convergence

Threat Finance
18 Per 2009 statistics, the unbanked make up 7.7 percent, or 9 million U.S households. This amounts to 17
million American adults. See “2009 FDIC Survey of Unbanked and Underbanked Households,” (December 2009),
available at .
19 Prepaid or “Stored Value” cards are not defined as “monetary instruments” under U.S. law and thus they
cannot be seized under requirements to declare currency upon crossing the U.S. border.
20 “Philadelphia/Camden High Intensity Drug Trafficking Area Drug Market Analysis 2009,” NDIC, February
2009, available at .
21 “Hackers Indicted in Widespread ATM Heist,” The Wall Street Journal, November 11, 2009, available at
.
22 Specifically to address these issues, and as ordered by Congress via the “Credit Card Accountability, Responsibility,
and Disclosure (CARD) Act of 2009,” a new rule by the Financial Crimes Enforcement Network
(FinCEN), an agency of the Treasury Department, will change how cards are issued, reloaded, and reported in the
United States; this rule also renamed stored-value cards or prepaid cards and related instruments as “prepaid access
products,” available at .
23 “FinCEN Issues Prepaid Access Final Rule Balancing the Needs of Law Enforcement and Industry,” July 26,
2011, available at .
24 “Financial Crimes Enforcement Network, Amendment to the Bank Secrecy Act Regulations—Definition
of ‘Monetary Instrument,’” October 11, 2011, available at .
25 Aaron Smith, “Smartphone Adoption and Usage,” Pew Research Center, July 11, 2011, available at .
26 Charles Golvin, “2009: Year of The Smartphone—Kinda,” Forrester, January 4, 2010, available at .
27 Juniper Research Limited, “mPay, mShop, mTransfer!” available at .
28 Juniper Networks Global Threat Center (GTC), “Malicious Mobile Threats Report 2010/2011,” May 10,
2011.
29 Christopher Carboni, “Thoughts on Malware for Mobile Devices—Part 2,” Internet Storm Center Diary,
SANS Technology Institute, July 12, 2010, available at .
30 Moneyslex virtual exchange, Web site, available at .
31 Bitcoin Web site, available at .
32 Paysafecard Web site, available at .
33 Department of Justice, Press Release, April 27, 2007, available at .
34 Stephanie Condon, “Judge spares E-Gold directors jail time,” Cnet.com, November 20, 2008, available at
.
35 Ibid.
36 Treasury Department, “Terrorist Finance Tracking Program,” Fact Sheet, August 2, 2010, available at .
37 Ibid.
38 Ibid.
39 Jo Becker, “Beirut Bank Seen as a Hub of Hezbollah’s Financing,” The New York Times, December 13, 2011.
40 Ibid.
41 Ibid.
42 Craig Whitlock, “Diverse Sources Fund Insurgency in Afghanistan,” The Washington Post, September 29, 2009.
43 Catherine Collins with Ashraf Ali, “Financing the Taliban: Tracing the Dollars Behind the Insurgencies in
Afghanistan and Pakistan,” New America Foundation, April 19, 2010, available at .
44 Ibid.
45 Treasury Department, “Fact Sheet: Combating the Financing of Terrorism, Disrupting Terrorism at Its
Core,” available at .
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