Also known as black money, there seems to be a diversion from where the real focus should lie. The reason the word “laundered” is used is because the money is dirty at the beginning and is cleaned in order to allow the holder of the funds to use it in everyday affairs. Most likely started as a descriptive title for drug money, it is now used everywhere and sometimes where it should not be used.
Having served in Afghanistan for two years at Task Force 2010, as the lead forensic accountant I saw up close the start of dirty money and subsequently how it was moved around the world, using banks, hawalas and planes. That is money laundering.
I also led the investigation of the financial sanctions placed on Charles Taylor and his associates. That is also a clear example of dirty money, as he was convicted of war crimes.
Where the focus of U.S. Government and the media goes astray is the use of the words for anything that involves the movement of large amounts of money around the world. It is puzzling to hear the use of such terms for Paul Manafort when the only basis is large sums of money, foreign clients and foreign banks. If, that was the criteria then most Fortune 100 companies and lobbying firms representing foreign governments should be investigated as well.
The focus on money laundering needs to get back to the original theme of attacking the source of the black money. That is the dirtiest part. Yes, the recipients and money movers are just as guilty, but the illicit chain of commerce must be proven first. The law includes required evidence that talks about “proceeds of the crime”. First, state the crime and then follow the money. It will all come together nicely.
The money movers are critical as Al Capone witnessed. These movers and shakers can be banks, very large banks, as seen by recent billion dollar settlements by Commerzbank AG, Deutsche Bank, UBS, HSBC and others. But the funds were dirty as they entered the banking circles.
I suggest a refocus on black money, the banks, hawalas and money movers. The amounts will be billions of dollars and as once a tactic by our most famous General, George Washington, if you bankrupt the enemy you will win the war.
Thomas Creal, former U.N. Panel Expert and Lead Forensic Accountant for Task Force 2010.
SOURCE: Thomas Creal
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