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entitled 'International Financial Crime: Treasury's Roles and 
Responsibilities Relating to Selected Provisions of the USA PATRIOT 
Act' which was released on June 12, 2006. 

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Report to the Chairman, Committee on the Judiciary, House of 
Representatives: 

United States Government Accountability Office: 

GAO: 

May 2006: 

International Financial Crime: 

Treasury's Roles and Responsibilities Relating to Selected Provisions 
of the USA PATRIOT Act: 

Combating Money Laundering and Terrorist Financing: 

GAO-06-483: 

GAO Highlights: 

Highlights of GAO-06-483, a report to the Chairman, Committee on the 
Judiciary, House of Representatives. 

Why GAO Did This Study: 

Money laundering and terrorist financing can severely affect the 
nation’s economy and also result in loss of lives. To combat these 
transnational crimes, the Treasury Department (Treasury) and its 
component bureau, the Financial Crimes Enforcement Network (FinCEN), 
have key roles. Section 330 of the USA PATRIOT Act encourages the 
federal government to engage foreign jurisdictions in negotiations to 
ensure that foreign banks and financial institutions maintain adequate 
records to combat international financial crime. Treasury plays a lead 
role in facilitating such efforts. In accordance with its various 
responsibilities codified by section 361, FinCEN is to coordinate with 
its foreign counterparts—financial intelligence units (FIU). This 
report describes (1) Treasury’s approach for negotiating with foreign 
jurisdictions, (2) how FinCEN has contributed to establishing FIUs in 
foreign countries and enhancing the capabilities of these units, and 
(3) what actions FinCEN is taking to maximize its performance as a 
global partner. 

What GAO Found: 

With Treasury’s leadership, the U.S. interagency community has been 
acting to accomplish the goals articulated in section 330 of the USA 
PATRIOT Act. In particular, according to Treasury, negotiations with 
foreign jurisdictions are being accomplished through U.S. interactions 
with the Financial Action Task Force on Money Laundering (FATF), an 
intergovernmental entity that has developed international standards for 
combating money laundering and terrorist financing. Treasury emphasized 
that enactment of section 330 provided a welcomed congressional 
endorsement of long-standing U.S. policy to combat international 
financial crime by negotiating with foreign jurisdictions through 
multilateral organizations, such as FATF. 

Since its formation in 1995, FinCEN has helped foreign jurisdictions 
establish new FIUs and improve the capabilities of existing units. The 
number of FIUs has jumped from 14 in 1995 to 101 currently, partly 
because of training and technical support provided by FinCEN and 
Treasury’s Office of Technical Assistance and funding provided by the 
Department of State. Given the growth in the number of FIUs, future 
efforts likely will involve giving more attention to improving the 
capabilities of existing units, especially in reference to combating 
terrorist financing—an operational task now included in the formal 
definition of an FIU. 

To maximize performance as a global partner, FinCEN is taking various 
actions, such as assigning an analyst to the Federal Bureau of 
Investigation’s Terrorist Financing Operations Section. Also, FinCEN is 
modernizing the Egmont Secure Web, which is used by FIUs worldwide to 
exchange sensitive case information. To enhance its responsiveness to 
FIUs that request case assistance, FinCEN is allocating additional 
staff to its Office of Global Support and also is developing a new case 
management system. However, in the most recent customer satisfaction 
survey, FinCEN invited less than one-half of FIUs to participate and 
received only two responses. Future surveys would need to be more 
inclusive and incorporate better survey development and administration 
practices, such as follow-up efforts to achieve higher response rates, 
if the surveys are to serve as a useful management information tool for 
monitoring and enhancing performance. 

Figure: Meeting of FIU Representatives in Washington, D.C. (June 30 to 
July 1, 2005): 

What GAO Recommends: 

GAO recommends that the Director of FinCEN take appropriate steps to 
ensure that future customer satisfaction surveys include more 
comprehensive coverage of and higher response rates from FIUs. Treasury 
agreed. 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-483]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Rich Stana at (202) 512-
8777 or stanar@gao.gov. 

[End of Section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Treasury Department Has a Key Role in Promoting International 
Cooperation to Combat Money Laundering and Terrorist Financing: 

Enhancing the Capabilities of Financial Intelligence Units Is a 
Continuing Challenge: 

FinCEN Is Taking Various Actions to Maximize Its Performance as a 
Global Partner, but More Comprehensive Feedback from Financial 
Intelligence Units Would Be Useful: 

Conclusions: 

Recommendation for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Objectives: 

Scope and Methodology: 

Data Reliability: 

Appendix II: Financial Action Task Force and Related Regional Bodies: 

The Financial Action Task Force and Related Regional Bodies Encompass 
Member Jurisdictions around the Globe: 

FATF Recommendations Provide a Set of Countermeasures against Money 
Laundering and Terrorist Financing: 

A Widely Adopted Methodology Is Used for Monitoring Compliance with 
Financial Action Task Force Recommendations: 

Appendix III: The Egmont Group of Financial Intelligence Units: 

The Egmont Group of Financial Intelligence Units Has Grown 
Significantly since 1995: 

The Egmont Group Provides a Network for Exchanging Information: 

Tables: 

Table 1: Main Weaknesses Identified in Assessments of Compliance with 
FATF Recommendations for Combating Money Laundering and Terrorist 
Financing: 

Table 2: Financial Intelligence Units Connected to Egmont Secure Web 
and Number of User Accounts per Country (as of February 2006): 

Table 3: Case-Management Statistics--Foreign FIU and FinCEN Requests 
for Assistance: 

Table 4: Number and Names of Foreign Customer Entities That Requested 
Assistance from FinCEN in Fiscal Year 2005 (as of July 25, 2005): 

Table 5: Establishment Dates and Membership of FATF and FATF-style 
Regional Bodies: 

Table 6: FATF Recommendations on Money Laundering and Terrorist 
Financing: 

Table 7: Essential Criteria Used in the Methodology for Monitoring 
Implementation of FATF Recommendation 26: 

Table 8: Egmont Group Membership by Year and Jurisdiction: 

Figure: 

Figure 1: Annual Growth in the Number of Financial Intelligence Units: 

Abbreviations: 

BSA: Bank Secrecy Act: 
FATF: Financial Action Task Force on Money Laundering: 
FBI: Federal Bureau of Investigation: 
FinCEN: Financial Crimes Enforcement Network: 
FIU: financial intelligence unit: 
IDW: Investigative Data Warehouse: 
IMF: International Monetary Fund: 
SAR: suspicious activity report: 
USA PATRIOT (Act): Uniting and Strengthening America by Providing 
Appropriate Tools Required to Intercept and Obstruct Terrorism (Act): 

United States Government Accountability Office: 

Washington, DC 20548: 

May 12, 2006: 

The Honorable Jim Sensenbrenner, Jr. 
Chairman: 
Committee on the Judiciary: 
House of Representatives: 

Dear Mr. Chairman: 

Money laundering and terrorist financing are transnational crimes that 
can have devastating effects, involving severe economic consequences as 
well as loss of lives. The combating of these crimes demands not only 
effective U.S. interagency efforts but also concerted international 
cooperation. Key roles are played by the Department of the Treasury 
(Treasury) and one of its components, the Financial Crimes Enforcement 
Network (FinCEN).[Footnote 1] Section 330 of the USA PATRIOT 
Act[Footnote 2] expresses the sense of the Congress that the President 
should direct the Secretary of State, the Attorney General, or the 
Secretary of the Treasury to enter into negotiations with foreign 
jurisdictions to ensure that foreign banks and other financial 
institutions maintain records of transactions and account information 
relating to terrorist organizations or their members and to ensure that 
such records are made available to U.S. law enforcement and domestic 
financial institutions when appropriate. State Department, Justice 
Department, and Federal Reserve Board officials told us that the 
Treasury Department plays a lead role in addressing the efforts 
encouraged by section 330. According to Treasury Department officials, 
the U.S. interagency community has been acting to accomplish the goals 
articulated in section 330 through ongoing efforts to combat 
international financial crime. Section 361 of the USA PATRIOT 
Act[Footnote 3] established FinCEN as a statutory bureau in the 
Treasury Department and listed its various duties and powers, which 
include coordinating with its foreign counterparts--that is, financial 
intelligence units (FIUs) in other countries. These units are 
specialized governmental agencies created to combat money laundering, 
terrorist financing, and other financial crimes. Each FIU is the 
respective nation's central agency responsible for obtaining 
information (e.g., suspicious transaction reports) from financial 
institutions, processing or analyzing the information, and then 
disseminating it to appropriate authorities. 

This report addresses the following questions regarding efforts under 
sections 330 and 361 of the USA PATRIOT Act to combat money laundering 
and terrorist financing: 

* Under section 330, how has the Department of the Treasury interacted 
or negotiated with foreign jurisdictions to promote cooperative efforts 
to combat money laundering and terrorist financing? 

* Under section 361, how has FinCEN contributed to establishing FIUs in 
foreign countries and enhancing the capabilities of these units to 
combat money laundering and terrorist financing? 

* What actions is FinCEN taking to maximize its performance as a global 
partner in combating money laundering and terrorist financing? 

* To address these questions, we interviewed responsible officials at 
and analyzed relevant documentation obtained from the Departments of 
Justice, State, and the Treasury and applicable components. Also, in 
further reference to promoting international cooperation, we focused on 
obtaining information about Treasury's role and activities regarding 
multilateral organizations--particularly the Financial Action Task 
Force on Money Laundering (FATF), an intergovernmental entity that has 
developed international standards for combating money laundering and 
terrorist financing, and the various FATF-style regional bodies that 
implement the standards.[Footnote 4] We obtained information about 
FinCEN's participation in the Egmont Group, the association of FIUs 
worldwide, whose purpose is to facilitate transnational cooperation and 
information sharing to combat money laundering and terrorist financing. 
Regarding statistical information that we obtained from FinCEN--such as 
the number of requests for assistance submitted by foreign FIUs to 
FinCEN--we discussed the sources of the data with FinCEN officials and 
worked with them to resolve any discrepancies. We determined that these 
data were sufficiently reliable for the purposes of this review. We 
conducted our work from May 2005 through March 2006 in accordance with 
generally accepted government auditing standards. Appendix I presents 
more details about our objectives, scope, and methodology. 

Results in Brief: 

According to Treasury Department officials, the U.S. interagency 
community has been seeking to accomplish the goals articulated in 
section 330 through ongoing efforts to combat international financial 
crime by actively engaging and negotiating with foreign jurisdictions 
through the medium of FATF, the related FATF-style regional bodies, the 
International Monetary Fund, and the World Bank. Treasury officials 
also commented that enactment of section 330 represents a welcomed 
congressional endorsement of long-standing U.S. government policy to 
work with these entities to develop a global system to ensure that all 
countries adopt and are assessed against international standards for 
protecting financial systems and jurisdictions from money laundering 
and terrorist financing. Further, as an incentive or pressure mechanism 
that can be used in conjunction with foreign negotiations, Treasury 
considers section 311 of the USA PATRIOT Act to be particularly 
relevant.[Footnote 5] For example, section 311 authorizes the Secretary 
of the Treasury (following appropriate interagency consultation and 
consideration of multiple factors) to designate a foreign jurisdiction 
or an institution as being of "primary money laundering concern"-- 
which, in turn, could result in the Secretary of the Treasury taking 
one or more special measures, such as prohibiting or imposing 
conditions upon the opening of correspondent accounts with the 
designated entity. Since the USA PATRIOT Act was signed into law in 
October 2001, three foreign jurisdictions (Burma, Nauru, and Ukraine) 
and certain financial institutions in Belarus, Latvia, the Macau 
Special Administrative Region (China), Syria, and the "Turkish Republic 
of Northern Cyprus"[Footnote 6] have been designated primary money 
laundering concerns. Special measures have not been imposed in most of 
these cases, but the prospect of imposing them has led to some 
corrective actions. 

As a member of the Egmont Group since 1995, FinCEN has focused its 
global efforts particularly on assisting jurisdictions to establish new 
FIUs and improving the capabilities of existing units. Over the past 
decade, the number of FIUs recognized by the Egmont Group has increased 
more than sevenfold, from 14 in 1995 to 101 as of July 2005, partly 
because of federal interagency efforts, including training and 
technical support provided by FinCEN and Treasury's Office of Technical 
Assistance as well as funding provided by the Department of 
State.[Footnote 7] According to FinCEN, given the dynamic growth in the 
number of FIUs, future efforts will involve giving more attention to 
improving the capabilities of existing units, especially in reference 
to combating terrorist financing--an operational task now included in 
the Egmont Group's definition of an FIU. During our review, State 
Department officials noted one area where they would like to augment 
U.S. assistance to nascent FIUs; that is, ensuring the nascent FIUs 
have appropriate information technology (hardware and software) because 
such technology is essential to appropriately functioning FIUs. The 
State Department and FinCEN are engaged in ongoing discussions on how 
to augment such assistance. 

To maximize its performance as a global partner in combating money 
laundering and terrorist financing, FinCEN is undertaking various 
actions. Following passage of the USA PATRIOT Act, FinCEN's most 
important operational priority has been to provide counterterrorism 
support to the law enforcement and intelligence community. In this 
regard, FinCEN in January 2006 assigned an analyst to the Federal 
Bureau of Investigation's (FBI) Terrorist Financing Operations Section. 
Also, FinCEN currently is modernizing the Egmont Secure Web--an 
Internet-based system used primarily for its encrypted e-mail 
capability to exchange sensitive case information. Most (96) of the 
Egmont Group's 101 members are connected to the Egmont Secure Web, 
which is operated and maintained by FinCEN, and the system is 
considered to be of paramount importance to the operations of FIUs. By 
operating and improving the Egmont Secure Web, FinCEN plays a key role 
in fostering the exchange of information among FIUs. Further, to 
enhance its own responsiveness to information requests submitted by 
foreign FIUs, FinCEN is allocating additional staff resources to its 
Office of Global Support, which is responsible for processing requests 
from foreign FIUs, and FinCEN is developing a new case management 
system, which is targeted for completion in fiscal year 2008. FinCEN 
periodically surveys its customers to help assess its responsiveness to 
domestic and international requests for assistance. However, FinCEN's 
most recent customer satisfaction survey of external clients had 
limited coverage of FIUs; less than half of all Egmont Group members 
were invited to participate, and only two provided responses. This 
report recommends that the Director of FinCEN take appropriate steps to 
help ensure that future surveys of FIUs are sufficiently inclusive and 
responsive to achieve the intended purpose of providing performance- 
based information as a basis for evaluating services, including the 
identification of areas warranting improvement. The Department of the 
Treasury agreed with our recommendation. 

Background: 

In an international context, the Treasury Department is the United 
States' counterpart to other nations' ministries of finance. The 
department's responsibilities, among other things, include safeguarding 
the U.S. financial system from abuse by money launderers, terrorists, 
and other criminals. Over the years, in carrying out this 
responsibility, the department has established relationships with 
finance ministries, central banks, and other financial institutions in 
nations around the world as well as with multilateral organizations 
such as FATF, the FATF-style regional bodies, the International 
Monetary Fund (IMF), and the World Bank. 

FATF is an intergovernmental entity whose purpose is to establish 
international standards and to develop and promote policies for 
combating money laundering and terrorist financing. At its formation in 
1989 by the United States and other industrialized nations, FATF's 
original focus was to establish anti-money-laundering standards and 
monitor the progress of nations in meeting the standards. In 1990, FATF 
issued its "Forty Recommendations on Money Laundering" to promote the 
adoption and implementation of anti-money-laundering measures. For 
instance, the recommendations encouraged nations to enact legislation 
criminalizing money laundering and requiring financial institutions to 
report suspicious transactions. Following the events of September 11, 
2001, FATF expanded its role to combat terrorist financing. 
Specifically, in October 2001, FATF adopted "Eight Special 
Recommendations on Terrorist Financing." Among other actions, these 
recommendations committed members to criminalize the financing of 
terrorism and to freeze and confiscate terrorist assets. In October 
2004, FATF published a ninth special recommendation on terrorist 
financing to target cross-border movements of currency and monetary 
instruments ("cash couriers"). 

Collectively, FATF's "40 plus 9" recommendations are widely recognized 
as the international standards for combating money laundering and 
terrorist financing (see app. II). In monitoring nations' progress in 
implementing the recommendations, FATF collaborates with other 
multilateral organizations, particularly the FATF-style regional bodies 
that represent nations in seven geographic areas. These regional groups 
are to help nations in the region to implement the international 
standards developed by FATF. Also, these standards have been recognized 
and endorsed by the World Bank and IMF for use in conducting 
evaluations and assessments of nations' progress in implementing 
measures to counter money laundering and terrorist financing. To be 
compliant with FATF recommendations, a nation must, among other 
measures, establish an effective FIU. 

The United States' FIU is FinCEN, which was administratively 
established in 1990 as a Treasury Department component. FinCEN was 1 of 
the 14 charter members of the Egmont Group, which was formed in 1995 to 
enhance information sharing among FIUs (see app. III). In 2001, section 
361 of the USA PATRIOT Act established FinCEN as a statutory bureau in 
the Treasury Department. Organizationally, FinCEN is part of Treasury's 
Office of Terrorism and Financial Intelligence, which is the 
department's policy and enforcement entity regarding terrorist 
financing, money laundering, financial crime, and sanctions issues. 
Treasury's budget request for fiscal year 2007 included $91.3 million 
(and 352 full-time-equivalent personnel) to support FinCEN's mission of 
safeguarding the financial system from abuses of money laundering, 
terrorist financing, and other financial crime. FinCEN carries out this 
broad mission by, among other means, administering the Bank Secrecy Act 
(BSA)[Footnote 8] and networking with domestic regulatory, law 
enforcement, and intelligence agencies as well as with foreign 
counterparts. 

