Per my last blog entry, I would like to propose a simple and realistic seven point plan to re-invigorate our “stalled” anti-money and counter-terrorist finance countermeasures.
The first step is to develop a strategy. Fortunately, we already have one. It is the 2007 National Anti-Money Laundering Strategy. It is an inter-departmental/inter-agency effort signed by the Secretaries of Treasury, Homeland Security, the Attorney General, etc. The report can be found here: http://www.treasury.gov/resource-center/terrorist-illicit-finance/Documents/nmls.pdf
The strategy report does a good job of identifying the perceived threats in 2007; for example, the growing issue of mobile payments, trade-based money laundering, bulk cash smuggling, regulatory challenges in the gaming and insurance industries, capacity building, and imposing meaningful “measureables,” and others. The plan lays out fairly comprehensive steps forward and gives appropriate government entities such as Treasury’s FinCEN specific tasks to accomplish in order to achieve the enumerated goals.
Unfortunately, for the most part nothing was done. The National Anti-Money Laundering Strategy Report has been ignored. The concerned agencies and departments have not accomplished what they were obligated to do. In large part, ignoring our own strategy is why we have under-performed in the anti-money laundering arena over the last five years.
Currently, there is talk within the U.S. anti-money laundering community about developing a new strategy report. Undoubtedly, additional threats will be identified such as social media and cyber. But there is no need to re-invent the wheel. We simply have to dust-off and update the 2007 strategy. However, unless there is accountability, this will once again become a political and bureaucratic feel-good exercise that will have few meaningful results. Accountability is step two in my plan. Stay tuned.
The first step is to develop a strategy. Fortunately, we already have one. It is the 2007 National Anti-Money Laundering Strategy. It is an inter-departmental/inter-agency effort signed by the Secretaries of Treasury, Homeland Security, the Attorney General, etc. The report can be found here: http://www.treasury.gov/resource-center/terrorist-illicit-finance/Documents/nmls.pdf
The strategy report does a good job of identifying the perceived threats in 2007; for example, the growing issue of mobile payments, trade-based money laundering, bulk cash smuggling, regulatory challenges in the gaming and insurance industries, capacity building, and imposing meaningful “measureables,” and others. The plan lays out fairly comprehensive steps forward and gives appropriate government entities such as Treasury’s FinCEN specific tasks to accomplish in order to achieve the enumerated goals.
Unfortunately, for the most part nothing was done. The National Anti-Money Laundering Strategy Report has been ignored. The concerned agencies and departments have not accomplished what they were obligated to do. In large part, ignoring our own strategy is why we have under-performed in the anti-money laundering arena over the last five years.
Currently, there is talk within the U.S. anti-money laundering community about developing a new strategy report. Undoubtedly, additional threats will be identified such as social media and cyber. But there is no need to re-invent the wheel. We simply have to dust-off and update the 2007 strategy. However, unless there is accountability, this will once again become a political and bureaucratic feel-good exercise that will have few meaningful results. Accountability is step two in my plan. Stay tuned.
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