity or shonky on-line ‘shop' or casino that accepts only e-cash, payments for drugs or other illegal endeavours could be placed in a virtually untraceable form.
With the dominant forms of e-cash currently being issued through banks, however, records of payouts made — while untraceable back to the giver — may result in the launderer having to pay tax on a supposedly legitimate income. (Unless of course the accounts are set up in one of the tax haven countries with the bank acting as go-between on his e-cash accounts.)
So the problems faced by money launderers in the use of tax havens and overseas bank accounts via the Internet, can be seen to be the same as in the real world — placement of funds without being caught. What the virtual world does provide them with though, is a larger pool of information and readier access to like-minded individuals.
Also problematic for the launderer are many of the security features now included on smartcards. Mondex cards, for example, have an extensive audit capability available for on-line transactions and are programmed to automatically react to ‘unusual' card behaviour.
Suspicions can be aroused, for instance, by regular or frequent value redemption from particular ‘unexplained' sources, or by a high average of redemptions relative to the card's purpose (for example, an individual's card behaving as if it was handling the amounts appropriate to a retailer's card) and temporarily close down.
The disintermediation associated with the Internet in general and the concept of cyberpayments in particular may lead to less vulnerabilities in the money laundering process — issues which have been examined in various fora.
The 1996 report of the Electronic Commerce Task Force to the Commonwealth Law Enforcement Board, for example, explored and identified issues of concern to law enforcement in respect of specific electronic payment technologies. In particular, the report noted that " . . . e-commerce takes no cognisance of geographic or jurisdictional boundaries, domestic or international . . . "20
The report identified a number of problems, including:
• How to ensure that offences committed by means of e-commerce come to the notice of law enforcement.
• How to locate, and if necessary decode, data that records e-transactions.
• How to identify the parties to e-transactions and to obtain admissible evidence to prove identity to the requisite standard of proof.
• How to do all the above in cases where the suspected offender, and evidence needed to prove a case, is outside Australia.21
The lag time between the introduction of technology and the implementation of legislation to provide oversight was also identified by the task force as one of the challenges facing law enforcement. For example, although AUSTRAC has monitored all international telegraphic transfers of money since 1992, it is not empowered to monitor e-commerce.
Without information to trigger a physical search of a suspect's hard drive, the money launderer can be happily socking away their dollars without a care in the world.
And in the event of evidence arising in the course of other investigations that might lead law enforcement to the launderer, programs are now freely available which promise to wipe ‘sensitive' files to the extent that even sophisticated recovery software will be unable to unscramble them.
Furthermore, many of the ever-increasing variety of providers offering electronic cash alternatives are not subject to mandatory reporting requirements. While the proposed Electronic Transactions Act (expected to be enacted by the Australian Government this year) will require storage of information to enable identification between parties to e-commerce, it does not address the potential for new money laundering opportunities to emerge should unscrupulous elements gain popular e-cash provider status.
Ideally, only accountable providers should be able to offer electronic cash. This will not solve the problem posed by off-shore bank involvement in a middleman capacity, of course, but will make life difficult for the novice criminal. Short of regulation, another option is to tilt the playing field towards the technologies that provide an audit capability on their product. Without a widespread market share, any particular form of e-cash will be of little use to the launderer.
Also of concern are the problems associated with investigating crimes which cross jurisdictional and national boundaries. These are well-known to law enforcers, who — without investigative or coercive powers — must rely on cooperation either informal or via mutual assistance channels. Online, the challenges are multiplied exponentially.
Service providers are loathe to provide information about customers even to authorities within their own country, let alone to others. As already noted, some of the less reputable could not provide identifying details even if they wanted to.
The CLEB report suggests the nationality of persons could be used as a basis for determining jurisdiction.22 This is a sensible suggestion but, as always, has inherent problems relating to differing laws, customs, political sensitivities and the like. Mr Inkster suggests the formation of an international court of justice to which a country could appeal.23
The Australian Taxation Office's E-Commerce Project24 also examined new payment technology issues. Acknowledging that the Internet allows less certainty about individual identities and the difficulties associated with encryption, the project found that some electronic payment systems had significant evasion potential; the application of the existing jurisdictional rules was doubtful; and broad-based international cooperation would be required to administer domestic tax laws relating to electronic commerce.
In addition, the project recommended that AUSTRAC should be asked to review the definition of ‘cash dealer' under the Financial Transaction Reports Act.
This would bring non-bank providers of electronic cash under the umbrella of compulsory transaction reporting.
