|UNITED STATES OF AMERICA
FAFT AML Deficient
Higher Risk Areas
US Dept of State Money Laundering assessment
Not on EU White list equivalent jurisdictions
Medium Risk Areas
Although some States in the USA offer offshore financial services e.g. Delaware, the United States is not considered to be an Offshore Financial Centre
The USA is not on the FATF List of Countries that have been identified as having strategic AML deficiencies
Compliance with FATF Recommendations
The last Mutual Evaluation Report relating to the implementation of anti-money laundering and counter-terrorist financing standards in the USA was undertaken by the Financial Action Task Force (FATF) in 2016. According to that Evaluation, the USA was deemed Compliant for 9 and Largely Compliant for 21 of the FATF 40 Recommendations.
The AML/CFT framework in the U.S. is well developed and robust. Domestic coordination and cooperation on AML/CFT issues is sophisticated and has matured since the previous evaluation in 2006. The understanding of money laundering (ML) and terrorist financing (TF) risks is well-supported by a variety of ongoing and complementary risk assessment processes, including the 2015 National Money Laundering Risk Assessment (NMLRA) and National Terrorist Financing Risk Assessment (NTFRA), which were both published. The national AML/CFT strategies, key priorities and efforts of law enforcement and other agencies seem to be driven by these processes and are coordinated at the Federal level across a vast spectrum of agencies in a number of areas.
The financial sectors bear most of the burden in respect of required measures under the Bank Secrecy Act (BSA). Financial institutions (FIs), in general, have an evolved understanding of ML/TF risks and obligations, and have systems and processes for implementing preventive measures, including for on-boarding customers, transaction monitoring and reporting suspicious transactions.
However, the regulatory framework has some significant gaps, including minimal coverage of certain institutions and businesses (investment advisers (IAs), lawyers, accountants, real estate agents, trust and company service providers (other than trust companies). Minimal measures are imposed on designated non-financial businesses and professions (DNFBPs), other than casinos and dealers in precious metals and stones, and consist of the general obligation applying to all trades and businesses to report transactions (or a series of transactions) involving more than USD 10 000 in cash, and targeted financial sanctions (TFS) requirements. Other comprehensive AML/CFT obligations do not apply to these sectors. In the U.S. context the vulnerability of these minimally covered DNFBP sectors is significant, considering the many examples identified by the national risk assessment process.
Law enforcement efforts rest on a well-established task force environment which enables the pooling of expertise from a wide range of law enforcement agencies (LEAs), including prosecutors, to support quality ML/TF investigation and prosecution outcomes. Overall, LEAs have access to a wide range of financial intelligence, capabilities and expertise allowing them to trace assets, identify targets and undertake expert financial ML/TF investigations. There is a strong focus on following the money in predicate offence investigations at the Federal level. A similar focus on identifying terrorist financiers in terrorism-related investigations applies. The U.S. investigates and prosecutes TF networks aggressively in line with its risk profile. International cooperation in these areas is generally effective though improvements are underway to further improve the timely handling of (a large volume) of mutual legal assistance (MLA) and extradition requests.
Lack of timely access to adequate, accurate and current beneficial ownership (BO) information remains one of the fundamental gaps in the U.S. context. The NMLRA identifies examples of legal persons being abused for ML, in particular, through the use of complex structures to hide ownership. While authorities did provide case examples of successful investigations in these areas, challenges in ensuring timely access to and availability of BO information more generally raises significant concerns, bearing in mind risk and context.
At the Federal level, the U.S. achieves over 1 200 ML convictions a year. Many of these cases are large, complex, white collar crime cases, in line with the country’s risk profile. Federal authorities have the lead role in all large and/or international investigations. There is however no uniform approach to State-level AML efforts and it is not clear that all States give ML due priority. The AML system would benefit from ensuring that a range of tax crimes are predicate offenses for ML.
The Federal authorities aggressively pursue high-value confiscation in large and complex cases, in respect of assets located both domestically and abroad. The authorities effectively resort to criminal, civil and administrative tools to forfeit assets. At State and local levels, there is little available information, though it appears that civil forfeiture is vigorously pursued by some States.