Treasury Department Has a Key Role in Promoting International 
Cooperation to Combat Money Laundering and Terrorist Financing: 

Section 330 of the USA PATRIOT Act expresses the sense of the Congress 
that the President should direct the Secretary of State, the Attorney 
General, or the Secretary of the Treasury to enter into negotiations 
with foreign jurisdictions to facilitate cooperative efforts to combat 
money laundering and terrorist financing. State Department, Justice 
Department, and Federal Reserve Board officials told us that the 
Treasury Department plays a lead role in addressing these efforts. 
According to Treasury Department officials, the U.S. interagency 
community has been acting to accomplish the goals articulated in 
section 330 through its interactions with FATF and the FATF-style 
regional bodies to ensure global compliance with international 
standards for combating money laundering and terrorist financing. 
Treasury officials also told us that enactment of section 330 provided 
a welcomed congressional endorsement of long-standing U.S. government 
policy to actively engage and negotiate with foreign jurisdictions 
through the medium of FATF and the related FATF-style regional bodies. 
Further, in conjunction with foreign negotiations, Treasury considers 
another provision of the USA PATRIOT Act--section 311--to be a useful 
mechanism for helping to promote compliance with standards. 

The Congress Has Encouraged International Cooperative Efforts: 

Through section 330 of the USA PATRIOT Act, Congress has encouraged the 
United States to engage in international cooperative efforts to combat 
money laundering and terrorism. Specifically, section 330 specifies, 
"It is the sense of the Congress that the President should direct the 
Secretary of State, the Attorney General, or the Secretary of the 
Treasury, as appropriate, and in consultation with the Board of 
Governors of the Federal Reserve, to seek to enter into negotiations 
with the appropriate financial supervisory agencies and other officials 
of any foreign country the financial institutions of which do business 
with United States financial institutions or which may be utilized by 
any foreign terrorist organization (as designated under section 219 of 
the Immigration and Nationality Act), any person who is a member or 
representative of any such organization, or any person engaged in money 
laundering or financial or other crimes." 

In carrying out such negotiations, section 330 further specifies the 
sense of the Congress that: 

"the President should direct the Secretary of State, the Attorney 
General, or the Secretary of the Treasury, as appropriate, to seek to 
enter into and further cooperative efforts, voluntary exchanges, the 
use of letters rogatory,[Footnote 9] mutual legal assistance treaties, 
and international agreements to (1) ensure that foreign banks and other 
financial institutions maintain adequate records of transaction and 
account information relating to any foreign terrorist organization (as 
designated under section 219 of the Immigration and Nationality Act), 
any person who is a member or representative of any such organization, 
or any person engaged in money laundering or financial or other crimes; 
and (2) establish a mechanism whereby such records may be made 
available to United States law enforcement officials and domestic 
financial institution supervisors, when appropriate." 

Section 330 does not constitute an express mandate--that is, section 
330 does not impose an affirmative obligation on any agency or official 
to enter into negotiations. Nonetheless, the language of section 330 
does suggest that efforts should be undertaken to engage in appropriate 
negotiations. 

Treasury and the Interagency Community Engage in Multilateral Efforts 
to Promote International Cooperation: 

State Department, Justice Department, and Federal Reserve Board 
officials told us that the lead role regarding the efforts encouraged 
by section 330 of the USA PATRIOT Act is held by the Treasury 
Department. According to the Treasury Department, the U.S. interagency 
community is fulfilling section 330 by actively engaging and 
negotiating with foreign jurisdictions through the medium of FATF and 
the related FATF-style regional bodies. The U.S. delegation to FATF, 
which is headed by the Deputy Assistant Secretary of the Treasury's 
Office of Terrorist Finance and Financial Crime, includes 
representatives of the Departments of Homeland Security, Justice, and 
State; the federal financial regulators; and the National Security 
Council. 

Regarding efforts encouraged by section 330, Treasury's Office of 
Terrorist Finance and Financial Crime said that the United States-- 
working through FATF, the FATF-style regional bodies, the International 
Monetary Fund, and the World Bank--has led efforts to develop a global 
system to ensure that all countries adopt and are assessed against 
international standards for protecting financial systems and 
jurisdictions from money laundering and terrorist financing. As 
mentioned previously, these international standards consist of the FATF 
"Forty Recommendations on Money Laundering" and "Nine Special 
Recommendations on Terrorist Financing" (see app. II). 

Treasury testimony at a congressional hearing in July 2005 before the 
Senate Committee on Banking, Housing, and Urban Affairs also cited the 
benefits of international standard-setting bodies. Regarding U.S. 
efforts and participation in these bodies, the Treasury Under 
Secretary's prepared statement included the following points:[Footnote 
10] 

* "The Financial Action Task Force (FATF) sets the global standards for 
anti-money laundering and counter terrorist financing, and it is also 
through this venue that we promote results. Treasury, along with our 
counterparts at State, Justice, and Homeland Security, has taken an 
active role in this 33-member body which articulates international 
standards in the form of recommendations, guidelines, and best 
practices to aid countries in developing their own specific anti-money 
laundering and counter-terrorist financing laws and regulations. … The 
success and force of FATF lie not only in the mutual evaluation process 
to which it holds its own members, but also in the emergence of FATF- 
style regional bodies … that agree to adopt FATF standards and model 
themselves accordingly on a regional level." 

* "Hawala, a relationship-based system of money remittances, plays a 
prominent role in the financial systems of the Middle East. … 
Internationally, Treasury leadership in the FATF has brought the issue 
of hawala to the forefront, resulting in implementation of FATF Special 
Recommendation VI, which requires all FATF countries to ensure that 
individuals and entities providing money transmission services must be 
licensed and registered, and subjected to the international standards 
set out by FATF." 

* "As governments apply stricter oversight and controls to banks, wire 
transmitters, and other traditional methods of moving money, we are 
witnessing terrorists and criminals resorting to bulk cash smuggling. 
FATF Special Recommendation IX was issued in late 2004 to address this 
problem and it calls upon countries to monitor cross-border 
transportation of currency and to make sanctions available against 
those who make false declarations or disclosures in this regard. This 
recommendation has already prompted changes in legislation abroad." 

Further, on July 29, 2005, the United Nations Security Council 
unanimously adopted a U.S.-sponsored resolution (Resolution 1617) that, 
among other matters, "strongly urges" all member states to "implement 
the comprehensive, international standards" embodied in the FATF 40 
plus 9 recommendations.[Footnote 11] Subsequently, at its most recent 
plenary meeting (October 12 to 14, 2005), FATF noted that "formal 
endorsement of the FATF standards by the U.N. Security Council is a 
major step toward effective implementation of the Recommendations 
throughout the world." 

Regarding the U.S. government's continuing efforts to actively engage 
and negotiate with foreign jurisdictions as encouraged by section 330, 
Treasury's Office of Terrorist Finance and Financial Crime said that 
outreach to the international community to enhance global best 
practices to combat money laundering and terrorist financing involves 
various challenges. These challenges include ensuring that the 
international standards are current in reference to emerging trends and 
technology and are balanced and flexible enough to be relevant and 
applicable to all countries and situations, as well as ensuring that 
evaluations or assessments of countries are conducted on a consistent 
basis and manner. 

Treasury Views Section 330 as a Congressional Endorsement of Long- 
standing U.S. Government Policy and a Stimulus for Continued Efforts: 

According to Treasury's Office of Terrorist Finance and Financial 
Crime, interagency efforts to work through FATF and the FATF-style 
regional bodies to help ensure global compliance with international 
standards for combating money laundering and terrorist financing is a 
long-standing policy of the U.S. government--a policy that has had 
strong support from the White House. In further elaboration, Treasury 
officials said that because working through FATF and the FATF-style 
regional bodies is a long-standing policy, no specific guidance was 
needed from the President or the White House to implement section 330. 
That is, Treasury was already seeking to accomplish the goals 
articulated in section 330. The officials commented that passage of 
section 330 did not cause Treasury or the interagency community to 
alter the objectives of ongoing or planned negotiations. In sum, the 
Treasury officials stressed that enactment of section 330 provided a 
welcomed congressional endorsement of long-standing U.S. government 
policy and also provided a stimulus for continued efforts in 
negotiating with foreign jurisdictions. 

Treasury Considers Section 311 as Particularly Relevant for Negotiating 
with Foreign Jurisdictions: 

As an incentive or pressure mechanism that can be used in conjunction 
with foreign negotiations, Treasury considers section 311 of the USA 
PATRIOT Act to be particularly relevant for helping to ensure global 
compliance with international standards for combating money laundering 
and terrorist financing.[Footnote 12] Section 311 authorizes the 
Secretary of the Treasury--in consultation with the Secretary of State 
and the Attorney General and with consideration of multiple factors--to 
find that reasonable grounds exist for concluding that a foreign 
jurisdiction, a financial institution, a class of transactions, or a 
type of account is of "primary money laundering concern." Such a 
designation is a precursor or condition precedent for taking one or 
more special measures. For instance, following a designation and with 
additional consultation and consideration of specific factors, the 
Secretary of the Treasury may require U.S. financial institutions to 
take certain "special measures" with respect to applicable 
jurisdictions, institutions, accounts, or transactions. The special 
measures can range from enhanced recordkeeping or reporting obligations 
to a requirement to terminate and not open correspondent accounts 
involving the primary money laundering concern. 

Since the USA PATRIOT Act was signed into law in October 2001, section 
311 designations have been announced for three foreign jurisdictions 
(Ukraine, Nauru, and Burma). Treasury's first use of section 311 
authority was in December 2002, with the designation of Ukraine and 
Nauru as being of primary money laundering concern. A third 
jurisdiction, Burma, was designated in November 2003. 

In addition to foreign jurisdiction designations, Treasury has also 
used section 311 authority to designate certain foreign financial 
institutions as being of primary money laundering concern. Examples 
include Myanmar Mayflower Bank and Asia Wealth Bank (November 2003), 
Commercial Bank of Syria (May 2004), First Merchant Bank of the 
"Turkish Republic of Northern Cyprus" and Infobank of Belarus (August 
2004), and Multibanka and VEF Banka of Latvia (April 2005). More 
recently, in September 2005, Treasury designated Banco Delta Asia SARL, 
which is located in the Macau Special Administrative Region, China. 

In discussing section 311 with us, Treasury's Office of Terrorist 
Finance and Financial Crime officials characterized designations--even 
without subsequent special measures being taken--as a very useful tool 
for bringing pressure on countries and institutions to meet 
international standards. For example, after being designated by 
Treasury in December 2002, Ukraine subsequently took steps to address 
deficiencies by amending its anti-money-laundering law, its banking and 
financial services laws, and its criminal code. Accordingly, Treasury 
revoked its designation in April 2003. 

Enhancing the Capabilities of Financial Intelligence Units Is a 
Continuing Challenge: 

Since 1995, the number of FIUs recognized by the Egmont Group has 
increased more than sevenfold. Attributable reasons include FATF- 
related efforts, as well as those of the federal interagency community. 
A particular focus of FinCEN--working with federal interagency 
partners--has been to provide training and technical assistance to help 
create and enhance the capabilities of FIUs. Given the significant 
growth in the number of FIUs recognized by the Egmont Group, which now 
totals 101, more attention is being focused on improving the 
capabilities of existing units, especially in reference to combating 
terrorist financing--an operational task now included in the Egmont 
Group's definition of an FIU. Generally, FIUs are evaluated as part of 
an overall methodology designed to assess a country's compliance with 
the international standards contained in the FATF 40 plus 9 
recommendations for combating money laundering and terrorist financing. 
According to FinCEN, its efforts to improve the capabilities of foreign 
FIUs must be achieved through cooperation, collaboration, and 
consensus--given that the Egmont Group is responsible for dealing with 
its members' shortcomings or noncompliance with standards. 

The Number of Financial Intelligence Units Has Increased Significantly 
Since 1995: 

Over the past decade, the number of FIUs recognized by the Egmont Group 
increased more than sevenfold, from 14 in 1995 to 101 as of July 2005 
(see fig. 1). 

Figure 1: Annual Growth in the Number of Financial Intelligence Units: 

[See PDF for image] 

[A] As of July 2005. 

[End of figure] 

A goal of the Egmont Group is to provide a forum for FIUs to improve 
support to their respective national programs for combating money 
laundering and terrorist financing. Egmont Group membership is not 
automatic for new or nascent FIUs. Rather, the Egmont Group has a Legal 
Working Group responsible for assessing each FIU-candidate to ensure 
that the prospective member meets admission criteria. For instance, the 
assessment criteria are used to determine whether the FIU-candidate 
meets the Egmont definition of an FIU, has reached full operational 
status, and is legally capable and willing to cooperate on the basis of 
Egmont principles (see app. III). Also, among other responsibilities, 
an Egmont Group member that sponsors or mentors the FIU-candidate is 
expected to have first-hand experience (including an on-site visit) to 
confirm the operational status of the candidate FIU. 

Growth in the Number of Financial Intelligence Units Is Attributable to 
Various Reasons: 

The significant growth in the number of FIUs is attributable to various 
reasons, including FATF-related efforts to establish international 
standards and promote policies for combating money laundering and 
terrorist financing. For example, FATF recommendation number 26 (see 
app. II) specifies that countries should establish an FIU that serves 
as a national center for receiving (and, as permitted, requesting), 
analyzing, and disseminating suspicious transaction reports and other 
information regarding potential money laundering or terrorist 
financing. Moreover, a contributing role has been played by the Egmont 
Group, which has an Outreach Working Group to identify candidate 
countries for membership and help them meet international standards. 

Further, the growth in the number of FIUs is attributable partly to 
federal interagency efforts, including training and technical support 
provided by FinCEN and Treasury's Office of Technical Assistance, as 
well as funding provided by the State Department. As a member of the 
Egmont Group since 1995, FinCEN in particular has focused its global 
efforts on assisting jurisdictions establish new FIUs and improving 
existing units. For instance, in helping to establish new FIUs, 
FinCEN's assistance has included a variety of activities, such as 
performing country assessments, advising or commenting on draft FIU 
legislation, providing seminars on the combating of money laundering, 
conducting training courses for FIU personnel, and furnishing technical 
advice on computer systems. According to FinCEN, much of its work now 
involves strengthening existing FIUs. In this regard, FinCEN's 
activities include conducting personnel exchanges (from foreign FIU to 
FinCEN and vice versa) and participating in operational workshops and 
other training initiatives. Also, FinCEN noted that much of its 
assistance involves regional or multilateral efforts, such as working 
closely with the Egmont Group of FIUs, the United Nations, and 
multilateral development banks. 

As an example of a recent FIU-related activity, FinCEN reported that it 
sent a four-person team to Saudi Arabia in the first quarter of fiscal 
year 2006 to conduct an on-site assessment and provide various 
presentations (covering, for example, information exchange issues) to 
employees of the Saudi FIU. In addition, FinCEN's activities for fiscal 
year 2005 included providing training (either abroad or at FinCEN) to 
FIU representatives from various nations, such as Argentina, Brazil, 
China, Guatemala, South Korea, Paraguay, and Sri Lanka. For fiscal year 
2004, FinCEN reported that it joined with the United Arab Emirates to 
host representatives from Afghanistan, Bangladesh, Maldives, Pakistan, 
and Sri Lanka on developing FIUs. Also, FinCEN's reported activities 
for fiscal year 2003 include: 

* conducting personnel exchanges with Egmont Group allies from several 
Baltic nations (i.e., Estonia, Latvia, and Lithuania), Bolivia, Turkey, 
South Korea, Ukraine, and Russia; 

* co-hosting regional training workshops in Malaysia and Mauritius; 
and: 

* sponsoring Bahrain, Mauritius, and South Africa as new members into 
the Egmont Group--with the latter two countries representing Africa's 
first representatives in the group. 

* Similarly, according to the State Department, recent activities of 
Treasury's Office of Technical Assistance include (1) providing 
training and technical assistance to FIUs in Paraguay and Peru, (2) 
helping the Senegal FIU achieve operational status, and (3) working 
with Ukraine to streamline its national FIU.[Footnote 13] 

* Generally, U.S. government assistance in creating and strengthening 
FIUs can be viewed as being one strategic element among several 
designed to enhance the capacity of global partners. For instance, the 
training and technical assistance that U.S. agencies provide to 
vulnerable countries are intended to help the countries develop five 
elements that, according to the State Department, are needed for an 
effective anti-money-laundering and counter-terrorism-financing 
regimes--a legal framework, a financial regulatory system, law 
enforcement capabilities, judicial and prosecutorial processes, and an 
appropriate FIU. However, despite the formation of an interagency 
coordination entity--the Terrorist Financing Working Group--U.S. 
efforts to coordinate the delivery of training and technical assistance 
lack an integrated strategic plan, as we recently reported.[Footnote 
14] Among other matters, our October 2005 report noted disagreements 
between the State and Treasury departments on procedures and practices 
for delivering training and technical assistance as well as 
disagreements regarding interagency leadership and coordination 
responsibilities. The report recommended that the Secretary of State 
and the Secretary of the Treasury develop an integrated strategic plan 
and enter into an agreement specifying the roles of each department, 
bureau, and office with respect to conducting needs assessments and 
delivering training and technical assistance. In March 2006, the State 
Department provided the Congress a written statement (as required under 
31 U.S Code § 720) regarding action taken on the recommendation. State 
commented that several steps were being taken to enhance interagency 
coordination. The written statement noted, for example, that the 
National Security Council and the departments of State, Justice, the 
Treasury, and Homeland Security were reviewing the work of the 
Terrorist Financing Working Group in light of recent years' experience, 
with a view to making any appropriate updates and adjustments to 
enhance its effectiveness. 

Also, during our review, State Department officials noted one area 
where they would like to augment U.S. assistance to nascent FIUs. This 
area involves ensuring that nascent FIUs have appropriate information 
technology (hardware and software). The officials emphasized that such 
technology is essential to appropriately functioning FIUs. In this 
regard, the officials said that the State Department and FinCEN are 
engaged in ongoing discussions on how to augment such assistance. 

Further regarding future directions, FinCEN's Deputy Director (who also 
chairs the Egmont Committee[Footnote 15]) commented that there will be 
continuing efforts to establish new FIUs, particularly in priority 
regions (such as the Middle East and Central Asia) critical to 
combating money laundering and terrorist financing. Moreover, given the 
dynamic growth in the Egmont Group's membership, the Deputy Director 
noted that the Egmont Committee will be giving more attention to 
improving the capabilities or effectiveness of existing FIUs. 

