US NATIONAL THREAT ASSESSMENTS 2018

On 28th January, ACFCS reported on 4 reports the US government released detailing the overarching strategies to counter a chilling array of criminal threats, from narco-traffickers to rogue nation states, healthcare fraudsters to Nigerian princes and princesses, Indian “IRS” agents, to terror financiers and weapons and human traffickers.  There are 3 assessments – one each for money laundering and terrorist financing (an update to 2015 analyses), a new assessment revealing the financial tendrils tied to the proliferation of weapons and, lastly, a national strategy summarising the 3 reviews.

It identifies, “emerging and continuing risks” requiring further action including –

  • the growing misuse of virtual currencies, particularly anonymous “privacy coins”;
  • a lack of regulation and supervision of virtual currency providers in many foreign jurisdictions;
  • complicit insiders at financial institutions facilitating sanctions evasion, money laundering and other crime;
  • complicit merchants facilitating money laundering;
  • recruitment of unwitting and unquestioning individuals to facilitate money laundering;
  • trade-based money laundering – the assessments have, yet again, noted the perennial laundering vulnerability of global trade in the form of under- or over-invoiced items or simply lying about what is really in a particular crate or shipping container.

Links to the assessments can be found on the ACFCS page.

https://www.acfcs.org/news/435882/In-assessments-strong-AML-program-vital-to-countering-rising-terror-cyber-proliferation-risks.htm

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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