The U.S. authorities effectively implement targeted financial sanctions for both terrorism and proliferation financing purposes, though not all U.N designations have resulted in domestic designations (mainly on the basis of insufficient identifiers). Most designations take place without delay, and are effectively communicated to the private sector. The U.S. Specially Designated Nationals and Blocked Persons List (SDN List) is used by thousands of FIs across the U.S. and beyond which gives the U.S sanctions regime a global effect in line with the size, complexity and international reach of the U.S. financial system. The U.S has had significant success in identifying the funds/other assets of designated persons/entities, and preventing them from operating or executing financial transactions related to terrorism and proliferation. Only minor improvements are needed in this area.
AML/CFT supervision of the banking and securities sectors appears to be robust as a whole, and is evolving for money services businesses (MSBs) through greater coordination at the State level. The U.S. has a range of sanctions that it can and does impose on FIs as well as an array of dissuasive remedial measures, including informal supervisory actions. These measures seem to have the desired impact on achieving the supervisory objectives. The most significant supervisory gap is lack of comprehensive AML/CFT supervisory processes for the DNFBPs, other than casinos.
Risks and General Situation
The global dominance of the U.S. dollar generates trillions of dollars of daily transaction volume through U.S. banks, which creates significant exposure to potential ML activity (generated out of both domestic and foreign predicate offenses) and risks of cross-border illicit flows. The U.S. also faces significant risks from TF and is vulnerable to such abuse because of the unique scope, openness and reach of its financial system globally, and the direct threat posed by terrorist groups to U.S. interests.
The United Nations office on Drugs and Crime (UNODC) estimated proceeds from all forms of financial crime in the U.S., excluding tax evasion, was USD 300 billion in 2010 (about 2% of the U.S. economy). Fraud (including healthcare fraud, identity theft, tax fraud, mortgage fraud, retail and consumer fraud and securities fraud) generates the largest volume of illicit proceeds, particularly healthcare fraud against the Federal government which accounts for approximately USD 80 billion annually. Other major sources of proceeds are drug trafficking (generating about USD 64 billion annually), transnational organized crime, human smuggling and public corruption (both domestic and foreign).
The main ML vulnerabilities assessed by the U.S. were in the cash, banking, MSB, casino and securities sectors, and were characterized as: use of cash and monetary instruments in amounts under regulatory record-keeping and reporting thresholds; opening bank and brokerage accounts using nominees to disguise the identity of the individuals who control the accounts; creating legal entities without accurate information about the identity of the beneficial owner; misuse of products and services resulting from deficient compliance with AML obligations; and merchants and FIs wittingly facilitating illegal activity. The main TF threats and vulnerabilities include: raising funds through criminal activity, individuals raising funds under the auspices of charitable giving but outside of any charitable organization, individual contributions and self-funding; moving and placing funds through banks, licensed MSBs, unlicensed money transmitters and cash smuggling; and potential emerging threats from global terrorist activities, cybercrime and identity theft, and new payment systems.
US Department of State Money Laundering assessment (INCSR)
The U.S.A. was deemed a Jurisdiction of Primary concern by the US Department of State 2013 International Narcotics Control Strategy Report (INCSR).
There is no US State Department Money Laundering Report available however, we set out below an extract from the IMF Report: United States: Financial Sector Assessment Program-Anti-Money Laundering And Combating The Financing Of Terrorism (AML/CFT)-Technical Notes: -
This note sets out the findings and recommendations made in the Financial Sector Assessment Program (FSAP) for the United States in the areas of anti-money laundering and combating the financing of terrorism (AML/CFT). It summarizes the findings of a targeted review of measures to prevent U.S. legal persons and arrangements from being misused for money laundering (ML)/financing of terrorism (FT). This discussion is not, in any way, an evaluation or assessment of the U.S. AML/CFT system. The United States will undergo a complete mutual evaluation by the Financial Action Task Force (FATF) beginning June 1, 2015, the results of which will be made public in 2016.
The last FATF assessment in 2006 found that the United States had implemented an AML/CFT system that was broadly in line with the international standard, although a significant shortcoming was identified. The United States had significantly strengthened its AML/CFT regime since the previous mutual evaluation, including through enhanced legislation. However, there was a notable shortcoming with respect to the Recommendation addressing customer due diligence (CDD) which is one of the FATF’s core Recommendations. There were also other deficiencies regarding the availability of ownership information about corporations and trusts, and the requirements applicable to certain designated non-financial businesses and professions (DNFBPs).