Capabilities of Financial Intelligence Units: Some Aspects Are Covered 
in Assessments of Compliance with FATF Recommendations: 

Generally, FIUs are evaluated as part of an overall methodology 
designed to assess a country's compliance with the international 
standards contained in the FATF 40 plus 9 recommendations for combating 
money laundering and terrorist financing (see app. II). 

As mentioned previously, FATF recommendations provide international 
standards for combating money laundering and terrorist financing. In 
this regard: 

"A key element in the fight against money laundering and the financing 
of terrorism is the need for countries to be monitored and evaluated, 
with respect to these international standards. The mutual evaluations 
conducted by the FATF and the FATF-style regional bodies, as well as 
assessments conducted by the IMF and the World Bank, are a vital 
mechanism for ensuring that the FATF Recommendations are effectively 
implemented by all countries."[Footnote 16] 

Our research and inquiries identified one published study that 
presented comparative or multicountry results based on mutual 
evaluations of nations' compliance with the FATF recommendations. The 
study--Twelve-Month Pilot Program of Anti-Money-Laundering and 
Combating the Financing of Terrorism (AML/CFT) Assessments-Joint Report 
on the Review of the Pilot Program, March 10, 2004--was prepared 
jointly by IMF and the World Bank. The study summarized the results of 
the mutual evaluations of 41 jurisdictions, conducted during the 12- 
month period that ended in October 2003.[Footnote 17] The assessments 
used a common methodology adopted by FATF and endorsed by the Executive 
Boards of IMF and the World Bank.[Footnote 18] Of the 41 assessments, 
33 were conducted by IMF or the World Bank, and 8 were conducted by 
FATF and the FATF-style regional bodies. 

In their March 2004 joint report, IMF and the World Bank presented 
assessment findings for the 41 jurisdictions in a summary format, 
rather than associating compliance levels or deficiencies with any 
individual country. For instance, the report made the following general 
observations: 

* "Overall compliance with the FATF 40+8 Recommendations is uneven 
across jurisdictions. Many jurisdictions show a high level of 
compliance with the original FATF 40 Recommendations. The most 
prevalent deficiency among all assessments is weaker compliance with 
the Eight Special Recommendations on terrorist financing." 

* "There is generally a higher level of compliance in high and middle 
income countries than in low income countries. Higher income countries 
typically have well developed AML/CFT regimes but with specific gaps, 
especially concerning the Eight Special Recommendations on terrorist 
financing." 

* The joint report did not separately present or discuss assessment 
findings related to the functioning or effectiveness of FIUs. However, 
two of the 13 main weaknesses identified are directly related to FIUs. 
These two weaknesses (see table 1) are topic 12 (no requirement to 
report promptly to the FIU if financial institutions suspect that funds 
stem from criminal activity) and topic 13 (poor international exchange 
of information relating to suspicious transactions and to persons or 
corporations involved). 

Table 1: Main Weaknesses Identified in Assessments of Compliance with 
FATF Recommendations for Combating Money Laundering and Terrorist 
Financing: 

Reference number: 1; 
Weakness identified: Topic: Poor assistance to other countries' 
financing of terrorism investigations; 
Total number of countries assessed: 40; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Number: 19; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Percent of total: 48%. 

Reference number: 2; 
Weakness identified: Topic: Poor attention to transactions with higher 
risk countries; 
Total number of countries assessed: 41; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Number: 18; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Percent of total: 44. 

Reference number: 3; 
Weakness identified: Topic: Poor detection and analysis of unusual 
large or otherwise suspicious transactions; 
Total number of countries assessed: 40; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Number: 17; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Percent of total: 43. 

Reference number: 4; 
Weakness identified: Topic: No criminalization of the financing of 
terrorism and terrorist organizations; 
Total number of countries assessed: 40; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Number: 17; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Percent of total: 43. 

Reference number: 5; 
Weakness identified: Topic: Inadequate systems to report suspicious 
transactions linked to terrorism; 
Total number of countries assessed: 39; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Number: 16; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Percent of total: 41. 

Reference number: 6; 
Weakness identified: Topic: Inadequate anti-money- laundering programs 
in supervised banks, financial institutions or intermediaries; 
authority to cooperate with judicial and law enforcement; 
Total number of countries assessed: 40; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Number: 16; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Percent of total: 40. 

Reference number: 7; 
Weakness identified: Topic: Inadequate guidelines for suspicious 
transactions' detection; 
Total number of countries assessed: 41; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Number: 16; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Percent of total: 39. 

Reference number: 8; 
Weakness identified: Topic: Inadequate measures to freeze and 
confiscate terrorist assets; 
Total number of countries assessed: 40; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Number: 14; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Percent of total: 35. 

Reference number: 9; 
Weakness identified: Topic: No requirement to take reasonable measures 
to obtain information about customer identity; 
Total number of countries assessed: 41; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Number: 14; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Percent of total: 34. 

Reference number: 10; 
Weakness identified: Topic: Inadequate procedures for mutual assistance 
in criminal matters for production of records, search of persons and 
premises, seizure and obtaining of evidence for money laundering 
investigations and prosecutions; 
Total number of countries assessed: 41; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Number: 14; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Percent of total: 34. 

Reference number: 11; 
Weakness identified: Topic: Inadequate internal policies, procedures, 
controls, audit, and training programs; 
Total number of countries assessed: 40; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Number: 13; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Percent of total: 33. 

Reference number: 12; 
Weakness identified: Topic: No requirement to report promptly to the 
financial intelligence unit if financial institutions suspect that 
funds stem from a criminal activity; 
Total number of countries assessed: 41; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Number: 13; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Percent of total: 32. 

Reference number: 13; 
Weakness identified: Topic: Poor international exchange of information 
relating to suspicious transactions and to persons or corporations 
involved; 
Total number of countries assessed: 41; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Number: 13; 
Assessed countries found "materially noncompliant" or "noncompliant" 
Percent of total: 32. 

Source: International Monetary Fund and World Bank, Twelve-Month Pilot 
Program of Anti-Money-Laundering and Combating the Financing of 
Terrorism (AML/CFT) Assessments--Joint Report on the Review of the 
Pilot Program (March 10, 2004, annex II, table 12, p, 55). 

Notes: The assessments were conducted during the 12-month period ending 
in October 2003. 

[End of table] 

According to the joint report, the 41 assessments in the pilot program 
included compliance ratings for 27 of the FATF 40 Recommendations and 7 
of the 8 Special Recommendations. Some recommendations were not rated 
because they had not yet fully come into force or they were not 
explicitly assessable, given their nature. The assessment methodology 
called for use of a four-grade rating scale--compliant, largely 
compliant, materially noncompliant, and noncompliant. 

The joint report noted that assessments using the common methodology 
are increasingly used as a diagnostic tool to identify technical 
assistance needs, including assistance for creating and strengthening 
FIUs. 

Although not published, an overview of more recent FIU-related 
assessment findings was presented on July 1, 2005, in Washington, D.C., 
at the annual plenary meeting of the Egmont Group. Specifically, an IMF 
representative presented summary information covering 29 countries, 
whose names were not disclosed. The IMF representative noted that the 
information was derived from the results of mutual evaluations or 
assessments conducted during 2003 to 2005 using the common methodology 
endorsed by FATF, IMF, and the World Bank. According to the 
presentation, the findings of the assessments indicated that many of 
the FIUs had shortcomings, such as a shortage of staff (one-third of 
the total), a lack of political independence (one-fourth), and legal 
obstacles to international cooperation (one-third). Other shortcomings 
cited were (scope not quantified) lack of clear legal framework, lack 
of strategic analysis tools, lack of access to appropriate information 
and databases, excessive transmission of information to law enforcement 
agencies, lack of guidelines on the identification of suspicious 
behavior, lack of feedback, lack of powers to sanction failure to 
report, and legal obstacles to the transmission of suspicious 
transaction reports. 

In its January 2006 response to our inquiry, the State Department said 
that the U.S. government and other major donors generally are well 
informed about the existence of FIUs (and their capabilities and 
deficiencies) in those jurisdictions in which the donors wish to 
participate. State commented that while mutual evaluations are but one 
source of information and can be outdated before being discussed at 
meetings of the FATF-style regional bodies, these evaluations are 
useful in identifying deficiencies and prompting corrective action by 
the respective jurisdiction. 

Dealing with FIU Shortcomings or Noncompliance with Standards Is a 
Responsibility of the Egmont Group: 

According to FinCEN's Deputy Director (and chair of the Egmont 
Committee), the Egmont Group is responsible for dealing with its 
members' shortcomings or noncompliance with standards. That is, even 
though influential, FinCEN has only one vote within the 101-member 
Egmont Group. Therefore, FinCEN's efforts to improve the capabilities 
of foreign FIUs must be achieved through cooperation, collaboration, 
and consensus. 

To better address Egmont Group members' shortcomings or noncompliance 
with standards, the Deputy Director commented that his preference is 
for full transparency of assessment findings. In this regard, in its 
most recent annual report, FATF announced a new process for reporting 
assessment teams' findings that are compiled in mutual assessment 
reports. Specifically, according to FATF, 

"A summary of each report will be published on the FATF website and 
FATF members have agreed in principle to make public the full mutual 
evaluation reports (with the ultimate decision being left to each FATF 
member for its own report). The FATF intends to provide comprehensive 
information on its members' actions in combating money laundering and 
terrorist financing."[Footnote 19] 

The Deputy Director also commented that the most significant functional 
change for the Egmont Group in recent years was expansion of the 
definition of an FIU in response to the terrorist attacks of September 
11. Shortly thereafter, at an October 2001 special meeting of the 
Egmont Group in Washington, D.C., the members expressed a sense that 
the group's operational functions should expand beyond money laundering 
to address terrorist financing. Later, at the Egmont Group's 12th 
plenary meeting--held during June 21 to 25, 2004, and hosted in 
Guernsey, Channel Islands--the definition of "financial intelligence 
unit" was amended to include a reference to terrorist financing. This 
new definition is reflected in the Statement of Purpose of the Egmont 
Group of Financial Intelligence Units, which resulted from the Guernsey 
plenary meeting. Thus, combating terrorist financing now is included in 
the definition of tasks an FIU is required to perform. 

According to the Deputy Director, existing FIUs have a grace period of 
at least 2 years to become compliant with the new definition. He noted 
that throughout the history of the Egmont Group, no member has ever 
been excluded from continuing participation. The Deputy Director added, 
however, that plenary meetings in recent years have begun to address 
the issue of noncompliance. For example, according to documentation of 
Egmont Group meetings:[Footnote 20] 

* The 11th Egmont Group plenary, held July 21 to 25, 2003, in Sydney, 
Australia, marked the "first attempt to establish a procedure for 
dealing with members that may no longer meet Egmont standards." 

* At the 12th Egmont plenary session, held June 21 to 25, 2004, in 
Guernsey, Channel Islands, "a paper was drafted which outlines the 
procedures to address those Egmont members that may no longer meet the 
established definitions and standards of the Egmont Group, or that fail 
to exchange information." 

* The Deputy Director said that a paper on noncompliance was also 
presented at the most recent Egmont plenary meeting, held June 30 to 
July 1, 2005, in Washington, D.C. He added that the issue will be 
revisited at the 2006 plenary meeting in Cyprus. He explained that 
dealing with noncompliance will be a difficult issue and likely will 
reflect a go-slow approach. For instance, the Deputy Director opined 
that before administrative action (such as exclusion) is taken, the 
noncompliant member probably would be offered ameliorating assistance 
over an extended period of time. 

FinCEN Is Taking Various Actions to Maximize Its Performance as a 
Global Partner, but More Comprehensive Feedback from Financial 
Intelligence Units Would Be Useful: 

Since the events of September 11, FinCEN's most important operational 
priority has been to provide counterterrorism support to the law 
enforcement and intelligence community. In January 2006, to enhance its 
support role, FinCEN assigned an analyst to the FBI's Terrorist 
Financing Operations Section. Also, among other actions to maximize 
performance as a global partner in combating money laundering and 
terrorist financing, FinCEN is modernizing the Egmont Secure Web--the 
Internet-based system developed and maintained by FinCEN and used by 
FIUs worldwide to exchange information. Further, FinCEN is allocating 
additional staff resources to facilitate responding to foreign requests 
for assistance and is developing a new case management system. However, 
FinCEN's most recent customer satisfaction survey of FIUs had limited 
coverage and a very low response rate, partly because there was no 
follow-up with nonrespondents. Future surveys would need to be more 
inclusive and incorporate better survey development and administration 
practices, such as follow-up efforts to achieve higher response rates, 
if the surveys are to serve as a useful management information tool for 
monitoring and enhancing performance. 

Challenges for FinCEN Include Redirecting Its Efforts to More Complex 
Cases as well as Supporting the Nation's Focus on Detecting and 
Preventing Terrorist Financing: 

FinCEN has recognized that it faces various challenges, such as 
redirecting its efforts to more complex cases, some of which inevitably 
have international linkages. Another important challenge is to support 
the nation's focus on detecting and preventing terrorist financing, 
which also can involve international linkages. 

At a congressional hearing held on April 29, 2004, the FinCEN Director 
testified that FinCEN must step up its international engagement with 
counterparts around the world by, among other means, enhancing: 

"the FinCEN analytical product we provide to our global counterparts 
when asked for information. Today, we are primarily providing the 
results of a data check. We think we owe our colleagues more. … [W]e 
will also be making more requests for information and analysis from our 
partners--particularly when the issue involves terrorist financing or 
money laundering."[Footnote 21] 

Similarly, FinCEN's strategic plan for fiscal years 2006 to 2008 noted 
that "a strategic challenge is to make the transition away from 
relatively simple query services that we have historically provided to 
law enforcement agencies, so that we can redirect our efforts toward 
more complex analysis and investigative support."[Footnote 22] Also, 
the strategic plan stated: 

"Like the rest of America, the Financial Crimes Enforcement Network is 
still adapting to changes triggered by the events of 9/11. These 
changes include … supporting the Department of the Treasury's new focus 
on detecting and preventing terrorist financing. … While the Financial 
Crimes Enforcement Network has historically developed the information, 
analytical processes, and tools required to detect money laundering, we 
need to develop additional tools--and to gain access to additional 
data, including classified data--in order to better detect terrorist 
financing." 

Further elaboration of planned efforts to enhance FinCEN's analytical 
capabilities is presented in Treasury's budget submission for fiscal 
year 2006: 

"FinCEN must upgrade the quality of its analysis related to terrorist 
financing and money laundering. FinCEN has begun a major initiative to 
enhance the ability of FinCEN analysts to consider all information 
sources, including, as appropriate, classified data, when analyzing 
money laundering and terrorist financing methods. To be successful, 
this will require an overall upgrade to the security environment, 
significant investments in training and building analytical skills 
relating to terrorist financing, upgrade of the analytical software 
related to text mining, enhanced availability of classified sources … 
and an increase in overall personnel security classifications to allow 
the integration of all information sources."[Footnote 23] 

A primary data source used by FinCEN analysts is the government's 
database of BSA-related forms, including suspicious activity reports 
(SARs) filed by financial institutions. An integral part of FinCEN's 
counterterrorism strategy involves reviewing and referring all SARs 
related to terrorist financing to law enforcement and intelligence 
agencies. For instance, as of September 2005, FinCEN reported that it 
had proactively developed and referred a total of 526 potential 
terrorist financing leads to appropriate agencies, such as the FBI's 
Terrorist Financing Operations Section and Joint Terrorism Task Forces. 

In 2004, the FBI contacted the Director of FinCEN and requested bulk 
access to BSA reports for ingestion into the FBI's system, the 
Investigative Data Warehouse (IDW). The FinCEN Director recognized the 
benefits of having the data available in this format and approved the 
request. According to the FBI: 

"[The IDW] is a centralized, web-enabled, closed system repository for 
intelligence and investigative data. This system, maintained by the 
FBI, allows appropriately trained and authorized personnel throughout 
the country to query for information of relevance to investigative and 
intelligence matters. In addition to BSA data provided by FinCEN, IDW 
includes information contained in myriad other law enforcement and 
intelligence community databases. The benefits of IDW include the 
ability to efficiently and effectively access multiple databases in a 
single query. As a result of the development of this robust information 
technology, a review of data that might have previously taken days or 
months now takes only minutes or seconds."[Footnote 24] 

The FBI noted that FinCEN provides the IDW with regular updates of the 
BSA data. Also, the FBI told us that it has not had any discussions 
with FinCEN regarding ways to enhance FinCEN's link-analysis 
capability. Generally, link analysis involves use of data mining and 
other computerized techniques to identify relationships across 
organizations, people, places, events, etc. Rather, the FBI noted that 
it requested FinCEN to assign an analyst to the FBI's Terrorist 
Financing Operations Section. Such an assignment, the FBI explained, 
would provide FinCEN access to additional data sources, which would be 
useful to FinCEN in performing its various roles. FinCEN told us that 
it accepted this offer almost immediately, and, subsequently, in 
January 2006, the designated FinCEN analyst reported to the FBI to 
begin initial training (2 weeks) with Terrorist Financing Operations 
Section personnel. More recently, in March 2006, in providing us 
feedback on this arrangement and other interactions, the FBI commented 
that it highly values its strong partnership with FinCEN. 

In further reference to analyzing SARs and developing counterterrorism- 
related leads, we note that FinCEN developed and transmitted a total of 
four referrals to FIUs during the past 4 fiscal years, 2002 through 
2005. Of these four referrals, according to FinCEN, two were sent to 
Spain's FIU, one was sent to the United Kingdom's FIU, and one was sent 
to both Canada's FIU and the United Kingdom's FIU. In addition to these 
proactive referrals, FinCEN emphasized that it regularly interacts with 
foreign FIUs to explore opportunities for working on issues of mutual 
interest. These efforts, according to FinCEN, essentially achieve the 
same goals and results as proactive referrals--and perhaps in a more 
tailored and effective manner. 