Also important were recommendations that the ATO seek regulatory neutrality between physical cash and electronic cash, and liaise with the Reserve Bank to require reporting of amounts on issue for various electronic cash systems.
Although electronic cash has not yet been recognised as a negotiable instrument, one of the outcomes of the proposed Electronic Transactions Act will be to ensure functional equivalence between paper-based and electronic transactions. More difficult to address is the calculation of e-cash in circulation — because ownership of these new ‘currencies' resides in the hands of private companies rather than reserve banks.
Moving into the realm of ‘here's hoping' is the recommendation that organisations which operate or host commercial Internet sites be licensed and display ACN numbers. In a similar vein, the Consumer Rights Journal suggests the need for a regulator empowered to undertake audits of operators in electronic financial systems.25 Both these suggestions might be enforceable in Australia, but offer little if not taken up worldwide.
Equally desirable but even less achievable is the suggestion that the ATO seek to have access to credit card and electronic payment system records held outside of Australia. The precedent set by even entertaining such a notion would cause the tax haven countries to break out in a cold sweat.
Of less certain efficacy, is the recommendation that the ATO seek a $100 to $500 limit on "certain cash-like electronic payment systems". For a start, this would appear to run contrary to the CLEB report's recommendation that "rather than impeding technological advancement, appropriate law enforcement measures should assist it."26 If e-commerce is to flourish, denomination limits must be reasonable.
In addition, the signing by Australia and the USA of ‘Cooperation on Electronic Commerce' — an agreement that locks Australia into adopting a laissez faire approach to developing the online economy — makes such constrained e-cash limits even more unlikely.27
One thing is sure — denomination limits on cyberpayment systems, which differing opinions see as more likely to be set around US$1000 to $3000,28 would probably not deter money launderers who are used to the annoyance of having to smurf money around transaction reporting anyway.
A possible method of combating cyberlaundering was postulated in a report by the RAND corporation.29 Using the hypothesis that competing Mexican and Colombian drug traffickers were increasingly exploiting cyberpayment technologies to launder drug money and threatening the financial and perhaps political stability of Mexico, participants in a simulation exercise were asked to come up with tactical responses to such a crisis.30
The result was the Cyberpayment Network Targeting Order — an analogue to a current law enforcement technique used in the USA. Geographic Targeting Orders give the US Treasury Department the authority to require any or all financial institutions in a geographic area to file special reports or maintain records in stated circumstances.
The most obvious sticking point in the use of CNTOs to track laundered funds is bank secrecy. Despite 145 States ratifying the 1988 United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances which required, among other things, that signatories comply with international standards to ensure transparency in banking practices, a UNDCP report considers that only 40 States have really complied.31
In launching the report, Jean-Francois Thorny, Manager of the UNDCP's Global Program against Money Laundering, noted that most of the US$1 billion laundered daily throughout the world passed through banks in financial havens — about 80 per cent of which had no physical presence, no employees and no cashiers. "But they do make a lot of business, especially through the Internet," he told members of the press at a briefing on money laundering.32
On the positive side, however, e-cash is not a generic currency at this point in time, and crossing from one brand to another is similar to changing money on the foreign exchange.
A similar problem is encountered in attempting to cross from SVC to e-cash. Mondex, for example, allows exchange of value only with other Mondex cards or with the bank account of the card holder, while eCash — although strong on privacy in the transaction stages — is available only through reputable banks at this time. In short, the anonymity that launderers desire is not yet achievable.
This does not, of course, rule out the involvement or complicity of corrupt bank officials, such as was seen recently in Operation Casablanca, where US officials uncovered a cross-border money laundering scheme involving Mexican bank officials and Colombian drug cartels.
The biggest threat posed by the Internet and the new payment technologies to law enforcement is the concept of truly anonymous electronic money — a virtual ‘Preen' whose stain-removing qualities would withstand the most stringent scrutiny.
At present, digital walls prevent the crossover of the various ‘currencies' without third party involvement — possibly the primary reason behind the FATF's finding that the new technology systems, while in a phase of steady development and even rapid expansion, were showing little innovation relative to money laundering.33
Should e-cash become universalised and providers go unregulated, however, the movement of value around the globe — more specifically into the tax haven countries with strict bank privacy regulations — would be all but unstoppable.
To effectively close the net on cyberlaundering, regulation and accountability of e-cash providers is a necessity. Commitment to transparency of banking practices and enhanced cooperative arrangements between nations are also required, while new investigative methods and training aimed specifically at the Internet must be developed — and sooner rather than later.