The U.S. AML/CFT legal and institutional framework has yet to address deficiencies identified in the most recent FATF mutual evaluation report (MER) regarding ownership information for U.S. corporations and trusts; in particular more rapid progress is needed to enhance transparency of legal persons to bolster financial system integrity. Trusts have a different legal and institutional framework. Draft regulations have been produced to strengthen financial institutions’ (FIs) obligations to identify and verify the identity of beneficial owners and policy intentions announced to improve the authorities’ access to information on the beneficial ownership (BO) and control of U.S. corporations. These measures—to address deficiencies identified in the last FATF MER of June 2006—are progressing slowly. However, in 2010 U.S. tax authorities began requiring information that includes some BO information from legal entities and trusts applying for an Employer Identification Number (EIN), which is required when they have income, employees, or are otherwise required to file any documents with the Internal Revenue Service (IRS) or open an account with an FI. Nonetheless, deficiencies remain, and even when completed, the intended changes may not completely address all of the deficiencies cited in the last FATF mutual evaluation report.
The approach taken by law enforcement agencies (LEAs) to access BO information—relying largely on a wide range of investigative powers and techniques— while often successful cannot always ensure timely access to current BO information of all U.S. corporations. The inability to access accurate BO information directly from states, FIs or agents serving corporations or trusts may curtail how effective the authorities can be in pursuing criminally persons who misuse corporations to launder proceeds generated domestically as well as abroad or to trace and recover their illicit assets. This includes laundering associated with taxes evaded in the United Statesand abroad, by U.S. citizens and foreigners respectively, and to cooperate effectively with their foreign counterparts in this regard. The amount laundered from taxes evaded in the United States may be substantial. Serious tax crimes are not predicate crimes to ML. The authorities estimated the U.S. net tax gap to be around $450 billion in 2006, excluding international tax evasion, and tax crimes for state taxes.
General overview of the U.S. AML/CFT Framework
The United States has a mature legal and institutional AML/CFT framework, having first criminalized money laundering in 1986. The framework covers most requirements of the FATF recommendations. There are many agencies involved in combating ML and FT at both federal and state levels encompassing regulatory, law enforcement, prosecutorial, and other roles. The United States is a founding member of the FATF, and has undergone three assessments against the FATF Recommendations.
The FATF assessment in 2006 found that the United States had implemented an AML/CFT system that was broadly in line with the international standard. It had significantly strengthened its AML/CFT regime since the previous mutual evaluation (June 1997), including through enhanced legislation, subjecting most deposit-taking institutions to the full range of AML/CFT requirements, aggressive law enforcement action, and good cooperation domestically and internationally.
However, shortcomings were identified, notably in relation to some specific requirements for undertaking customer due diligence (CDD), the availability of corporate ownership information, and the requirements applicable to certain designated non-financial businesses and professions (DNFBPs).In relation to CDD, the evaluators determined that not all requirements were imposed on FIs using instruments that complied technically with the FATF standard and also concluded that there were no requirements for FIs to look beyond a customer to establish the identity of the beneficial owners in all cases. The evaluators found that the United States’ compliance with the two recommendations dealing with the transparency of legal persons and arrangements was very weak and rated both as non-compliant. In relation to DNFBPs, the United States was found to be non-compliant with the FATF recommendations relating to CDD, recordkeeping, suspicious transaction reporting, and internal controls and partially compliant with the Recommendation on regulation and supervision.
Fund staff, in a TN prepared in the context of the 2010 U.S. FSAP, reported some strengthening of the regime, but also a lack of progress in addressing key deficiencies. The 2010 TN reported on some enhancements to legislation and the continuation of aggressive law enforcement action. It also reported that identified deficiencies relating to CDD, coverage of DNFBPs, and the availability of BO information for legal persons and arrangements remained.
FATF also determined that the United States did not substantially address the identified shortcomings since the 2006 mutual evaluation. Under FATF procedures for its third round of mutual evaluations countries were required to report back to the FATF on steps taken to address deficiencies noted in their MERs with respect to the Recommendations that were rated as partially compliant or non-compliant. In the case of the United States, these were Recommendations on CDD for FIs, CDD and recordkeeping for DNFBPs, suspicious transaction reporting and internal controls for DNFBPs, regulation and supervision of DNFBPs, transparency of legal persons, and transparency of legal arrangements. Following the 2006 mutual evaluation, the FATF required the United States to report on progress addressing its deficiencies. The third round follow-up process was postponed pending the outcome of the U.S. fourth round mutual evaluation, which began on June 1.