Modernizing the Egmont Secure Web: Technology Is Critical to 
Information Sharing, a Core Function of Financial Intelligence Units: 

Facilitating the cross-border exchange of information is a core 
function of FIUs. FinCEN plays a key role in fostering the secure 
exchange of information among FIUs, given that FinCEN operates and 
maintains the Egmont Secure Web. An Internet-based system, the Egmont 
Secure Web is used by FIUs primarily for its encrypted e-mail 
capability to exchange sensitive case information. In 1997, FinCEN 
initially launched the Egmont Secure Web, and its development was 
funded solely by the Treasury Forfeiture Fund.[Footnote 25] 

Operationally, according to FinCEN, the Egmont Secure Web is of 
paramount importance to FIUs. For instance, the Egmont Group's 
guidelines--Best Practices for the Exchange of Information between 
Financial Intelligence Units--state that, where appropriate, FIUs 
should use the Egmont Secure Web, which permits secure online 
information sharing among members. According to FinCEN, the system has 
encouraged unprecedented cooperation among FIUs because of security, 
ease of use, and quick response time. Also, FinCEN officials explained 
that the Egmont Secure Web provides online access to many reference 
materials, such as official Egmont procedural documents, FIU contact 
information, case examples, recently noted trends, and minutes from all 
Egmont meetings. 

A large majority (96) of the Egmont Group's 101 members are connected 
to the Egmont Secure Web. As of February 2006, 67 of the 96 FIUs each 
had one Egmont Secure Web user account, and 29 other FIUs each had two 
or more user accounts (see table 2). With 49 user accounts, FinCEN's 
total is nearly three times that of Belgium's FIU, which has the second 
largest number of user accounts (18). For fiscal year 2004, FinCEN 
reported that it supported 844 law enforcement cases via information 
exchanges with foreign jurisdictions and that an estimated 98 percent 
of FinCEN's responses to these jurisdictions went through the Egmont 
Secure Web. 

Table 2: Financial Intelligence Units Connected to Egmont Secure Web 
and Number of User Accounts per Country (as of February 2006): 

Number of Egmont Secure Web user accounts per country: 1; 
Number and names of countries connected to Egmont Secure Web: Number of 
countries: 67; 
Number and names of countries connected to Egmont Secure Web: [Empty]; 
Number and names of countries connected to Egmont Secure Web: Names of 
countries: Albania, Andorra, Anguilla, Aruba, Austria, Bahrain, 
Barbados, Belize, Bermuda, Bolivia, Bosnia and Herzegovina, Brazil, 
Bulgaria, Cayman Islands, Colombia, Cook Islands, Costa Rica, Croatia, 
Cyprus, Czech Republic, Dominica, Dominican Republic, Egypt, Estonia, 
Finland, Germany, Gibraltar, Grenada, Guatemala, Guernsey, Hong Kong, 
Hungary, Iceland, Ireland, Isle of Man, Israel, Japan, Jersey, Lebanon, 
Lithuania, Luxembourg, Macedonia, Malaysia, Malta, Marshall Islands, 
Mexico, Monaco, Netherlands Antilles, New Zealand, Panama, Paraguay, 
Peru, Portugal, Qatar, Romania, Russia, San Marino, Singapore, 
Slovakia, St. Vincent and the Grenadines, Sweden, Switzerland, Taiwan, 
Turkey, United Arab Emirates, Vanuatu, and Venezuela; 
Total number of Egmont Secure Web user accounts: 67. 

Number of Egmont Secure Web user accounts per country: 2; 
Number and names of countries connected to Egmont Secure Web: Number of 
countries: 15; 
Number and names of countries connected to Egmont Secure Web: [Empty]; 
Number and names of countries connected to Egmont Secure Web: Names of 
countries: Antigua & Barbuda, Denmark, France, Georgia, Italy, Korea, 
Latvia, Liechtenstein, Mauritius, Montenegro, Norway, Poland, Serbia, 
South Africa, and United Kingdom; 
Total number of Egmont Secure Web user accounts: 30. 

Number of Egmont Secure Web user accounts per country: 3; 
Number and names of countries connected to Egmont Secure Web: Number of 
countries: 5; 
Number and names of countries connected to Egmont Secure Web: [Empty]; 
Number and names of countries connected to Egmont Secure Web: Names of 
countries: Bahamas, Chile, Indonesia, Netherlands, and Slovenia; 
Total number of Egmont Secure Web user accounts: 15. 

Number of Egmont Secure Web user accounts per country: 4; 
Number and names of countries connected to Egmont Secure Web: Number of 
countries: 2; 
Number and names of countries connected to Egmont Secure Web: [Empty]; 
Number and names of countries connected to Egmont Secure Web: Names of 
countries: Honduras and Spain; 
Total number of Egmont Secure Web user accounts: 8. 

Number of Egmont Secure Web user accounts per country: 5; 
Number and names of countries connected to Egmont Secure Web: Number of 
countries: 2; 
Number and names of countries connected to Egmont Secure Web: [Empty]; 
Number and names of countries connected to Egmont Secure Web: Names of 
countries: Argentina and Canada; 
Total number of Egmont Secure Web user accounts: 10. 

Number of Egmont Secure Web user accounts per country: 6; 
Number and names of countries connected to Egmont Secure Web: Number of 
countries: 2; 
Number and names of countries connected to Egmont Secure Web: [Empty]; 
Number and names of countries connected to Egmont Secure Web: Names of 
countries: Thailand and Ukraine; 
Total number of Egmont Secure Web user accounts: 12. 

Number of Egmont Secure Web user accounts per country: 12; 
Number and names of countries connected to Egmont Secure Web: Number of 
countries: 1; 
Number and names of countries connected to Egmont Secure Web: [Empty]; 
Number and names of countries connected to Egmont Secure Web: Names of 
countries: Australia; 
Total number of Egmont Secure Web user accounts: 12. 

Number of Egmont Secure Web user accounts per country: 18; 
Number and names of countries connected to Egmont Secure Web: Number of 
countries: 1; 
Number and names of countries connected to Egmont Secure Web: [Empty]; 
Number and names of countries connected to Egmont Secure Web: Names of 
countries: Belgium; 
Total number of Egmont Secure Web user accounts: 18. 

Number of Egmont Secure Web user accounts per country: 49; 
Number and names of countries connected to Egmont Secure Web: Number of 
countries: 1; 
Number and names of countries connected to Egmont Secure Web: [Empty]; 
Number and names of countries connected to Egmont Secure Web: Names of 
countries: United States; 
Total number of Egmont Secure Web user accounts: 49. 

Number of Egmont Secure Web user accounts per country: Total; 
Number and names of countries connected to Egmont Secure Web: Number of 
countries: 96; 
Number and names of countries connected to Egmont Secure Web: [Empty]; 
Number and names of countries connected to Egmont Secure Web: Names of 
countries: [Empty]; 
Total number of Egmont Secure Web user accounts: 221. 

Source: FinCEN data. 

Note: An Egmont Secure Web user account is issued to an authorized user 
within an FIU that has been admitted into the Egmont Group. The request 
for a user account is submitted to FinCEN by an official within the 
foreign FIU. The account grants access to the Egmont Secure Web system 
and enables "view only" use of the Web content, including pages and 
documents posted for all FIUs. Also, the account includes the use of 
secure e-mail-enabling exchange of sensitive documents between FIUs. 

[End of table] 

FinCEN is in the process of modernizing the system by acquiring 
upgraded hardware and software. FinCEN officials estimated that the 
upgrade will be completed by mid-2006 and cost approximately $631,000. 
Further, the officials noted the following information: 

* The U.S. government is the owner of the system and all other users 
are stakeholders. In effect, FinCEN is providing a service to a group 
(i.e., the Egmont Group)--of which, FinCEN itself is a member. 

* The Egmont Secure Web meets or exceeds the requirements for 
information systems that handle sensitive but unclassified information. 

* The issuance of a digital certificate gives some assurance that users 
have met security requirements, but the burden is on the respective FIU 
to be responsible.[Footnote 26] 

* As a further safeguard, the officials noted that the Egmont Secure 
Web does not give foreign FIUs access to FinCEN's internal systems--for 
example, the FIUs have no direct access to BSA data. 

Management Information and Customer Feedback Are Important Tools for 
Monitoring and Improving Performance: 

Important tools for monitoring and improving performance of any 
organization include implementing an effective management information 
system and obtaining feedback from customers. Such tools are 
particularly relevant for FinCEN, a networking organization that has a 
significant role and responsibilities in combating international 
financial crime. 

Case Management: New Information System Being Developed to Better 
Manage Requests for Assistance: 

In response to our inquiry about what trends are reflected in data 
regarding the timeliness of FinCEN's responses to foreign FIU requests 
for assistance, FinCEN officials said that their management information 
system does not lend itself easily to the identification of trends. The 
officials noted, however, that FinCEN was developing a new case 
management system to make statistical information more readily 
available. According to FinCEN officials, full implementation of the 
new system is scheduled for the last quarter of fiscal year 2008. The 
officials told us that as of March 2006, no decision had been reached 
on the new system's hardware or software platform. However, the 
officials noted that in developing the new system, FinCEN is 
coordinating with Treasury's Enterprise Architecture Office and also is 
complying with applicable guidance from the Office of Management and 
Budget. 

Available case-management statistics show that FinCEN receives more 
requests from foreign FIUs than it submits to these counterparts. As 
table 3 indicates, the number of incoming requests to FinCEN has been 
about twice the number of outgoing requests in recent fiscal years. 

Table 3: Case-Management Statistics--Foreign FIU and FinCEN Requests 
for Assistance: 

Fiscal year: 2002; 
Foreign FIU requests to FinCEN (incoming requests): 510; 
FinCEN requests to foreign FIUs (outgoing requests): 341. 

Fiscal year: 2003; 
Foreign FIU requests to FinCEN (incoming requests): 529; 
FinCEN requests to foreign FIUs (outgoing requests): 211. 

Fiscal year: 2004; 
Foreign FIU requests to FinCEN (incoming requests): 612; 
FinCEN requests to foreign FIUs (outgoing requests): 292. 

Fiscal year: 2005 (through 7/25/05); 
Foreign FIU requests to FinCEN (incoming requests): 561; 
FinCEN requests to foreign FIUs (outgoing requests): 238. 

Source: FinCEN data. 

Note: The data in table 3 quantify only those requests in which FinCEN 
was a party that either received or submitted a request for 
information. Thus, the data do not include, for example, requests 
submitted by a foreign FIU to another foreign FIU. 

[End of table] 

In managing and processing incoming requests, FinCEN's policy is to 
give priority to terrorism-related requests and other "expedite" 
requests, such as those involving imminent law enforcement action or 
other extenuating time-sensitive circumstances. FinCEN officials said 
that responses are prepared to meet these deadlines. Otherwise, the 
officials said that requests from foreign FIUs are to be handled on a 
first-come, first-served basis. Generally, the officials noted that the 
timeliness of FinCEN in responding to requests from foreign FIUs can 
depend on a variety of factors, such as the volume of requests, the 
types and amount of information being requested, the number of subjects 
involved (e.g., persons and accounts), whether additional 
clarifications of the requests are needed, and even the extent of time 
zone differences between FinCEN and the foreign FIUs. 

According to FinCEN data, the average time for responding to foreign 
requests was 106 days in fiscal year 2002 and increased to 124 days in 
fiscal year 2004. The FinCEN officials attributed this increase to 
various reasons, including the growing number of FIUs and a loss of 
contract staff who handled the majority of the requests from foreign 
FIUs. More recently, FinCEN officials said that the average response 
time had decreased to 63 days for fiscal year 2005 (through July 25, 
2005). To further improve response times, the officials indicated that 
FinCEN was (1) shifting additional employees to its Office of Global 
Support (within the Analysis and Liaison Division), which is 
responsible for processing requests from foreign FIUs, and (2) hiring 
contract staff to specifically handle FIU requests for information. 

Customer Satisfaction Survey of Financial Intelligence Units: Limited 
Coverage and Low Response Rate: 

For fiscal year 2005 (through July 25, 2005), a total of 561 requests 
were made to FinCEN by 75 foreign customers, primarily FIUs. Sixteen 
FIUs accounted for two-thirds of the total requests, as table 4 shows. 

Table 4: Number and Names of Foreign Customer Entities That Requested 
Assistance from FinCEN in Fiscal Year 2005 (as of July 25, 2005): 

Foreign customers (75) that requested assistance from FInCEN: Number: 
1; 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: Ukraine FIU; 
Foreign requests to FinCEN for assistance: Number of requests: 44; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: [Empty]. 

Foreign customers (75) that requested assistance from FInCEN: Number: 
2; 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: Belgium FIU; 
Foreign requests to FinCEN for assistance: Number of requests: 40; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: [Empty]. 

Foreign customers (75) that requested assistance from FInCEN: Number: 
3; 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: Isle of Man FIU; 
Foreign requests to FinCEN for assistance: Number of requests: 39; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: [Empty]. 

Foreign customers (75) that requested assistance from FInCEN: Number: 
4; 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: Russia FIU; 
Foreign requests to FinCEN for assistance: Number of requests: 28; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: [Empty]. 

Foreign customers (75) that requested assistance from FInCEN: Number: 
5; 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: Poland FIU; 
Foreign requests to FinCEN for assistance: Number of requests: 27; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: [Empty]. 

Foreign customers (75) that requested assistance from FInCEN: Number: 
6; 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: Hungary FIU; 
Foreign requests to FinCEN for assistance: Number of requests: 26; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: [Empty]. 

Foreign customers (75) that requested assistance from FInCEN: Number: 
7; 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: Bulgaria FIU; 
Foreign requests to FinCEN for assistance: Number of requests: 23; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: [Empty]. 

Foreign customers (75) that requested assistance from FInCEN: Number: 
8; 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: Romania FIU; 
Foreign requests to FinCEN for assistance: Number of requests: 19; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: [Empty]. 

Foreign customers (75) that requested assistance from FInCEN: Number: 
9; 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: Brazil FIU; 
Foreign requests to FinCEN for assistance: Number of requests: 18; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: [Empty]. 

Foreign customers (75) that requested assistance from FInCEN: Number: 
10; 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: France FIU; 
Foreign requests to FinCEN for assistance: Number of requests: 18; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: [Empty]. 

Foreign customers (75) that requested assistance from FInCEN: Number: 
11; 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: Ireland FIU; 
Foreign requests to FinCEN for assistance: Number of requests: 18; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: [Empty]. 

Foreign customers (75) that requested assistance from FInCEN: Number: 
12; 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: Switzerland FIU; 
Foreign requests to FinCEN for assistance: Number of requests: 16; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: [Empty]. 

Foreign customers (75) that requested assistance from FInCEN: Number: 
13; 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: Israel FIU; 
Foreign requests to FinCEN for assistance: Number of requests: 15; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: [Empty]. 

Foreign customers (75) that requested assistance from FInCEN: Number: 
14; 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: Spain FIU; 
Foreign requests to FinCEN for assistance: Number of requests: 15; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: [Empty]. 

Foreign customers (75) that requested assistance from FInCEN: Number: 
15; 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: Latvia FIU; 
Foreign requests to FinCEN for assistance: Number of requests: 14; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: [Empty]. 

Foreign customers (75) that requested assistance from FInCEN: Number: 
16; 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: Croatia FIU; 
Foreign requests to FinCEN for assistance: Number of requests: 13; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: [Empty]. 

Foreign customers (75) that requested assistance from FInCEN: Number: 
Subtotal (1 through 16); 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: [Empty]; 
Foreign requests to FinCEN for assistance: Number of requests: 373; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: 66. 

Foreign customers (75) that requested assistance from FInCEN: Number: 
All 59 others (17 through 75)[A]; 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: [Empty]; 
Foreign requests to FinCEN for assistance: Number of requests: 188; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: 34. 

Foreign customers (75) that requested assistance from FInCEN: Number: 
Total; 
Foreign customers (75) that requested assistance from FInCEN: 
Jurisdiction and entity: [Empty]; 
Foreign requests to FinCEN for assistance: Number of requests: 561; 
Foreign requests to FinCEN for assistance: Percentage of total foreign 
requests: 100. 

Source: FinCEN. 

[A] The number of requests submitted by each of these 59 entities 
(primarily FIUs) ranged from 1 to 9. Foreign customers other than FIUs 
were relatively few and included, for example, Interpol. 

[End of table] 

One management priority of FinCEN is to periodically conduct customer 
satisfaction surveys. The purpose of such surveys is to "identify 
strengths and opportunities to improve services to external 
clients."[Footnote 27] FinCEN contracted with an independent research 
organization to conduct the most recent survey, which was designed and 
implemented during August to October 2005.[Footnote 28] To obtain 
feedback on FinCEN's support for investigative cases, one survey 
instrument was used for both domestic law enforcement customers 
(federal, state, and local) and international customers (FIUs). The 
survey instrument was designed to obtain feedback on various aspects of 
FinCEN's services provided during fiscal year 2005, such as the ease of 
making requests, the timeliness of responses, and the value or 
usefulness of information provided. 

To facilitate distribution of the survey instrument, FinCEN provided 
the contractor with a list of 325 customers, a total consisting of both 
domestic and international customers. According to FinCEN, this total 
represented all customers who had requested assistance from FinCEN in 
fiscal year 2005 and for whom FinCEN had valid e-mail addresses. All 
325 customers were invited via e-mail to participate in the Web-based 
survey. 

Of the 325 customers, 41 were FIUs. In answering our inquiry, FinCEN 
officials were unable to explain why all FIUs that requested assistance 
from FinCEN in fiscal year 2005 were not included in the survey. 

Subsequently, from the 325 domestic and international customers invited 
to participate in the survey, a total of 78 responses were collected, 
giving an overall response rate of 24 percent. Although not broken out 
separately in the contractor's final report, the FIU-related response 
rate was much lower, with only 2 of the 41 FIUs responding. 

