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​ • Money Launderers have to be Stupid or Unlucky to be Caught • Testimony before the Senate Judiciary Committee on AML Reform • Illicit Tobacco and the ATF • Our AML Efforts Are A Percentage Point Away from Total Failure • China Inc. February 28, 2018 Money Launderers have to be Stupid or Unlucky to be Caught These days, a money launderer has to be either very stupid or very unlucky to get caught. In fact, data suggests the U.S. Government’s efforts to enforce America’s money-laundering laws fail 99.9 percent of the time. As financial crime expert “Total failure is just a decimal point away.” All of which makes it all the more surprising that Paul Manafort and Rick Gates, President Trump’s former campaign chairman and his deputy, got busted last week. Special Counsel Robert Muller accused Manafort, with Gates’s help, of laundering approximately $30 million—an effort that, according to the indictment, began years ago but continued through their time on the Trump presidential campaign.

The charges do not involve Mr. Trump or his campaign. Had Trump lost the election, Manafort and Gates might have gotten away with their alleged crimes. But now they’re caught up in Mueller’s investigation of Russian meddling in the 2016 election, and they have the misfortune of being pursued by skilled and motivated prosecutors with deep expertise in financial crimes and almost unlimited resources.

Mueller’s team includes Andrew Weissmann, who no less than former White House strategist Steve Bannon has reportedly dubbed “the LeBron James of money-laundering investigations.” It’s tempting to think of money laundering as a victimless crime. Who cares if Paul Manafort was able to buy himself some fancy rugs a nice brownstone in Brooklyn? So what if Rick Gates bought himself a nice house and sent his kids to private schools? That view couldn’t be more wrong. I spent 26 years in the U.S.

Government, much of it fighting the scourge of money laundering. It’s a crime that sustains devastating drug epidemics—opioids, methamphetamines, cocaine. Gang violence, fraud in government programs, corruption, internet scams, identity theft and so many other crimes affect our daily lives. Terrorism—made possible in part by money laundering—threatens our national security.

Many of the ills we face come back to money. And money laundering—the hiding or disguising of the proceeds of any form of criminal activity—is the essential component of transnational crime. Without the ability to move money around, pay their foot soldiers and profit from their illegal activities, criminal networks wither and die. It shouldn’t take a national political scandal to crack down on their misdeeds.

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*** How big is the world’s money-laundering crisis? It’s hard to say for sure, because precise data doesn’t exist. The IMF believes money laundering makes up about 2 to 5 percent of the world’s GDP, or approximately $1.5 trillion to $3.7 trillion in 2015.

Similarly, the Office on Drugs and Crime found criminal proceeds in 2009 amounted to 3.6 percent of global GDP or roughly $2.1 trillion. Using these guesstimates, the amount of international money laundering today is approximately the same as the annual U.S. Federal budget. Depending on what is included in the count, the reality is much higher. For example, there is an international movement to recognize tax evasion as a predicate offense to charge money laundering. The that between $21 and $32 trillion is hiding in more than 80 international tax havens. The scope of the problem is breathtaking, as the release of the “Panama” and “Paradise” papers showed.