Transparency and beneficial ownership of U.S. legal persons and arrangements
Broadly speaking, there are three main types of legal persons and arrangements in the United States: corporations (including limited liabilities companies), partnerships, and trusts. More than 30 million legal persons and arrangements exist, but the precise figure is unknown. They are also able to be owned or controlled by non-residents, but the extent of such ownership is also unknown. The following discussions on corporations focus on those that are not publicly traded.
It has been long recognized that U.S. corporations may be misused for ML and related predicate crimes, both by U.S. and foreign persons. The 2006 MER noted that a threat assessment identified the formation of shell companies within certain states as a serious cause for concern, and there is general agreement among LEAs that, while the vast majority of corporations pursue legal activities, others are being misused for ML (including laundering of proceeds from foreign offenses) and related predicate crimes. As identified by the authorities, corporations may be used as a front to open bank accounts without revealing the identity of the individuals who own or control the account, and corporate vehicles are a common method used to place, layer, and integrate illicit proceeds in the financial system. The authorities indicated that they reviewed ML- related indictments from 2006 to 2012 and found many cases involving the use of corporations.
In contrast, trusts are generally considered by most authorities to pose low ML/FT risks. In the United States, a trust is a legal arrangement created between two private persons or a private person and a trust company under state law. Trust companies are authorized to act in a fiduciary (i.e., trustee) capacity and are subject to the Bank Secrecy Act. However, lawyers and accountants who assist with setting up trusts are unregulated for AML/CFT. The LEAs who met with the mission are of the view that trusts are not particularly attractive vehicles to those wishing to hide their activities, particularly compared to corporations, because of tax reporting obligations. However, some authorities believe that the ML/FT risks posed by trusts are not necessarily lower. The mission was unable to access more information about the ML/FT risks posed by trusts governed by U.S. laws.
There are no international sanctions currently in force against this country.
Rating (100-Good / 0-Bad)
Transparency International Corruption Index
World Governance Indicator – Control of Corruption
The US has the largest and most technologically powerful economy in the world, with a per capita GDP of $49,800. In this market-oriented economy, private individuals and business firms make most of the decisions, and the federal and state governments buy needed goods and services predominantly in the private marketplace.
US business firms enjoy greater flexibility than their counterparts in Western Europe and Japan in decisions to expand capital plant, to lay off surplus workers, and to develop new products. At the same time, they face higher barriers to enter their rivals' home markets than foreign firms face entering US markets. US firms are at or near the forefront in technological advances, especially in computers and in medical, aerospace, and military equipment; their advantage has narrowed since the end of World War II. The onrush of technology largely explains the gradual development of a "two-tier labor market" in which those at the bottom lack the education and the professional/technical skills of those at the top and, more and more, fail to get comparable pay raises, health insurance coverage, and other benefits. Since 1975, practically all the gains in household income have gone to the top 20% of households. Since 1996, dividends and capital gains have grown faster than wages or any other category of after-tax income.
Imported oil accounts for nearly 55% of US consumption. Crude oil prices doubled between 2001 and 2006, the year home prices peaked; higher gasoline prices ate into consumers' budgets and many individuals fell behind in their mortgage payments. Oil prices climbed another 50% between 2006 and 2008, and bank foreclosures more than doubled in the same period. Besides dampening the housing market, soaring oil prices caused a drop in the value of the dollar and a deterioration in the US merchandise trade deficit, which peaked at $840 billion in 2008. The sub-prime mortgage crisis, falling home prices, investment bank failures, tight credit, and the global economic downturn pushed the United States into a recession by mid-2008. GDP contracted until the third quarter of 2009, making this the deepest and longest downturn since the Great Depression. To help stabilize financial markets, in October 2008 the US Congress established a $700 billion Troubled Asset Relief Program (TARP). The government used some of these funds to purchase equity in US banks and industrial corporations, much of which had been returned to the government by early 2011. In January 2009 the US Congress passed and President Barack OBAMA signed a bill providing an additional $787 billion fiscal stimulus to be used over 10 years - two-thirds on additional spending and one-third on tax cuts - to create jobs and to help the economy recover.
