convergence

Lindholm and Realuyo
and counterterrorism operations. International initiatives such as those undertaken by the
Financial Action Task Force have raised awareness of the detrimental effects of illicit financing
on international financial markets and promoted increased regulation and oversight to safeguard
the international financial system. Since illicit actors threaten all sectors of society, the
private sector must be aware of these threats and engage in combating transnational organized
crime and illicit networks. Through public-private sector partnerships, we can glean a better
understanding of financial innovation’s advantages and disadvantages and of how illicit actors
might be financing themselves. While illicit finance will never be fully eliminated, it is a key
enabler of illicit networks that must be met head-on through comprehensive and collaborative
strategies that engage a whole-of-nation approach.
Notes
1 Strategy to Combat Transnational Organized Crime: Addressing Converging Threats to National Security (Washington,
DC: The White House, July 2011), available at .
2 Ibid.
3 Treasury Department Web site, available at .
4 Financial Action Task Force Web site, available at .
5 Jean-François Thony, “Money Laundering and Terrorism Financing: An Overview,” Current Developments in
Monetary and Financial Law 3 (Washington, DC: International Monetary Fund Publications, 2002), available at
.
6 International Monetary Fund, Fact Sheet, “The IMF and the Fight Against Money Laundering and the Financing
of Terrorism,” August 31, 2011, available at .
7 d Global Relief Foundation v. Paul H. O’Neil et al., 207 F. Supp. 2 779, U.S. District Court, Northern District
of Illinois, Eastern Division, June 11, 2002.
8 U.S. v. Enaam Arnaout, Case No. 02CR892, U.S. District Court, Northern District of Illinois, Eastern
Division, April 2002.
9 “How Much Does a Million Dollars Weigh?” Fivecentnickel.com, available at .
10 Financial transparency reporting requires Currency and Monetary Instrument Reports, which obligate the
filer to declare if he or she is transporting $10,000 or more in cash or monetary instruments across the border.
11 Rohan Gunaratna, “The Evolution of Al Qaeda,” in Countering the Financing of Terrorism, ed. Thomas J.
Biersteker and Sue E. Eckert, 58–59 (New York: Routledge, 2008).
12 National Drug Intelligence Center (NDIC), National Drug Threat Assessment Report 2011 (Washington,
DC: Department of Justice, NDIC, 2011), 40, available at .
13 According to the Department of Justice, Al Barakaat operated a hybrid hawala in which its informal system
interconnected with the formal banking system. Because Al Barakaat also used financial institutions, law enforcement
was able to trace the transactions to Somalia by analyzing Suspicious Activity Reports generated by the banks
pursuant to their obligations under the 1970 Bank Secrecy Act [Pub. L. No. 91-508, 84 Stat. 1114 (1970) (codified
as amended in 12 U.S.C. §§ 1829(b), 1951–1959 (2000); 31 U.S.C. §§ 5311–5330 (2000)].
14 Douglas Farah, “A Bit More on Dawood Ibrahim and Why He Matters,” December 11, 2008, available at
.
15 NDIC, Report (2011), 40.
16 The Financial Action Task Force offers a useful demonstration of this process and related case studies, available
at .
17 Mercator Advisory Group, “Seventh Annual Prepaid Card Forecast,” available at .
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