As a result of the low response rate from the FIUs, insufficient 
information was received to help FinCEN identify strengths and 
opportunities to improve services to external clients. FinCEN did 
receive feedback on the level of satisfaction for two FIUs, which is 
helpful; however, the experiences of the two FIUs cannot be interpreted 
as representing the experiences of other FIUs. 

Generally, in conducting a survey, various efforts to promote the 
highest possible response rate can be considered during both survey 
development and survey administration. During survey development, 
consideration can be given to individual and organization 
characteristics that may affect the prospective respondents' level of 
cooperation in completing the survey. For instance, the prospective 
respondents may not want to be critical of the survey's sponsor. 
Another factor that affects cooperation is the burden that completing 
the survey instrument imposes on prospective respondents in terms of 
their time and the level of effort required to understand the questions 
and formulate responses. Pretesting the survey instrument is a way to 
help evaluate whether the potentially adverse effects of these types of 
factors have been minimized. Further, during survey administration, 
follow-up efforts with prospective respondents can help to promote the 
highest possible response rate. Such follow-up efforts can include e- 
mail messages, letters, or telephone calls. FinCEN officials told us 
they were unaware why the response rate from FIUs was low or whether 
the survey included any follow-up efforts to obtain responses from 
additional FIUs. 

In perspective, periodic surveys of customers are not the only method 
used by FinCEN to obtain performance feedback. For instance, in 
responding to each request for assistance from FIUs, the practice of 
FinCEN is to include an accompanying form that solicits feedback 
regarding the timeliness of FinCEN's response and the usefulness of the 
specific information provided. According to FinCEN officials, many of 
the feedback forms either are not returned or are returned with 
annotations indicating, for example, that the usefulness of the 
information provided by FinCEN may not be known until some future date. 
However, even if request-specific feedback is obtained, FinCEN 
officials recognize the benefits of conducting more comprehensive 
efforts, such as the periodic customer satisfaction surveys. This 
recognition, as mentioned previously, is reflected in FinCEN's 
Strategic Plan. 

Conclusions: 

FinCEN plays a critically important role in international efforts to 
combat money laundering and terrorist financing. It has been a leader 
in the adoption and implementation of international money laundering 
countermeasures and supporting and advancing the Egmont Group's 
principles and activities. A key part of FinCEN's international role 
has been its efforts to respond to requests for information related to 
possible international financial crime. Yet, FinCEN's method for 
obtaining performance feedback data from global partners is flawed. 
Relevant feedback data include whether FIUs find the information 
provided by FinCEN to be substantive, timely, and useful--or how 
information-sharing efforts could be improved. Without such data, 
FinCEN is not in the best position to help the international community 
combat financial crime. 

In its Strategic Plan, FinCEN recognizes the importance of periodically 
surveying its customers to "identify strengths and opportunities to 
improve services." However, FinCEN's most-recent customer satisfaction 
survey of its global partners had limited coverage--with less than one- 
half of all FIUs being invited to participate. Also, the response rate 
was very low, with no follow-up efforts directed specifically at 
nonresponding FIUs. In the future, FinCEN's customer satisfaction 
surveys of FIUs need to be more inclusive and reflect higher response 
rates if the surveys are to serve as a useful management information 
tool for monitoring and enhancing performance. The importance of 
monitoring and improving performance by obtaining feedback from 
customers is highlighted by the new operational role of FIUs in 
combating terrorist financing--a role in which the sharing or 
exchanging of information can be especially time critical. 

Recommendation for Executive Action: 

We recommend that the Director of FinCEN take appropriate steps in 
developing and administering future customer satisfaction surveys to 
help ensure more comprehensive coverage of and higher response rates 
from FIUs. For example, such steps could include pretesting the survey 
instrument and following-up with nonresponding FIUs. 

Agency Comments and Our Evaluation: 

We provided a draft of this report for comment to the departments of 
the Treasury, State, Homeland Security, and Justice, and the Federal 
Reserve Board. We received written responses from each agency. 

The Department of the Treasury responded that it supports our 
recommendation that the Director of FinCEN take appropriate steps in 
developing and administering future customer satisfaction surveys to 
help ensure more comprehensive coverage of and higher response rates 
from FIUs. The Department of the Treasury commented that it is 
committed to ensuring that customer surveys provide reliable 
performance feedback. 

The Department of State commented that our October 2005 report-- 
Terrorist Financing: Better Strategic Planning Needed to Coordinate 
U.S. Efforts to Deliver Counter-Terrorism Financing Training and 
Technical Assistance Abroad (GAO-06-19)--was not relevant for 
discussion in this report. In our view, however, the October 2005 
report provides relevant perspectives on interagency coordination and 
strategic planning, so we retained a brief discussion of it in this 
report. The Department of State also provided a technical comment 
regarding section 311 of the USA PATRIOT Act, which we incorporated 
where appropriate. 

The Department of Homeland Security and the Federal Reserve Board 
responded that they had no comments on this report. The Department of 
Justice provided technical comments only, which we incorporated in this 
report where appropriate. 

As arranged with your office, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
after the date of this report. At that time, we will send copies of 
this report to interested congressional committees and subcommittees. 
We will also make copies available to others on request. In addition, 
this report will be available at no charge on GAO's Web site at 
[Hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report or wish to 
discuss the matter further, please contact me at (202) 512-8777 or 
stanar@gao.gov. Contact points for our Offices of Congressional 
Relations and Public Affairs may be found on the last page of this 
report. Other key contributors to this report were Danny Burton, 
Frederick Lyles, Natasha Ewing, Thomas Lombardi, and Evan Gilman. 

Sincerely yours, 

Signed by: 

Richard M. Stana: 
Director, Homeland Security and Justice Issues: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Objectives: 

In response to a request from the Chairman, House Committee on the 
Judiciary, we reviewed the global or international-related efforts of 
the Department of the Treasury and the Financial Crimes Enforcement 
Network (FinCEN) to combat money laundering and terrorist financing. 
Section 330 of the USA PATRIOT Act expresses the sense of the Congress 
that the President should direct the Secretary of State, the Attorney 
General, or the Secretary of the Treasury, in consultation with the 
Board of Governors of the Federal Reserve, to seek to enter into 
negotiations with foreign jurisdictions that may be utilized by a 
foreign terrorist organization in order to further cooperative efforts 
to ensure that foreign banks and other financial institutions maintain 
adequate records of transactions and account information relating to 
any foreign terrorist organization or member thereof.[Footnote 29] The 
negotiators should also seek to establish a mechanism whereby those 
records would be made available to U.S. law enforcement officials and 
domestic financial institution supervisors, when appropriate. 

Section 361 of the USA PATRIOT Act established FinCEN as a statutory 
bureau in the Treasury Department and listed FinCEN's various duties 
and powers, which include coordinating with foreign counterparts--that 
is, financial intelligence units (FIUs) in other countries.[Footnote 
30] These units are specialized governmental agencies created to combat 
money laundering, terrorist financing, and other financial crimes. Each 
FIU is the respective nation's central agency responsible for obtaining 
information (e.g., suspicious transaction reports) from financial 
institutions, processing or analyzing the information, and then 
disseminating it to appropriate authorities. 

Specifically, our review focused on the following questions regarding 
efforts under sections 330 and 361 of the USA PATRIOT Act to combat 
money laundering and terrorist financing: 

* Under section 330 of the USA PATRIOT Act, how has the Department of 
the Treasury interacted or negotiated with foreign jurisdictions to 
promote cooperative efforts to combat money laundering and terrorist 
financing? 

* Under section 361, how has FinCEN contributed to establishing FIUs in 
foreign countries and enhancing the capabilities of these units to 
combat money laundering and terrorist financing? 

* What actions is FinCEN taking to maximize its performance as a global 
partner in combating money laundering and terrorist financing? 

Scope and Methodology: 

Initially, in addressing the principal questions, we reviewed sections 
330 and 361 of the USA PATRIOT Act and relevant legislative histories. 
Also, we reviewed information available on the Web sites of federal 
entities, including the departments of the Treasury (and FinCEN), 
Justice, State, and Homeland Security. Similarly, we reviewed 
information available on the Web sites of relevant multilateral or 
international bodies, such as (1) the Financial Action Task Force on 
Money Laundering (FATF), an intergovernmental entity whose purpose is 
to establish international standards and to develop and promote 
policies for combating money laundering and terrorist 
financing;[Footnote 31] (2) the various FATF-style regional bodies; (3) 
the International Monetary Fund; (4) the World Bank; and (5) the Egmont 
Group of FIUs.[Footnote 32] To obtain additional background and 
overview perspectives, we conducted a literature search to identify 
relevant reports, studies, articles, and other documents--including 
congressional hearing testimony--regarding U.S. and multilateral 
efforts to combat money laundering and terrorist financing. 

Treasury Department Efforts to Accomplish Goals Articulated under 
Section 330 of the USA PATRIOT Act: 

Regarding section 330 of the USA PATRIOT Act, to determine how the 
Department of the Treasury has interacted or negotiated with foreign 
jurisdictions to promote cooperative efforts to combat money laundering 
and terrorist financing, we interviewed responsible officials at and 
reviewed relevant documentation obtained from the departments of the 
Treasury, Justice, and State and the Federal Reserve Board. Also, 
because our preliminary inquiries indicated that efforts to accomplish 
the goals articulated under section 330 largely involve interactions 
with multilateral organizations--particularly FATF--we focused 
especially on the efforts of Treasury's Office of Terrorist Finance and 
Financial Crime, which leads the U.S. delegation to FATF and is the 
department's policy and enforcement entity regarding money laundering 
and terrorist financing. 

Further, because section 330 does not specify any consequences or 
penalties for noncooperative parties or countries, we determined the 
availability of incentive or pressure mechanisms that could be used in 
conjunction with negotiations. In this regard, on the basis of 
Treasury's response to our inquiry, we identified federal actions taken 
under USA PATRIOT Act section 311, which authorizes the Secretary of 
the Treasury--in consultation with the Secretary of State and the 
Attorney General--to find that reasonable grounds exist for concluding 
that a foreign jurisdiction, a financial institution, a class of 
transactions, or a type of account is of "primary money laundering 
concern."[Footnote 33] If such a finding is made, U.S. financial 
institutions could be required to take certain "special measures" 
against the applicable jurisdictions, institutions, accounts, or 
transactions. The special measures can range from enhanced record 
keeping or reporting obligations to a requirement to terminate 
correspondent banking relationships with the designated entity. 

FinCEN Contributions to Establishing FIUs in Foreign Countries and 
Enhancing Their Capabilities: 

In addressing this topic, we first obtained data on the annual growth 
in the number of FIUs over the past decade--from 1995, when the Egmont 
Group of FIUs was formed, to the present. Also, we obtained overview 
information on the history, purposes, and functioning of FIUs. For 
instance, the overview information--which was available on the Egmont 
Group's Web site (www.egmontgroup.org) or was otherwise published-- 
included the following: 

* Statement of Purpose of the Egmont Group of Financial Intelligence 
Units, 

* Principles for Information Exchange Between Financial Intelligence 
Units for Money Laundering and Terrorism Financing Cases, 

* Best Practices for the Exchange of Information between Financial 
Intelligence Units, and: 

* International Monetary Fund and World Bank, Financial Intelligence 
Units--An Overview, 2004. 

* In further reference to establishing FIUs and enhancing their 
capabilities, we obtained information on the efforts (e.g., training 
and technical support) of FinCEN and other federal contributors, such 
as Treasury's Office of Technical Assistance and the State Department. 
In so doing, we interviewed responsible officials at and reviewed 
relevant documentation obtained from FinCEN, Treasury, and State. The 
federal officials we contacted included FinCEN's Deputy Director, who 
chairs the Egmont Committee, which functions as the consultation and 
coordination mechanism for FIU heads and the Egmont Group's five 
working groups (information technology, legal, operational, training, 
and outreach).[Footnote 34] The documentation we reviewed included 
FinCEN's annual reports and strategic plans as well as the 
international narcotics control strategy reports released annually by 
the State Department's Bureau for International Narcotics and Law 
Enforcement Affairs--reports that present information on FinCEN's and 
other federal agencies' efforts to create and improve FIUs. In 
identifying these federal efforts, we did not attempt to disaggregate 
or separately quantify contributions attributable to the respective 
federal agency. Rather, we made inquiries regarding any potential 
issues involving interagency coordination of federal efforts. 

* Further regarding the capability of FIUs, we identified and reviewed 
available studies or reports. In particular, we reviewed a report 
prepared by the International Monetary Fund (IMF) and the World Bank 
that presented comparative or multicountry results based on mutual 
evaluations of nations' compliance with the FATF recommendations. The 
study--Twelve-Month Pilot Program of Anti-Money-Laundering and 
Combating the Financing of Terrorism (AML/CFT) Assessments-Joint Report 
on the Review of the Pilot Program, March 10, 2004--summarized the 
results of the mutual evaluations of 41 jurisdictions, conducted during 
the 12-month period that ended in October 2003. The assessments used a 
common methodology adopted by FATF and endorsed by the Executive Boards 
of IMF and the World Bank.[Footnote 35] 

* To obtain more current transnational perspectives on the capability 
of FIUs, we attended (as an observer) the most recent annual plenary 
meeting (June 30 to July 1, 2005) of the Egmont Group. At the plenary 
meeting, held in Washington, D.C., a summary of FIU-related assessment 
findings was presented. The information was derived from the results of 
mutual evaluations or assessments (of 29 countries) conducted from 2003 
to 2005 using the common methodology endorsed by FATF, IMF, and the 
World Bank. 

Actions FinCEN Is Taking to Maximize Its Performance as a Global 
Partner in Combating Money Laundering and Terrorist Financing: 

We inquired about FinCEN's efforts to update or modernize the Egmont 
Secure Web, which is the Internet-based communications system developed 
and maintained by FinCEN and used by FIUs worldwide to share or 
exchange information. Generally, the Egmont Secure Web is considered to 
be of paramount importance to the operations of FinCEN and foreign 
FIUs. For instance, the Egmont Group's guidelines--Best Practices for 
the Exchange of Information between Financial Intelligence Units--state 
that, where appropriate, FIUs should use the Egmont Secure Web, which 
permits secure online information sharing among members. FinCEN is in 
the process of modernizing the system's 1997 architecture by acquiring 
upgraded hardware and software. A large majority (96) of the Egmont 
Group's 101 members are connected to the Egmont Secure Web. 

Also, we reviewed annual statistical information on international- 
related requests for assistance in developing or investigating cases. 
Specifically, for fiscal years 2002 to 2005, we obtained statistics on 
requests for assistance submitted by foreign FIUs to FinCEN. To the 
extent permitted by available data, we analyzed the statistical 
information on incoming requests in reference to the subject matter of 
the request, the country of submission, and the timeliness of FinCEN's 
response to the submitting FIU. We did not analyze the quality of 
FinCEN's responses to the incoming requests for assistance. However, we 
reviewed the results of the most recent customer feedback survey 
conducted by FinCEN. Also, we inquired about FinCEN's efforts to better 
monitor or improve timeliness performance by developing a new case 
management system and assigning additional employees to the Office of 
Global Support, which is responsible for processing requests from 
foreign FIUs. 

Further, we inquired about FinCEN's efforts to enhance its analytical 
capabilities to handle more complex cases and support the nation's 
focus on detecting and preventing terrorist financing. For example, we 
contacted the Federal Bureau of Investigation's (FBI) Terrorist 
Financing Operations Section and the Foreign Terrorist Tracking Task 
Force. 

Data Reliability: 

We conducted our work from June 2005 to March 2006 in accordance with 
generally accepted government auditing standards. Regarding the 
statistical information we obtained from FinCEN--i.e., information 
concerning requests for assistance submitted by foreign FIUs to FinCEN-
-we discussed the sources of the data with FinCEN officials and worked 
with them to resolve discrepancies we identified with the data they 
provided. As resolved and presented in this report, we determined that 
these data were sufficiently reliable for the purposes of this review. 

[End of section] 

Appendix II: Financial Action Task Force and Related Regional Bodies: 

This appendix presents summary information regarding the purposes and 
functioning of the Financial Action Task Force on Money Laundering and 
the various FATF-style regional bodies--international entities whose 
mission focuses on combating money laundering and terrorist financing. 
The summary information is derived largely from FATF's Web site 
(www.fatf-gafi.org), which provides links to the regional bodies. Also, 
we discussed the information with Treasury Department officials. 

The Financial Action Task Force and Related Regional Bodies Encompass 
Member Jurisdictions around the Globe: 

Initially, FATF was created in 1989 by the G7 nations in response to 
growing concerns about money laundering.[Footnote 36] However, after 
the events of September 11, FATF's mission was expanded to combat the 
financing of terrorism. The mission of FATF consists of three principal 
activities--(1) setting standards for combating money laundering and 
terrorist financing, (2) evaluating the progress of nations in 
implementing measures to meet the standards, and (3) identifying and 
studying methods and trends regarding money laundering and terrorist 
financing. In fulfilling this mission, FATF is assisted by various FATF-
style regional bodies that have been established since 1992. As table 5 
indicates, FATF and the related regional bodies encompass member 
jurisdictions around the globe. 

Table 5: Establishment Dates and Membership of FATF and FATF-Style 
Regional Bodies: 

FATF and FATF-style regional bodies: FATF; 
Year established: 1989; 
Number and names of member jurisdictions (as of July 2005): Number: 33; 
Number and names of member jurisdictions (as of July 2005): Names: 
Argentina, Australia, Austria, Belgium, Brazil, Canada, Denmark, 
Finland, France, Germany, Greece, Hong Kong, China, Iceland, Ireland, 
Italy, Japan, Luxembourg, Mexico, the Kingdom of the Netherlands, New 
Zealand, Norway, Portugal, the Russian Federation, Singapore, South 
Africa, Spain, Sweden, Switzerland, Turkey, United Kingdom, United 
States, the European Commission,[A] and the Gulf Cooperation 
Council[B]. 