In 2010 and 2011, the federal budget deficit reached nearly 9% of GDP. In 2012 the federal government reduced the growth of spending and the deficit shrank to 7.6% of GDP. Wars in Iraq and Afghanistan required major shifts in national resources from civilian to military purposes and contributed to the growth of the budget deficit and public debt. Through 2011, the direct costs of the wars totaled nearly $900 billion, according to US government figures. US revenues from taxes and other sources are lower, as a percentage of GDP, than those of most other countries. In March 2010, President OBAMA signed into law the Patient Protection and Affordable Care Act, a health insurance reform that was designed to extend coverage to an additional 32 million American citizens by 2016, through private health insurance for the general population and Medicaid for the impoverished. Total spending on health care - public plus private - rose from 9.0% of GDP in 1980 to 17.9% in 2010.
In July 2010, the president signed the DODD-FRANK Wall Street Reform and Consumer Protection Act, a law designed to promote financial stability by protecting consumers from financial abuses, ending taxpayer bailouts of financial firms, dealing with troubled banks that are "too big to fail," and improving accountability and transparency in the financial system - in particular, by requiring certain financial derivatives to be traded in markets that are subject to government regulation and oversight. In December 2012, the Federal Reserve Board (Fed) announced plans to purchase $85 billion per month of mortgage-backed and Treasury securities in an effort to hold down long-term interest rates, and to keep short term rates near zero until unemployment drops below 6.5% or inflation rises above 2.5%. In late 2013, the Fed announced that it would begin scaling back long-term bond purchases to $75 billion per month in January 2014 and reduce them further as conditions warranted; the Fed, however, would keep short-term rates near zero so long as unemployment and inflation had not crossed the previously stated thresholds. Long-term problems include stagnation of wages for lower-income families, inadequate investment in deteriorating infrastructure, rapidly rising medical and pension costs of an aging population, energy shortages, and sizable current account and budget deficits.
15 April 2015 - Reuters: President Barack Obama told Congress on Tuesday he intends to remove Cuba from a U.S. list of state sponsors of terrorism, clearing the main obstacle to restoring diplomatic relations and reopening embassies shut for more than half a century.
Congress has 45 days to consider Obama's decision before it takes effect, but lawmakers cannot stop it unless both chambers approve a joint resolution, a move that is highly unlikely.
April 2014 - Extracted from IMF Report - United States: Financial Sector Assessment Program-Detailed Assessment of Observance on the Basel Core Principles for Effective Banking Supervision
The agencies have enforced supervisory guidance that directs banks to establish CDD policies, procedures and processes, which are risk based and integrated into the bank’s overall risk management strategy. The U.S. federal banking agencies have identified failures of such during examinations evidenced by recent public enforcement actions (as shown on the website of each agency).
Over 300 such enforcement actions related to AML/CFT have been initiated in the last 4 years. Pursuant to 31 U.S.C §5318(1), the FBAs and Treasury have issued regulations requiring various account opening procedures, including verifying the identity of any persons seeking to open an account and maintaining records of such information. Banks must establish a Customer Identification Program and maintain records of the information used to verify the person’s identity. The BSA and CIP regulations generally require that the banks properly safeguard and maintain copies of reports and records for a period of five years following the completion of the transaction or after the account has been closed.
The CIP also must include procedures for responding to circumstances in which the bank cannot form a reasonable belief that it knows the true identity of a customer. For certain non-U.S. accounts and transactions, banks must identify all beneficial owners. For U.S. transactions where the client is a legal entity, the identification of the ultimate beneficial owner is not required.
The FBAs evaluate whether the CIP enables a bank to form a reasonable belief of the customer’s true identity at account opening and to ensure that account profiles are kept current. In addition, supervisors will review if the bank has identified PEPs and, if so, how the corresponding risks are managed. There is, however, no explicit requirement that decisions on entering into relationship with such persons shall be escalated to the bank’s senior management. The current definition of PEPs in the U.S. only includes foreign nationals. Domestic PEPs are not defined, but are expected to be included in high net worth individuals monitoring as a higher risk category.
31 U.S.C §5318(i) and 31 CFR Part 1010 requires risk based due diligence for U.S. private banking and correspondent accounts involving foreign persons. The statute requires reasonable steps to ascertain the identity of nominal and beneficial owners (except of legal entities) of, and the source of funds deposited into, such accounts. Stricter requirements apply when the customer is defined as a foreign PEP. However, in practice banks are expected to, and do, apply these higher standards to all other transactions and accounts.