Given the competing agendas of the minimalists versus the global law makers when it comes to regulation of the Internet, the birth of effective legislation will no doubt be difficult and protracted. What's more, the resulting offspring is unlikely to please either of its progenitors.
The author would like to thank the following people for their comments on this paper:
• Graham Pinner, Deputy Director, AUSTRAC.
• AFP Liaison Officer to AUSTRAC, Federal Agent Tim Morris.
• General Manager Scientific and Technological Systems and
• Management, Federal Agent Phil Baer.
• Federal Agent Alan Ross, Policy Group
1 Under the Proceeds of Crime Act 1987, a person is guilty of money laundering if she/he "receives, possesses, conceals, disposes of or brings into Australia any property or money that is proceeds of crime when she/he knows or ought reasonably to know that the money or other property is derived from unlawful activity".
2 FATF #13.
3 AUSTRAC Guideline No 1: Suspicious Transaction Reporting.
4 More than a million homes online, The Australian, December 1, 1998.
5 More than a million homes online, The Australian, December 1, 1998.
6 Electronic Commerce in Australia, April 1998, Department of Industry Science and Tourism.
7 A. Stringer, A cashless society must deal with the hard stuff, Consumer Rights Journal, Vol. 2, No. 2, January/February 1998, p.10.
8 C. Bowes, Line of least resistance, The Bulletin, November 24, 1998.
9 In March 1998, Skeeve Stevens was sentenced to three years' jail in the Sydney District Court for causing actual and potential commercial harm to the computer system of Internet Service Provider AUSNet.
10 Chris Connolly, Electronic Commerce: Legal and Consumer Issues, paper to Cyber Law Conference (Business Law Education Centre), Hilton Hotel Sydney, April 1998.
11 Electronic Commerce in Australia, April 1998, Department of Industry Science and Tourism.
12 Chris Connolly, Electronic Commerce: Legal and Consumer Issues, paper to Cyber Law Conference (Business Law Education Centre), Hilton Hotel Sydney, April 1998.
13 Cookies are bits of data placed on a hard drive by a server, often without the owner's knowledge. Cookies can be seen by a server later and can be used to track usage patterns, most often for hyper-targeted advertising.
14 Electronic cash is known generically as e-cash. The term ‘e-cash' is distinct from brand names such as ‘eCash' and ‘CyberCash'.
15 D. Chaum, David Chaum on Electronic Commerce: How Much Do You Trust Big Brother? DigiCash website.
16 .D. Chaum, David Chaum on Electronic Commerce: How Much Do You Trust Big Brother? DigiCash website.
17 J. Blum, M. Levi et al, Financial Havens, Bank Secrecy and Money Laundering, a study prepared on behalf of the United Nations under the auspices of the Global Program against Money Laundering, Office for Drug Control and Crime Prevention. Preliminary Report, May 29, 1998.
18 J. Blum, speaking before the Committee on Banking and Financial Services, US House of Representatives, June 11, 1998.
19 M. Lawson, International court needed to bring Skase to justice, Financial Review, November 20, 1998.
20 Enter the World, The Report of the Electronic Commerce Task Force to the Commonwealth Law Enforcement Board, 1996.
21 Report to CLEB, para 5.1.4.
22 Report to CLEB, para 4.2.22.
23 M. Lawson, International court needed to bring Skase to justice, Financial Review, November 20, 1998.
24 The findings of the Tax E-Commerce Project can be viewed at http://www.ato.gov.au/ecp/
25 A. Stringer, A cashless society must deal with the hard stuff, Consumer Rights Journal, Vol. 2, No. 2, January/February 1998, p.4
26 ‘The Big Picture', Report to CLEB.
27 Australia, US click on e-commerce, Financial Review, December 1, 1998.
28 Cyberpayments and Money Laundering: Problems and Promise, the RAND Report, 1998, p. xiii.
29 RAND is a non-profit institution which helps improve policy and decision making through research and analysis.
30 Cyberpayments and Money Laundering: Problems and Promise, the RAND Report, 1998, p. xv.
31 J. Blum, M. Levi et al, Financial Havens, Banking Secrecy and Money Laundering.
32 Jean-Francois Thorny, speaking at a press briefing on money laundering, June 5, 1998.
33 1997–98 Report on Money Laundering Typologies, Financial Action Task Force, February 12, 1998.
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