FATF and FATF-style regional bodies: Caribbean Financial Action Task 
Force; 
Year established: 1992; 
Number and names of member jurisdictions (as of July 2005): Number: 30; 
Number and names of member jurisdictions (as of July 2005): Names: 
Antigua and Barbuda, Anguilla, Aruba, The Bahamas, Barbados, Belize, 
Bermuda, the British Virgin Islands, the Cayman Islands, Costa Rica, 
Dominica, Dominican Republic, El Salvador, Grenada, Guatemala, Guyana, 
Republic of Haiti, Honduras, Jamaica, Montserrat, the Netherlands 
Antilles, Nicaragua, Panama, St. Kitts and Nevis, St. Lucia, St. 
Vincent and the Grenadines, Suriname, the Turks and Caicos Islands, 
Trinidad and Tobago, and Venezuela. 

FATF and FATF-style regional bodies: Asia/Pacific Group on Money 
Laundering; 
Year established: 1997; 
Number and names of member jurisdictions (as of July 2005): Number: 29; 
Number and names of member jurisdictions (as of July 2005): Names: 
Australia, Bangladesh, Brunei Darussalam, Cambodia, Chinese Taipei, 
Cook Islands, Fiji Islands, Hong Kong (China), India, Indonesia, Japan, 
Republic of Korea, Macau (China), Malaysia, the Marshall Islands, 
Mongolia, Nepal, New Zealand, Niue, Pakistan, Palau, the Philippines, 
Samoa, Singapore, Sri Lanka, Thailand, Tonga, the United States,[C] and 
Vanuatu. 

FATF and FATF-style regional bodies: Select Committee of Experts on the 
Evaluation of Anti-Money Laundering Measures (MONEYVAL); 
Year established: 1997; 
Number and names of member jurisdictions (as of July 2005): Number: 
27[D]; 
Number and names of member jurisdictions (as of July 2005): Names: 
Albania, Andorra, Armenia, Azerbaijan, Bosnia and Herzegovina, 
Bulgaria, Croatia, Cyprus, Czech Republic, Estonia, Georgia, Hungary, 
Latvia, Liechtenstein, Lithuania, Macedonia, Malta, Moldova, Monaco, 
Poland, Romania, the Russian Federation, San Marino, Serbia and 
Montenegro, Slovakia, Slovenia, and Ukraine. 

FATF and FATF-style regional bodies: Eastern and South Africa Anti- 
Money Laundering Group; 
Year established: 1999; 
Number and names of member jurisdictions (as of July 2005): Number: 12; 
Number and names of member jurisdictions (as of July 2005): Names: 
Botswana, Kenya, Malawi, Mauritius, Mozambique, Namibia, Swaziland, 
Seychelles, Tanzania, Uganda, Zambia, and Zimbabwe. 

FATF and FATF-style regional bodies: GAFISUD (South America); 
Year established: 2000; 
Number and names of member jurisdictions (as of July 2005): Number: 9; 
Number and names of member jurisdictions (as of July 2005): Names: 
Argentina, Bolivia, Brazil, Chile, Colombia, Ecuador, Paraguay, Peru, 
and Uruguay. 

FATF and FATF-style regional bodies: Eurasia FATF; 
Year established: 2004; 
Number and names of member jurisdictions (as of July 2005): Number: 6; 
Number and names of member jurisdictions (as of July 2005): Names: 
Belarus, China, Kazakhstan, Kyrgyz Republic, the Russian Federation, 
and Tajikistan. 

FATF and FATF-style regional bodies: Middle East and North Africa FATF; 
Year established: 2004; 
Number and names of member jurisdictions (as of July 2005): Number: 14; 
Number and names of member jurisdictions (as of July 2005): Names: 
Algeria, Bahrain, Egypt, Jordan, Kuwait, Lebanon, Morocco, Oman, Qatar, 
Saudi Arabia, Syria, Tunisia, the United Arab Emirates, and Yemen. 

Source: GAO, based on review of Web sites of FATF and regional bodies 
and verification by Treasury Department officials. 

[A] The European Commission is the executive arm of the European Union 
and is responsible for implementing the decisions of the European 
Parliament and the Council of the European Union. 

[B] The Gulf Cooperation Council--officially known as the Cooperation 
Council for the Arab States of the Gulf--was established in 1981 to 
promote stability and economic cooperation among the Persian Gulf 
nations of Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the United 
Arab Emirates. Although the Gulf Cooperation Council is a full member 
of FATF, the individual member countries are not. 

[C] The United States is a founding member of the Asia/Pacific Group on 
Money Laundering. 

[D] In addition to its 27 permanent members, MONEYVAL has 2 temporary 
members designated on a 2-year basis by the FATF presidency. For the 
period 2005-2006, the 2 temporary members are France and the 
Netherlands. 

[End of table] 

FATF Recommendations Provide a Set of Countermeasures against Money 
Laundering and Terrorist Financing: 

FATF recommendations are designed to ensure that each nation has in 
place a set of countermeasures against money laundering and terrorist 
financing. In 1990, FATF issued its "Forty Recommendations on Money 
Laundering." In October 2001, the month following the terrorist attacks 
in the United States, FATF issued "Eight Special Recommendations on 
Terrorist Financing." More recently, in October 2004, FATF published a 
ninth special recommendation on terrorist financing to target cross- 
border movements of currency and monetary instruments. Table 6 
summarizes the "Forty Recommendations on Money Laundering" and the 
"Nine Special Recommendations on Terrorist Financing." 

Table 6: FATF Recommendations on Money Laundering and Terrorist 
Financing: 

Forty Recommendations on Money Laundering: Number: 1; 
Forty Recommendations on Money Laundering: Recommendation: Scope of the 
criminal offense of money laundering: Countries should criminalize 
money laundering on the basis of United Nations Convention against 
Illicit Traffic in Narcotic Drugs and Psychotropic Substances, 1988 
(the Vienna Convention) and United Nations Convention against 
Transnational Organized Crime, 2000 (the Palermo Convention). Countries 
should apply the crime of money laundering to all serious offenses, 
with a view to including the widest range of predicate offenses. 
Predicate offenses may be described by reference to all offenses, or to 
a threshold linked either to a category of serious offenses or to the 
penalty of imprisonment applicable to the predicate offense (threshold 
approach), or to a list of predicate offenses, or a combination of 
these approaches. 

Forty Recommendations on Money Laundering: Number: 2; 
Forty Recommendations on Money Laundering: Recommendation: Criminal 
intent/ legal persons: Countries should ensure that (a) The intent and 
knowledge required to prove the offense of money laundering is 
consistent with the standards set forth in the Vienna and Palermo 
Conventions, including the concept that such mental state may be 
inferred from objective factual circumstances. (b) Criminal liability 
and, where that is not possible, civil or administrative liability 
should apply to legal persons. This should not preclude parallel 
criminal, civil, or administrative proceedings with respect to legal 
persons in countries in which such forms of liability are available. 
Legal persons should be subject to effective, proportionate, and 
dissuasive sanctions. Such measures should be without prejudice to the 
criminal liability of individuals. 

Forty Recommendations on Money Laundering: Number: 3; 
Forty Recommendations on Money Laundering: Recommendation: Provisional 
measures and confiscation: Countries should adopt measures similar to 
those set forth in the Vienna and Palermo Conventions, including 
legislative measures, to enable their respective competent authorities 
to confiscate property laundered, proceeds from money laundering or 
predicate offenses, instrumentalities used in or intended for use in 
the commission of these offense, or property of corresponding value, 
without prejudicing the rights of bona fide third parties. 

Forty Recommendations on Money Laundering: Number: 4; 
Forty Recommendations on Money Laundering: Recommendation: Financial 
secrecy: Countries should ensure that financial institution secrecy 
laws do not inhibit implementation of FATF recommendations. 

Forty Recommendations on Money Laundering: Number: 5; 
Forty Recommendations on Money Laundering: Recommendation: Customer due 
diligence: Financial institutions should not keep anonymous accounts or 
accounts in obviously fictitious names. Financial institutions should 
undertake customer due diligence measures, including identifying and 
verifying the identity of their customers. 

Forty Recommendations on Money Laundering: Number: 6; 
Forty Recommendations on Money Laundering: Recommendation: Politically 
exposed persons: Financial institutions should, in relation to 
politically exposed persons, in addition to performing normal due 
diligence measures (a) have appropriate risk management systems to 
determine whether the customer is a politically exposed person, (b) 
obtain senior management approval for establishing business 
relationships with such customers, (c) take reasonable measures to 
establish the source of wealth and source of funds, and (d) conduct 
enhanced ongoing monitoring of the business relationship. Examples of 
politically exposed persons include individuals who are heads of state 
or of government; senior politicians; senior government, judicial, or 
military officials; senior executives of state-owned corporations; and 
important political party officials. 

Forty Recommendations on Money Laundering: Number: 7; 
Forty Recommendations on Money Laundering: Recommendation: Cross-border 
correspondence: Financial institutions should, in relation to cross- 
border correspondent banking and other similar relationships, in 
addition to performing normal due diligence measures (a) gather 
sufficient information about a respondent institution to understand 
fully the nature of the respondent's business and to determine from 
publicly available information the reputation of the institution and 
the quality of supervision, including whether it has been subject to a 
money laundering or terrorist financing investigation or regulatory 
action; (b) assess the respondent institution's anti-money-laundering 
and terrorist financing controls; (c) obtain approval from senior 
management before establishing new correspondent relationships; (d) 
document the respective responsibilities of each institution; 
and (e) with respect to payable-through accounts, be satisfied that the 
respondent bank has verified the identity of and performed ongoing due 
diligence on the customers having direct access to accounts of the 
correspondent and that it is able to provide relevant customer 
identification data upon request to the correspondent bank. 

Forty Recommendations on Money Laundering: Number: 8; 
Forty Recommendations on Money Laundering: Recommendation: Non-face-to-
face business relationships or transactions: Financial institutions 
should pay special attention to any money laundering threats that may 
arise from new or developing technologies that might favor anonymity, 
and take measures, if needed, to prevent their use in money laundering 
schemes. In particular, financial institutions should have policies and 
procedures in place to address any specific risks associated with non- 
face-to-face business relationships or transactions. 

Forty Recommendations on Money Laundering: Number: 9; 
Forty Recommendations on Money Laundering: Recommendation: 
Intermediaries/ introduced business: Countries may permit financial 
institutions to rely on intermediaries or other third parties to 
perform elements…of the customer due diligence process or to introduce 
business, provided that…[specified] criteria…are met. Where such 
reliance is permitted, the ultimate responsibility for customer 
identification and verification remains with the financial institution 
relying on the third party. 

Forty Recommendations on Money Laundering: Number: 10; 
Forty Recommendations on Money Laundering: Recommendation: Record 
keeping: Financial institutions should maintain, for at least 5 years, 
all necessary records on transactions, both domestic or international, 
to enable them to comply swiftly with information requests from the 
competent authorities. Such records must be sufficient to permit 
reconstruction of individual transactions (including the amounts and 
types of currency involved if any) so as to provide, if necessary, 
evidence for prosecution of criminal activity. Financial institutions 
should keep records on the identification data obtained through the 
customer due diligence process (e.g., copies or records of official 
identification documents like passports, identity cards, driving 
licenses or similar documents), account files and business 
correspondence for at least 5 years after the business relationship is 
ended. The identification data and transaction records should be 
available to domestic competent authorities upon appropriate authority. 

Forty Recommendations on Money Laundering: Number: 11; 
Forty Recommendations on Money Laundering: Recommendation: Attention to 
complex, unusual transactions: Financial institutions should pay 
special attention to all complex, unusual large transactions, and all 
unusual patterns of transactions, which have no apparent economic or 
visible lawful purpose. The background and purpose of such transactions 
should, as far as possible, be examined, the findings established in 
writing, and be available to help competent authorities and auditors. 

Forty Recommendations on Money Laundering: Number: 12; 
Forty Recommendations on Money Laundering: Recommendation: Customer due 
diligence and record keeping for designated nonfinancial businesses and 
professions: The customer due diligence and recordkeeping requirements 
set out in Recommendations 5, 6, and 8 to 11 apply to designated non- 
financial businesses and professions in…[certain] situations. [Note: 
These entities include casinos; real estate agents; dealers in precious 
metals and stones; lawyers, notaries, other independent legal 
professionals and accountants; and trust and company service 
providers.]. 

Forty Recommendations on Money Laundering: Number: 13; 
Forty Recommendations on Money Laundering: Recommendation: Suspicious 
transaction reporting: If a financial institution suspects or has 
reasonable grounds to suspect that funds are the proceeds of a criminal 
activity, or are related to terrorist financing, it should be required, 
directly by law or regulation, to report promptly its suspicions to the 
financial intelligence unit. 

Forty Recommendations on Money Laundering: Number: 14; 
Forty Recommendations on Money Laundering: Recommendation: Protection 
for suspicious transaction reporting/tipping off: Financial 
institutions, their directors, officers, and employees should be (a) 
protected by legal provisions from criminal and civil liability for 
breach of any restriction on disclosure of information imposed by 
contract or by any legislative, regulatory, or administrative 
provision, if they report their suspicion in good faith to the 
financial intelligence unit, even if they did not know precisely what 
the underlying criminal activity was, and regardless of whether illegal 
activity actually occurred and (b) prohibited by law from disclosing 
the fact that a suspicious transaction report or related information is 
being reported to the financial intelligence unit. 

Forty Recommendations on Money Laundering: Number: 15; 
Forty Recommendations on Money Laundering: Recommendation: Internal 
policies and controls/screening, training, audit: Financial 
institutions should develop programs against money laundering and 
terrorist financing. These programs should include (a) the development 
of internal policies, procedures, and controls, including appropriate 
compliance management arrangements, and adequate screening procedures 
to ensure high standards when hiring employees; (b) an ongoing employee 
training program; and (c) an audit function to test the system. 

Forty Recommendations on Money Laundering: Number: 16; 
Forty Recommendations on Money Laundering: Recommendation: Suspicious 
transaction reporting and internal controls for designated non- 
financial businesses and professions: The requirements set out in 
Recommendations 13 to 15 and 21 apply to all designated non-financial 
businesses and professions, subject to… certain] qualifications. 

Forty Recommendations on Money Laundering: Number: 17; 
Forty Recommendations on Money Laundering: Recommendation: Sanctions: 
Countries should ensure that effective, proportionate, and dissuasive 
sanctions, whether criminal, civil, or administrative, are available to 
deal with natural or legal persons covered by these Recommendations 
that fail to comply with anti-money laundering or terrorist financing 
requirements. 

Forty Recommendations on Money Laundering: Number: 18; 
Forty Recommendations on Money Laundering: Recommendation: Shell banks: 
Countries should not approve the establishment or accept the continued 
operation of shell banks. Financial institutions should refuse to enter 
into, or continue, a correspondent banking relationship with shell 
banks. Financial institutions should also guard against establishing 
relations with respondent foreign financial institutions that permit 
their accounts to be used by shell banks. 

Forty Recommendations on Money Laundering: Number: 19; 
Forty Recommendations on Money Laundering: Recommendation: Cross-border 
transportation of currency: Countries should consider the feasibility 
and utility of a system where banks and other financial institutions 
and intermediaries would report all domestic and international currency 
transactions above a fixed amount, to a national central agency with a 
computerized data base, available to competent authorities for use in 
money laundering or terrorist financing cases, subject to strict 
safeguards to ensure proper use of the information. 

Forty Recommendations on Money Laundering: Number: 20; 
Forty Recommendations on Money Laundering: Recommendation: Application 
to other businesses and professions: Countries should consider applying 
the FATF Recommendations to businesses and professions, other than 
designated non-financial businesses and professions, that pose a money 
laundering or terrorist financing risk. Countries should further 
encourage the development of modern and secure techniques of money 
management that are less vulnerable to money laundering. 

Forty Recommendations on Money Laundering: Number: 21; 
Forty Recommendations on Money Laundering: Recommendation: Attention to 
transactions with problem countries: Financial institutions should give 
special attention to business relationships and transactions with 
persons, including companies and financial institutions, from countries 
which do not or insufficiently apply the FATF Recommendations. Whenever 
these transactions have no apparent economic or visible lawful purpose, 
their background and purpose should, as far as possible, be examined, 
the findings established in writing, and be available to help competent 
authorities. Where such country continues not to apply or 
insufficiently applies the FATF Recommendations, countries should be 
able to apply appropriate counter-measures. 

Forty Recommendations on Money Laundering: Number: 22; 
Forty Recommendations on Money Laundering: Recommendation: Application 
to branches and subsidiaries: Financial institutions should ensure that 
the principles applicable to financial institutions, which are 
mentioned above, are also applied to branches and majority-owned 
subsidiaries located abroad, especially in countries which do not or 
insufficiently apply the FATF Recommendations, to the extent that local 
applicable laws and regulations permit. When local applicable laws and 
regulations prohibit this implementation, competent authorities in the 
country of the parent institution should be informed by the financial 
institutions that they cannot apply the FATF Recommendations. 

Forty Recommendations on Money Laundering: Number: 23; 
Forty Recommendations on Money Laundering: Recommendation: Supervision/ 
regulation; prevention of criminals from positions: Countries should 
ensure that financial institutions are subject to adequate regulation 
and supervision and are effectively implementing the FATF 
Recommendations. Competent authorities should take the necessary legal 
or regulatory measure to prevent criminals or their associates from 
holding or being the beneficial owner of a significant or controlling 
interest or holding a management function in a financial institution. 

Forty Recommendations on Money Laundering: Number: 24; 
Forty Recommendations on Money Laundering: Recommendation: Supervision/ 
regulation for designated non-financial businesses and professions: 
Designated non-financial businesses and professions should be subject 
to regulatory and supervisory measures … Casinos should be subject to a 
comprehensive regulatory and supervisory regime that ensures that they 
have effectively implemented the necessary anti-money laundering and 
terrorist-financing measures.…Countries should ensure that the other 
categories of designated non-financial businesses and professions are 
subject to effective systems for monitoring and ensuring their 
compliance with requirements to combat money laundering and terrorist 
financing. 

