The June-November 2008 report* from the EU Counter-Terrorism Coordinator, on "Implementation of the Strategy and Action Plan to Combat Terrorism" has been issued and readers can access the 26-page document at:

A bill sent to the Argentinian Congress, which will allow its citizens to repatriate their overseas funds, and requires them to pay a only small tax, with no further civil or criminal penalty, could be a boon for international money launderers seeking a safe haven for the proceeds of crime. What's wrong with this picture? The proposed tax amnesty law, which will only impose a 6% tax on incoming funds placed into domestic bank accounts, and 8% on offshore assets disclosed but not repatriated, wiill not mandate the disclosure of information regarding when the funds were supposedly sent offshore. Whilst designed to bring money sent offshore, to avoid domestic income and wealth taxes, the proposed solution should not be allowed to become law.

There are multiple media reports that a former police officer currently serving a 30-year sentence for money laundering and cocaine charges will be pardoned by President George Bush prior to leaving office. The pardon is said to be issued on humanitarian grounds, due to poor health of the defendant, who has been in custody since 1993, and due to 'Substantial Assistance' rendered to law enforcement. The unofficial lists that have appeared to date appear to show that no other convicted money launderers will receive a pardon for their crimes by the outgoing administration, but there are some eleventh-hour pardons generally granted.

Action planned by both the EU and US to regulate hedge funds and to make their operations more transparent, will most likely result in the exit of substantial illicit deposits managed by money launderers. Whilst the hedge fund industry trumpets the fact that it is now generally practising effective AML and CTF compliance, this did not deter dirty money placed into the hedge fund industry in the early years, when compliance was virtually non-existent. Therefore, compliance officers who are aware of the quarterly redemption request dates on hedge fund participation should be watchful around the time that investors can cash out. Do not let suspect money exiting hedge funds find a safe harbour in your bank.

The US Treasury Department has designated its first non-financial institutions on its list of entities determined by OFAC to be owned or controlled by the Government of Iran. Iranian Transactions Regulations prohibit most commercial and financial transactions with these entities, regardless of where such entities are located or incorporated. This international aspect is important, because some of these companies have ties to the UK, Jersey and to Switzerland, according to OFAC.

Many of America's most senior (and therefore experienced) compliance officers will be home on Friday, enjoying an extended Thanksgiving holiday weekend with their families. Money launderers, who are constantly on alert for any possible opening or opportunity, are well aware of this fact. Some may choose to move illicit funds through US financial institutions that are short of compliance staff, and remember, the ultimate goal of such transfers is to usually place the money outside the United States, so watch for any large wire transfers on Friday originating in America, travelling outbound. 

The US Treasury has named a number of Zimbabwean and foreign businessmen reportedly closely linked to President Robert Mugabe as Specially Designated Nationals, or SDNs. They are accused by America of providing financial and logistical support to the present regime, enabling it to undermine democracy in that country. Be aware that the list of designees is not limited to Zimbabwe nationals; there are companies located throughout the world, and Thai and Malaysian nationals are also named.

The Holy Land Foundation of Relief and Development, and five senior leaders of the organisation, were convicted in US District Court in Dallas, Texas. on 108 charges of conspiracy to commit money laundering, conspiracy to provide material support to Hamas, a designated global terrorist group, and other counts. Some of the individuals were convicted on tax charges. The defendants were reported to have indirectly provided financial support to the families of Hamas suicide bomber and the families of individuals jailed in Israel for reputed terrorist activities. The first trial ended in a mistrial on most charges.

Money launderers for Politically Exposed Persons (PEPs) who are taking bribes, kickbacks, or some other form of illicit funds know very well that their clients have been profiled on World-Check. The clients are being turned away from opening accounts at major international banks, and they ask the laundrymen for advice and counsel. What are they told to do?  Read on, and learn how to identify the front-men.

Three leaders of Al-Shabaab, a sanctioned paramilitary group in Somalia that has reportedly been linked to al-Qaeda, have been listed as Specially Designated Global Terrorists (SDGT) by the US Treasury Office of Foreign Assets Control, also known as OFAC. The individuals include the organisation's reputed leader, its spokesman and a regional military leader. Some of those designated have multiple identities and passports issued in several countries.