Banks must have an adequate BSA/AML compliance program in place that includes ongoing monitoring to detect criminal and suspicious activities. Specifically, the program must have sufficient internal controls for monitoring suspicious activity, a qualified BSA compliance officer to oversee the program, independent testing to verify vulnerabilities in the program, and regular BSA/AML compliance training for all relevant personnel. The FFIEC BSA/AML
Examination Manual specifically addresses the regulatory expectations pertaining to internal controls, including CDD requirements, which are an essential component of a bank’s internal controls. See, e.g. 12 CFR Part 1010, subpart D. The Manual also states that the Board of Directors is responsible in setting policies regarding BSA/AML risk, which include prescribing the relationships with high risk accounts and countries the bank will enter into. Supervisors determine whether the internal controls include prudent account opening procedures and ongoing monitoring systems, including a customer acceptance policy identifying business relationships the bank will not accept, if any, and that standards are followed on an ongoing basis The FFIEC Manual also states that “Management should have a thorough understanding of the money laundering terrorist financing risk of its customer base. Under this approach the bank will obtain information at account opening sufficient to develop an understanding of normal and expected activity of the customer's occupation or business operations."
31 U.S.C §5318(i) and its implementing regulation at 31 CFR 1010.610 require banks to establish risk-based due diligence policies and procedures reasonably designed to detect and report money laundering through correspondent accounts established, maintained, administered or managed in the U.S. for a foreign financial institution.
In addition, banks must perform enhanced due diligence for foreign correspondent banks operating under certain high-risk banking licenses. Enhanced due diligence includes obtaining ownership information about certain correspondents, conducting additional scrutiny of the transactions routed through these accounts, and ascertaining whether the foreign correspondent provides access to other foreign financial institutions. 31 U.S.C §5318(j) prohibit U.S. banks from providing correspondent accounts to foreign shell banks.
The FFIEC BSA/AML Examination Manual has a chapter specifically addressing correspondent banking relationships. The agencies supervise banks to ensure compliance with foreign correspondent banking requirements. Supervisors are provided a number of significant high profile BSA/AML factors that may be used to help identify potential risk characteristics of a foreign correspondent customer in the Manual.
The agencies have enforced (in several cases) requirements that banks establish enhanced due diligence policies and processes regarding correspondent banking and have cited failures of such rules as a concern during examinations.
U.S. agencies generally view BSA/AML risks in domestic correspondent banking as low compared to other types of financial services. Nevertheless, U.S. agencies evaluate the policies and procedures for U.S. banks that offer correspondent banking services to domestic respondent banks, particularly with a view to detecting and reporting suspicious activities. These requirements, including that correspondent relationship are not initiated when adequate controls are not in place by the counterpart, are detailed in 31CFR 103.176.
A key component of the BSA/AML on-site examination is to ensure that the bank maintains an effective BSA/AML Compliance Program for its business activities that is commensurate with the bank’s risk profile. Prior to the examination, banking supervisors routinely conduct an offsite review of the FinCEN databases relative to bank SARs and CTRs to determine if the bank has filed such reports, and to determine if those reports were filed completely and in a timely manner. The agencies assess a bank’s compliance with BSA/AML and OFAC obligations using the core examination procedures detailed in the FFIEC BSA/AML Examination Manual during each examination. For larger and more complex banking organizations, the agencies maintain resident on-site supervisors who perform continuous monitoring of the control infrastructure and annually assess the organization’s condition and risk assessment.
The assessors found numerous evidences of supervisory criticisms and actions against deficient BSA/AML compliance. Thousands of AML/CFT inspection actions are carried out by the FBAs each year, and hundreds of related enforcement actions have been initiated.
2014 - FinCEN
Releases First Issue of SAR Stats
3 October 2013 - (FinCEN) issues Advisory to update financial institutions on activity associated with regulatory restrictions imposed on Mexican financial institutions for transactions in U.S.currency.
9 September 2013 - FinCEN releases an analysis of Mortgage Fraud SAR Filings in Calendar Year 2012
Extract from 2013 Asia Pacific Group on Money Laundering Yearly Typologies Report: -
The use of money mules – intermediaries who provide legitimate identifying information to open bank accounts and who then send and receive funds but have no role in the underlying predicate crime – is widespread.
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