Forty Recommendations on Money Laundering: Number: 25; 
Forty Recommendations on Money Laundering: Recommendation: Guidelines 
for detecting suspicious transactions/providing feedback: The competent 
authorities should establish guidelines and provide feedback which will 
assist financial institutions and designated non-financial businesses 
and professions in applying national measures to combat money 
laundering and terrorist financing, and in particular, in detecting and 
reporting suspicious transactions. 

Forty Recommendations on Money Laundering: Number: 26; 
Forty Recommendations on Money Laundering: Recommendation: Financial 
intelligence unit establishment/powers: Countries should establish a 
financial intelligence unit that serves as a national center for the 
receiving (and, as permitted, requesting), analysis, and dissemination 
of suspicious transaction reports and other information regarding 
potential money laundering or terrorist financing. The financial 
intelligence unit should have access, directly or indirectly, on a 
timely basis to the financial, administrative, and law enforcement 
information that it requires to properly undertake its functions, 
including the analysis of suspicious transaction reports. 

Forty Recommendations on Money Laundering: Number: 27; 
Forty Recommendations on Money Laundering: Recommendation: Designated 
law enforcement resources; investigative techniques: Countries should 
ensure that designated law enforcement authorities have responsibility 
for money laundering and terrorist financing investigations. Countries 
are encouraged to support and develop, as far as possible, special 
investigative techniques suitable for the investigation of money 
laundering, such as controlled delivery, undercover operations, and 
other relevant techniques. Countries are also encouraged to use other 
effective mechanisms such as the use of permanent or temporary groups 
specialized in asset investigation, and cooperative investigations with 
appropriate competent authorities in other countries. 

Forty Recommendations on Money Laundering: Number: 28; 
Forty Recommendations on Money Laundering: Recommendation: Document 
production, search and seizure powers: When conducting investigations 
of money laundering and underlying predicate offenses, competent 
authorities should be able to obtain documents and information for use 
in those investigations, and in prosecutions and related actions. This 
should include powers to use compulsory measures for the production of 
records held by financial institutions and other persons, for the 
search of persons and premises, and for the seizure and obtaining of 
evidence. 

Forty Recommendations on Money Laundering: Number: 29; 
Forty Recommendations on Money Laundering: Recommendation: Supervisory 
powers to monitor: Supervisors should have adequate powers to monitor 
and ensure compliance by financial institutions with requirements to 
combat money laundering and terrorist financing, including the 
authority to conduct inspections. They should be authorized to compel 
production of any information from financial institutions that is 
relevant to monitoring such compliance, and to impose adequate 
administrative sanctions for failure to comply with such requirements. 
"Supervisors" refers to designated competent authorities responsible 
for ensuring compliance by financial institutions with requirements to 
combat money laundering and terrorist financing. 

Forty Recommendations on Money Laundering: Number: 30; 
Forty Recommendations on Money Laundering: Recommendation: Adequate 
resources for competent authorities: Countries should provide their 
competent authorities involved in combating money laundering and 
terrorist financing with adequate financial, human, and technical 
resources. Countries should have in place processes to ensure that the 
staff of those authorities are of high integrity. 

Forty Recommendations on Money Laundering: Number: 31; 
Forty Recommendations on Money Laundering: Recommendation: Domestic 
cooperation: Countries should ensure that policymakers, the financial 
intelligence, law enforcement and supervisors have effective mechanisms 
in place which enable them to cooperate, and where appropriate 
coordinate domestically with each other concerning the development and 
implementation of policies and activities to combat money laundering 
and terrorist financing. 

Forty Recommendations on Money Laundering: Number: 32; 
Forty Recommendations on Money Laundering: Recommendation: Maintenance 
of statistics: Countries should ensure that their competent authorities 
can review the effectiveness of their systems to combat money 
laundering and terrorist financing systems by maintaining comprehensive 
statistics on matters relevant to the effectiveness and efficiency of 
such systems. This should include statistics on the suspicious 
transaction reports received and disseminated; on money laundering and 
terrorist financing investigations, prosecutions, and convictions; on 
property frozen, seized, and confiscated; and on mutual legal 
assistance or other international requests for cooperation. 

Forty Recommendations on Money Laundering: Number: 33; 
Forty Recommendations on Money Laundering: Recommendation: Use of legal 
persons; beneficial ownership: Countries should take measures to 
prevent the unlawful use of legal persons by money launderers. 
Countries should ensure that there is adequate, accurate, and timely 
information on the beneficial ownership and control of legal persons 
that can be obtained or accessed in a timely fashion by competent 
authorities. In particular, countries that have legal persons that are 
able to issue bearer shares should take appropriate measures to ensure 
that they are not misused for money laundering and be able to 
demonstrate the adequacy of those measures. Countries could consider 
measures to facilitate access to beneficial ownership and control 
information to financial institutions undertaking the requirements set 
out in Recommendation 5. 

Forty Recommendations on Money Laundering: Number: 34; 
Forty Recommendations on Money Laundering: Recommendation: Transparency 
for legal arrangements/trusts: Countries should take measures to 
prevent the unlawful use of legal arrangements by money launderers. In 
particular, countries should ensure that there is adequate, accurate, 
and timely information on express trusts, including information on the 
settler, trustee, and beneficiaries, that can be obtained or accessed 
in a timely fashion by competent authorities. Countries should consider 
measures to facilitate access to beneficial ownership and control 
information to financial institutions undertaking the requirements set 
out in Recommendation 5. 

Forty Recommendations on Money Laundering: Number: 35; 
Forty Recommendations on Money Laundering: Recommendation: 
International conventions: Countries should take immediate steps to 
become a party to and implement fully the Vienna Convention, the 
Palermo Convention, and the 1999 United Nations International 
Convention for the Suppression of the Financing of Terrorism. Countries 
are also encouraged to ratify and implement other relevant 
international conventions, such as the 1990 Council of Europe 
Convention on Laundering, Search, Seizure and Confiscation of the 
Proceeds from Crime, and the 2002 Inter-American Convention against 
Terrorism. 

Forty Recommendations on Money Laundering: Number: 36; 
Forty Recommendations on Money Laundering: Recommendation: Mutual legal 
assistance: Countries should rapidly, constructively, and effectively 
provide the widest possible range of mutual legal assistance in 
relation to money laundering and terrorist financing investigations, 
prosecutions, and related proceedings. In particular, countries should 
(a) not prohibit or place unreasonable or unduly restrictive conditions 
on the provision of mutual legal assistance, (b) ensure that they have 
clear and efficient processes for the execution of mutual legal 
assistance requests, (c) not refuse to execute a request for mutual 
legal assistance on the sole ground that the offense is also considered 
to involve fiscal matters, and (d) not refuse to execute a request for 
mutual legal assistance on the grounds that laws require financial 
institutions to maintain secrecy or confidentiality. Countries should 
ensure that the powers of their competent authorities required under 
Recommendation 28 are also available for use in response to requests 
for mutual legal assistance, and if consistent with their domestic 
framework, in response to direct requests from foreign judicial or law 
enforcement authorities to domestic counterparts. To avoid conflicts of 
jurisdiction, consideration should be given to devising and applying 
mechanisms for determining the best venue for prosecution of defendants 
in the interests of justice in cases that are subject to prosecution in 
more than one country. 

Forty Recommendations on Money Laundering: Number: 37; 
Forty Recommendations on Money Laundering: Recommendation: Provision of 
mutual legal assistance without dual criminality: Countries should, to 
the greatest extent possible, render mutual legal assistance 
notwithstanding the absence of dual criminality. Where dual criminality 
is required for mutual legal assistance or extradition, that 
requirement should be deemed to be satisfied regardless of whether both 
countries place the offense within the same category of offense or 
denominate the offense by the same terminology, provided that both 
countries criminalize the conduct underlying the offense. 

Forty Recommendations on Money Laundering: Number: 38; 
Forty Recommendations on Money Laundering: Recommendation: Freezing, 
seizing, and confiscating at foreign request; sharing confiscated 
assets: There should be authority to take expeditious action in 
response to requests by foreign countries to identify, freeze, seize, 
and confiscate property laundered, proceeds from money laundering or 
predicate offenses, instrumentalities used in or intended for use in 
the commission of these offenses, or property of corresponding value. 
There should also be arrangements for coordinating seizure and 
confiscation proceedings, which may include the sharing of confiscated 
assets. 

Forty Recommendations on Money Laundering: Number: 39; 
Forty Recommendations on Money Laundering: Recommendation: Extradition: 
Countries should recognize money laundering as an extraditable offense. 
Each country should either extradite its own nationals, or where a 
country does not do so solely on the grounds of nationality, that 
country should, at the request of the country seeking extradition, 
submit the case without delay to its competent authorities for the 
purpose of prosecution of the offenses set forth in the request. Those 
authorities should take their decision and conduct their proceedings in 
the same manner as in the case of any other offense of a serious nature 
under the domestic law of that country. The countries concerned should 
cooperate with each other, in particular on procedural and evidentiary 
aspects, to ensure the efficiency of such prosecutions. Subject to 
their legal frameworks, countries may consider simplifying extradition 
by allowing direct transmission of extradition requests between 
appropriate ministries, extraditing persons based only on warrants of 
arrests or judgments, and/or introducing a simplified extradition of 
consenting persons who waive formal extradition proceedings. 

Forty Recommendations on Money Laundering: Number: 40; 
Forty Recommendations on Money Laundering: Recommendation: 
International cooperation and exchange of information: Countries should 
ensure that their competent authorities provide the widest possible 
range of international cooperation to their foreign counterparts. There 
should be clear and effective gateways to facilitate the prompt and 
constructive exchange directly between counterparts, either 
spontaneously or upon requests, of information relating to both money 
laundering and the underlying predicate offenses. Exchanges should be 
permitted without unduly restrictive conditions. In particular, (a) 
competent authorities should not refuse a request for assistance on the 
sole ground that the request is also considered to involve fiscal 
matters; (b) countries should not invoke laws that require financial 
institutions to maintain secrecy or confidentiality as a ground for 
refusing to provide cooperation; and (c) competent authorities should 
be able to conduct inquiries and, where possible, investigations on 
behalf of foreign counterparts. Where the ability to obtain information 
sought by a foreign competent authority is not within the mandate of 
its counterparts, countries are also encouraged to permit a prompt and 
constructive exchange of information with non-counterparts. Cooperation 
with foreign authorities other than counterparts could occur directly 
or indirectly. When uncertain about the appropriate avenue to follow, 
competent authorities should first contact their foreign counterparts 
for assistance. Countries should also establish controls and safeguards 
to ensure that information exchanged by competent authorities is used 
only in an authorized manner, consistent with their obligations 
concerning privacy and data protection. 

Forty Recommendations on Money Laundering: Number: I; 
Forty Recommendations on Money Laundering: Recommendation: Ratification 
and implementation of UN instruments: Each country should take 
immediate steps to ratify and to implement fully the1999 United Nations 
International Convention for the Suppression of the Financing of 
Terrorism. Countries should also immediately implement the United 
Nations resolutions relating to the prevention and suppression of the 
financing of terrorist acts, particularly United Nations Security 
Council Resolution 1373. 

Forty Recommendations on Money Laundering: Number: II; 
Forty Recommendations on Money Laundering: Recommendation: 
Criminalizing the financing of terrorism and associated money 
laundering: Each country should criminalize the financing of terrorism, 
terrorist acts, and terrorist organizations. Countries should ensure 
that such offenses are designated as money laundering predicate 
offenses. 

Forty Recommendations on Money Laundering: Number: III; 
Forty Recommendations on Money Laundering: Recommendation: Freezing and 
confiscating terrorist assets: Each country should implement measures 
to freeze without delay funds or other assets of terrorists, those who 
finance terrorism and terrorist organizations in accordance with the 
United Nations resolutions relating to the prevention and suppression 
of the financing of terrorist acts. Each country should also adopt and 
implement measures, including legislative ones, which would enable the 
competent authorities to seize and confiscate property that is the 
proceeds of, or used in, or intended or allocated for use in, the 
financing of terrorism, terrorist acts, or terrorist organizations. 

Forty Recommendations on Money Laundering: Number: IV; 
Forty Recommendations on Money Laundering: Recommendation: Reporting 
suspicious transactions related to terrorism: If financial 
institutions, or other businesses or entities subject to anti-money 
laundering obligations, suspect or have reasonable grounds to suspect 
that funds are linked or related to, or are to be used for terrorism, 
terrorist acts or by terrorist organizations, they should be required 
to report promptly their suspicions to the competent authorities. 

Forty Recommendations on Money Laundering: Number: V; 
Forty Recommendations on Money Laundering: Recommendation: 
International cooperation: Each country should afford another country, 
on the basis of a treaty, arrangement, or other mechanism for mutual 
legal assistance or information exchange, the greatest possible measure 
of assistance in connection with criminal, civil enforcement, and 
administrative investigations, inquiries, and proceedings relating to 
the financing of terrorism, terrorist acts, and terrorist 
organizations. Countries should also take all possible measures to 
ensure that they do not provide safe havens for individuals charged 
with the financing of terrorism, terrorist acts, or terrorist 
organizations, and should have procedures in place to extradite, where 
possible, such individuals. 

Forty Recommendations on Money Laundering: Number: VI; 
Forty Recommendations on Money Laundering: Recommendation: Alternative 
remittance: Each country should take measures to ensure that persons or 
legal entities, including agents, that provide a service for the 
transmission of money or value, including transmission through an 
informal money or value transfer system or network, should be licensed 
or registered and subject to all the FATF recommendations that apply to 
banks and non-bank financial institutions. Each country should ensure 
that persons or legal entities that carry out this service illegally 
are subject to administrative, civil, or criminal sanctions. 

Forty Recommendations on Money Laundering: Number: VII; 
Forty Recommendations on Money Laundering: Recommendation: Wire 
transfers: Countries should take measures to require financial 
institutions, including money remitters, to include accurate and 
meaningful originator information (name, address, and account number) 
on funds transfers and related messages that are sent, and the 
information should remain with the transfer or related message through 
the payment chain. Countries should take measures to ensure that 
financial institutions, including money remitters, conduct enhanced 
scrutiny of and monitor for suspicious activity funds transfers which 
do not contain complete originator information (name, address, and 
account number). 

Forty Recommendations on Money Laundering: Number: VIII; 
Forty Recommendations on Money Laundering: Recommendation: Non-profit 
organizations: Countries should review the adequacy of laws and 
regulations that relate to entities that can be abused for the 
financing of terrorism. Non-profit organizations are particularly 
vulnerable, and countries should ensure that they cannot be misused (a) 
by terrorist organizations posing as legitimate entities; (b) to 
exploit legitimate entities as conduits for terrorist financing, 
including for the purpose of escaping asset freezing measures; and (c) 
to conceal or obscure the clandestine diversion of funds intended for 
legitimate purposes to terrorist organizations. 

Forty Recommendations on Money Laundering: Number: IX; 
Forty Recommendations on Money Laundering: Recommendation: Cash 
couriers: Countries should have measures in place to detect the 
physical cross- border transportation of currency and bearer negotiable 
instruments, including a declaration system or other disclosure 
obligation. Countries should ensure that their competent authorities 
have the legal authority to stop or restrain currency or bearer 
negotiable instruments that are suspected to be related to terrorist 
financing or money laundering, or that are falsely declared or 
disclosed. Countries should ensure that effective, proportionate, and 
dissuasive sanctions are available to deal with persons who make false 
declaration(s) or disclosure(s). In cases where the currency or bearer 
negotiable instruments are related to terrorist financing or money 
laundering, countries should also adopt measures, including legislative 
ones consistent with Recommendation 3 and Special Recommendation III, 
which would enable the confiscation of such currency or instruments. 

Source: GAO, based on review of FATF materials. 

[End of table] 

Collectively, these "40 plus 9" recommendations issued by FATF are 
recognized as the international standards for combating money 
laundering and terrorist financing. Although the FATF recommendations 
do not constitute a binding international convention, many countries-- 
e.g., member nations of FATF and the FATF-style regional bodies--have 
made a political commitment to combat money laundering and terrorist 
financing by implementing the recommendations. Moreover, the 
international community has recognized the need for monitoring to 
ensure that countries effectively implement the FATF recommendations. 

A Widely Adopted Methodology Is Used for Monitoring Compliance with 
Financial Action Task Force Recommendations: 

One of the means for monitoring compliance with FATF recommendations is 
a mutual evaluation process whereby a team of experts conducts on-site 
visits to assess the progress of member countries. To guide the 
assessment of a country's compliance with international standards, a 
widely adopted methodology is used--Methodology for Assessing 
Compliance with the FATF 40 Recommendations and the FATF 9 Special 
Recommendations (updated as of February 2005).[Footnote 37] In addition 
to its use by FATF mutual evaluation teams, the Methodology has also 
been approved or endorsed by the FATF-style regional bodies and the 
Executive Boards of the International Monetary Fund and the World Bank. 

The Methodology reflects the principles and follows the structure of 
the FATF recommendations. For each of the recommendations, the 
Methodology enumerates elements ("essential criteria") that should be 
present for full compliance. For instance, table 3 shows the essential 
criteria used for assessing implementation of FATF Recommendation 26, 
which calls for each nation to establish and empower a financial 
intelligence unit. 

Table 7: Essential Criteria Used in the Methodology for Monitoring 
Implementation of FATF Recommendation 26: 

Essential criterion reference number: 26.1; 
Subject of the essential criteria: Countries should establish an FIU 
that serves as a national center for receiving (and if permitted, 
requesting), analyzing, and disseminating disclosures of suspicious 
transaction reports and other relevant information concerning suspected 
money laundering or financing of terrorism activities. The FIU can be 
established either as an independent governmental authority or within 
an existing authority or authorities. 

Essential criterion reference number: 26.2; 
Subject of the essential criteria: The FIU or another competent 
authority should provide financial institutions and other reporting 
parties with guidance regarding the manner of reporting, including the 
specification of reporting forms and the procedures that should be 
followed when reporting. 

Essential criterion reference number: 26.3; 
Subject of the essential criteria: The FIU should have access, directly 
or indirectly, on a timely basis to the financial, administrative, and 
law enforcement information that it requires to properly undertake its 
functions, including the analysis of suspicious transaction reports. 

Essential criterion reference number: 26.4; 
Subject of the essential criteria: The FIU, either directly or through 
another competent authority, should be authorized to obtain from 
reporting parities additional information needed to properly undertake 
its functions. 

Essential criterion reference number: 26.5; 
Subject of the essential criteria: The FIU should be authorized to 
disseminate financial information to domestic authorities for 
investigation or action when there are grounds to suspect money 
laundering or the financing of terrorism. 

Essential criterion reference number: 26.6; 
Subject of the essential criteria: The FIU should have sufficient 
operational independence and autonomy to ensure that it is free from 
undue influence or interference. 

Essential criterion reference number: 26.7; 
Subject of the essential criteria: Information held by the FIU should 
be securely protected and disseminated only in accordance with the law. 

Essential criterion reference number: 26.8; 
Subject of the essential criteria: The FIU should publicly release 
periodic reports, and such reports should include statistics, 
typologies, and trends as well as information regarding its activities. 

Essential criterion reference number: 26.9; 
Subject of the essential criteria: Where a country has created an FIU, 
it should consider applying for membership in the Egmont Group. 

Essential criterion reference number: 26.10; 
Subject of the essential criteria: Countries should have regard to the 
Egmont Group Statement of Purpose and its Principles for Information 
Exchange Between Financial Intelligence Units for Money Laundering 
Cases. (These documents set out important guidance concerning the role 
and functions of FIUs and the mechanisms for exchanging information 
between FIUs.) 

Source: GAO, based on review of FATF materials. 

[End of table] 

[End of section] 

Appendix III: The Egmont Group of Financial Intelligence Units: 

This appendix presents summary information regarding the growth of the 
Egmont Group, which is an informal global association of governmental 
operating units created to support their respective nation's or 
territory's efforts to combat money laundering and terrorism financing. 
More detailed information about the purposes and functioning of the 
Egmont Group and its members is available at the entity's Web site 
(www.egmontgroup.org).[Footnote 38] 

The Egmont Group of Financial Intelligence Units Has Grown 
Significantly since 1995: 

On June 9, 1995, representatives of various nations (including the 
United States) and international organizations met at the Egmont- 
Arenberg palace in Brussels, Belgium, to discuss ways to enhance mutual 
cooperation in combating the global problem of money laundering. A 
result was creation of the Egmont Group, whose members are the 
specialized anti-money-laundering organizations known as financial 
intelligence units. In attendance at the 1995 meeting were 
representatives of 14 of these governmental units ("disclosure- 
receiving agencies") that became the first Egmont Group members. In the 
decade since 1995, the group's membership has increased significantly, 
reaching a total of 101 jurisdictions as of July 2005 (see table 8). 

Table 8: Egmont Group Membership by Year and Jurisdiction: 

Calendar year: 1995; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Number: 14; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Jurisdiction (countries and territories): Australia, 
Austria, Belgium, France, Iceland, Luxembourg, Monaco, the Netherlands, 
Norway, Slovenia, Spain, Sweden, United Kingdom, and the United States; 
Cumulative number of Egmont Group members (as of year end): 14. 

Calendar year: 1996; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Number: 0; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Jurisdiction (countries and territories): None; 
Cumulative number of Egmont Group members (as of year end): 14. 

Calendar year: 1997; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Number: 14; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Jurisdiction (countries and territories): Aruba, 
Chile, the Czech Republic, Denmark, Guernsey, Hong Kong, Hungary, 
Ireland, Isle of Man, Italy, Mexico, New Zealand, Panama, and Slovakia; 
Cumulative number of Egmont Group members (as of year end): 28. 

Calendar year: 1998; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Number: 10; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Jurisdiction (countries and territories): Croatia, 
Cyprus, Finland, Greece, Jersey, the Netherlands Antilles, Paraguay, 
Switzerland, Taiwan, and Turkey; 
Cumulative number of Egmont Group members (as of year end): 38. 

Calendar year: 1999; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Number: 10; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Jurisdiction (countries and territories): Bermuda, 
Bolivia, Brazil, British Virgin Islands, Bulgaria, Costa Rica, Latvia, 
Lithuania, Portugal, and Venezuela; 
Cumulative number of Egmont Group members (as of year end): 48. 

Calendar year: 2000; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Number: 5; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Jurisdiction (countries and territories): Colombia, 
the Dominican Republic, Japan, Estonia, and Romania; 
Cumulative number of Egmont Group members (as of year end): 53. 

Calendar year: 2001; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Number: 5; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Jurisdiction (countries and territories): The Bahamas, 
Cayman Islands, El Salvador, Liechtenstein, and Thailand; 
Cumulative number of Egmont Group members (as of year end): 58. 

Calendar year: 2002; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Number: 11; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Jurisdiction (countries and territories): Andorra, 
Barbados, Canada, Israel, Marshall Islands, Poland, Russia, Singapore, 
South Korea, United Arab Emirates, and Vanuatu; 
Cumulative number of Egmont Group members (as of year end): 69. 

Calendar year: 2003; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Number: 15; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Jurisdiction (countries and territories): Albania, 
Anguilla, Antigua and Barbuda, Argentina, Bahrain, Dominica, Germany, 
Guatemala, Lebanon, Malaysia, Malta, Mauritius, Serbia, South Africa, 
and St. Vincent and the Grenadines; 
Cumulative number of Egmont Group members (as of year end): 84. 

Calendar year: 2004; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Number: 10; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Jurisdiction (countries and territories): Belize, Cook 
Islands, Egypt, Georgia, Gibraltar, Grenada, Indonesia, Macedonia, St. 
Kitts and Nevis, and Ukraine; 
Cumulative number of Egmont Group members (as of year end): 94. 

Calendar year: 2005[A]; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Number: 7; 
Financial intelligence units admitted into Egmont Group membership 
during the year: Jurisdiction (countries and territories): Bosnia and 
Herzegovina, Honduras, Montenegro, Peru, Philippines, Qatar, and San 
Marino; 
Cumulative number of Egmont Group members (as of year end): 101. 

Source: FinCEN. 

[A] The admissions in calendar year 2005 and the cumulative total are 
as of July 2005. 

[End of table] 

The Egmont Group Provides a Network for Exchanging Information: 

The common purpose of every FIU is to combat money laundering and 
terrorism financing. This purpose is reflected in the Egmont Group's 
definition of an FIU, which is as follows: 

"A central, national agency responsible for receiving, (and as 
permitted, requesting), analyzing and disseminating to the competent 
authorities, disclosures of financial information: 

* concerning suspected proceeds of crime and potential financing of 
terrorism, or: 

* required by national legislation or regulation, in order to combat 
money laundering and terrorism financing."[Footnote 39] 

* This definition, which was adopted in June 2004 at the Egmont Group's 
plenary meeting in Guernsey, reflects an expansion of the role of FIUs 
to include combating terrorist financing. 

* Facilitating cross-border information sharing is a core goal of the 
Egmont Group. To enhance such sharing and provide guidelines, the 
Egmont Group has generated two documents--(1) Principles for 
Information Exchange between Financial Intelligence Units for Money 
Laundering and Terrorism Financing Cases and (2) Best Practices for the 
Exchange of Information between Financial Intelligence Units. In part, 
the Principles document provides that: 

* "FIUs should be able to exchange information freely with other FIUs 
on the basis of reciprocity or mutual agreement and consistent with 
procedures understood by the requested and requesting party. Such 
exchange, either upon request or spontaneously, should provide any 
available information that may be relevant to an analysis or 
investigation of financial transactions and other relevant information 
and the persons or companies involved." 

* "An FIU requesting information should disclose, to the FIU that will 
process the request, at a minimum the reason for the request, the 
purpose for which the information will be used and enough information 
to enable the receiving FIU to determine whether the request complies 
with its domestic law." 

* "Information exchanged between FIUs may be used only for the specific 
purpose for which the information was sought or provided." 

* "The requesting FIU may not transfer information shared by a 
disclosing FIU to a third party, nor make use of the information in an 
administrative, investigative, prosecutorial, or judicial purpose 
without the prior consent of the FIU that disclosed the information." 

* The Best Practices document specifies that "the exchange of 
information between FIUs should take place as informally and as rapidly 
as possible and with no excessive formal requirements, while 
guaranteeing protection of privacy and confidentiality of the shared 
data" and that, where appropriate, FIUs should use the Egmont Secure 
Web. Further, among other guidelines, the document provides that: 

* "If necessary the requesting FIU should indicate the time by which it 
needs to receive an answer. Where a request is marked 'urgent' or a 
deadline is indicated, the reasons for the urgency or deadline should 
be explained." 

* "FIUs should give priority to urgent requests. If the receiving FIU 
has concerns about the classification of a request as urgent, it should 
contact the requesting FIU immediately in order to resolve the issue. 
Moreover, each request, whether or not marked as 'urgent,' should be 
processed in the same timely manner as domestic requests for 
information." 

* "As a general principle, the requested FIU should strive to reply to 
a request for information, including an interim response, within 1 week 
from receipt in the following circumstances: 

* if it can provide a positive/negative answer to a request regarding 
information it has direct access to; 

* if it is unable to provide an answer due to legal impediments." 

* "Whenever the requested FIU needs to have external databases searched 
or query third parties (such as financial institutions), an answer 
should be provided within 1 month after receipt of the request." 

* "If the results of the enquiries are still not all available after 1 
month, the requested FIU should provide the information it already has 
in its possession or at least give an indication of when it will be in 
a position to provide a complete answer. This may be done orally." 

* "FIUs should consider establishing mechanisms in order to monitor 
request-related information, enabling them to detect new information 
they receive regarding transactions, STRs [suspicious transaction 
reports], etc., that are involved in previously received requests. Such 
a monitoring system would enable FIUs to inform former requesters of 
new and relevant material related to their prior request." 

FOOTNOTES 

[1] Among other functions, FinCEN is responsible for administering the 
Bank Secrecy Act, Pub. L. No. 91-508, 84 Stat. 1115 (1970) (codified as 
amended at 12 U.S.C. §§ 1951 et seq.), which is a record-keeping and 
reporting law designed to prevent financial institutions from being 
used as intermediaries for the transfer or deposit of money derived 
from criminal activity. See also 31 U.S.C. § 5301 et seq. 

[2] Uniting and Strengthening America by Providing Appropriate Tools 
Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001, 
Pub. L. No. 107-56, § 330, 115 Stat. 272, 320. 

[3] Codified as amended at 31 U.S.C. § 310. 

[4] FATF-style regional bodies represent nations in seven geographic 
areas, respectively, Asia/Pacific, Caribbean, Europe, Eurasia, South 
America, Eastern and Southern Africa, and Middle East and North Africa. 

[5] Codified as amended at 31 U.S.C. § 5318A. 

[6] The quotes indicate that the U.S. government has not officially 
recognized the "Turkish Republic of Northern Cyprus." 

[7] The most recent Egmont Group plenary meeting was held June 30 to 
July 1, 2005, in Washington, D.C. At the plenary meeting, the Egmont 
Group recognized 7 new members to its global network of FIUs, bringing 
the total membership to 101. 

[8] Pub. L. 91-508, 84 Stat. 1115 (1970). 

[9] In this context, a letter rogatory is a method of obtaining 
assistance from abroad in the absence of a treaty or executive 
agreement. Essentially, this device is a formal request from a court in 
one country to a court in another country to seek international 
judicial assistance in obtaining testimony or other evidence. 

[10] Testimony of Stuart Levey, Under Secretary, Office of Terrorism 
and Financial Intelligence, Department of the Treasury, at a hearing 
("Money Laundering and Terror Financing Issues in the Middle East"), 
before the Senate Committee on Banking, Housing, and Urban Affairs, 
July 13, 2005. 

[11] A primary purpose of Security Council Resolution 1617 was to 
reaffirm and strengthen international sanctions on Al-Qaida, the 
Taliban, and their associates. 

[12] Codified as amended at 31 U.S.C. § 5318A. 

[13] Department of State, Bureau for International Narcotics and Law 
Enforcement Affairs, International Narcotics Control Strategy Report, 
Volume II, Money Laundering and Financial Crimes (March 2006). 

[14] GAO, Terrorist Financing: Better Strategic Planning Needed to 
Coordinate U.S. Efforts to Deliver Counter-Terrorism Financing Training 
and Technical Assistance Abroad, GAO-06-19 (Washington, D.C.: Oct. 24, 
2005). 

[15] The Egmont Committee is composed of a chair, two co-vice chairs, 
the chairs of the Egmont Group's five working groups (information 
technology, legal, operational, training, and outreach), and regional 
representation from Africa, Asia, Europe, the Americas, and Oceania. 
The committee functions as the consultation and coordination mechanism 
for FIU heads and the five working groups. 

[16] International Monetary Fund, Legal Department, AML/CFT Standards 
and Reference Materials, April 2004. 

[17] At the time of the March 2004 report by IMF and the World Bank, 
the FATF recommendations were 40 plus 8. Later, in October 2004, FATF 
published a ninth special recommendation on terrorist financing (see 
app. II). 

[18] The common methodology reflects the principles of the FATF 
recommendations. See International Monetary Fund and World Bank, Joint 
Report on the Methodology for Assessing Compliance with the FATF 40 
Recommendations and the FATF 8 Special Recommendations--Supplementary 
Information (March 16, 2004). Also, appendix II of this report briefly 
discusses an updated version of the methodology--Methodology for 
Assessing Compliance with the FATF 40 Recommendations and the FATF 9 
Special Recommendations (updated as of February 2005). 

[19] Financial Action Task Force on Money Laundering, Annual Report 
2004-2005, June 10, 2005, p. 9. 

[20] Egmont Group, "Egmont Meetings at a Glance," www.egmontgroup.org 
(2006). 

[21] Statement of William J. Fox, Director, FinCEN, at a hearing 
("Counterterror Initiatives and Concerns in the Terror Finance 
Program") before the Senate Committee on Banking, Housing, and Urban 
Affairs, April 29, 2004. 

[22] Financial Crimes Enforcement Network, Strategic Plan, FY 2006- 
2008: Safeguarding the Financial System from the Abuse of Financial 
Crime (February 2005). 

[23] Department of the Treasury, Financial Crimes Enforcement Network, 
Fiscal Year 2006 Congressional Budget Submission (Feb. 7, 2005), p. 4. 

[24] Statement of Michael F. A. Morehart, Section Chief, Terrorist 
Financing Operations Section, Counterterrorism Division, FBI, at a 
hearing before the House Committee on Financial Services (May 26, 
2005). 

[25] The Treasury Forfeiture Fund is the receipt account for the 
deposit of nontax forfeitures made pursuant to laws enforced or 
administered by the Internal Revenue Service-Criminal Investigation and 
Department of Homeland Security components (including U.S. Immigration 
and Customs Enforcement, U.S. Customs and Border Protection, U.S. 
Secret Service, and U.S. Coast Guard). 

[26] Generally, before obtaining access to a federal computerized 
information system, a potential user must first be issued a digital 
certificate by a government-approved certificate authority. A digital 
certificate essentially is an electronic "credit card" that establishes 
a person's credentials when doing business or other transactions on the 
Web. The certificate contains the person's name, a serial number, 
expiration date, a copy of the certificate holder's public key (used 
for encrypting messages and digital signatures), and the digital 
signature of the certificate-issuing authority so that a recipient can 
verify that the certificate is real. FinCEN is the authority for 
issuing digital certificates for use of the Egmont Secure Web. 

[27] Financial Crimes Enforcement Network, Strategic Plan FY 2006 - 
2008, Safeguarding the Financial System from the Abuse of Financial 
Crime (February 2005, p. 22). 

[28] FinCEN's previous survey was conducted in September to October 
2003. 

[29] Uniting and Strengthening America by Providing Appropriate Tools 
Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001, 
Pub. L. No. 107-56, § 330, 115 Stat. 272, 320. 

[30] Codified as amended at 31 U.S.C. § 310. 

[31] FATF has issued "Forty Recommendations on Money Laundering" and 
"Nine Special Recommendations on Terrorist Financing." Collectively, 
FATF's "40 plus 9" recommendations are widely recognized as the 
international standards for combating money laundering and terrorist 
financing. 

[32] On June 9, 1995, representatives of various nations (including the 
United States) and international organizations met at the Egmont- 
Arenberg palace in Brussels, Belgium, to discuss ways to enhance mutual 
cooperation in combating the global problem of money laundering. A 
result was creation of the Egmont Group, whose members are the 
specialized anti-money-laundering organizations known as FIUs. 

[33] Codified as amended at 31 U.S.C. § 5318A. 

[34] The Egmont Committee is composed of a chair, two co-vice chairs, 
the chairs of the Egmont Group's five working groups, and regional 
representation from Africa, Asia, Europe, the Americas, and Oceania. 

[35] The common methodology reflects the principles of the FATF 
recommendations. See International Monetary Fund and World Bank, Joint 
Report on the Methodology for Assessing Compliance with the FATF 40 
Recommendations and the FATF 8 Special Recommendations-Supplementary 
Information (March 16, 2004). The common methodology was updated in 
2005--Methodology for Assessing Compliance with the FATF 40 
Recommendations and the FATF 9 Special Recommendations (updated as of 
February 2005). 

[36] The group of G7 nations--Canada, France, Germany, Italy, Japan, 
the United Kingdom, and the United States--has been expanded to include 
Russia. Annual G8 summits bring together the leaders of these nations-
-with participation of the European Union (represented by the President 
of the European Council and the President of the European Commission)-
-to discuss a broad-based agenda of international, economic, political, 
and social issues. 

[37] Copy available at www.fatf-gafi.org. 

[38] Another useful resource is a handbook prepared jointly by the 
International Monetary Fund and the World Bank, Financial Intelligence 
Units: An Overview (2004). 

[39] Egmont Group, Statement of Purpose of the Egmont Group of 
Financial Intelligence Units, www.egmontgroup.org (2006). 

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U.S. Government Accountability Office, 

441 G Street NW, Room 7149 

Washington, D.C. 20548: