CAPITALISM'S ACHILLES HEEL Dirty Money and How to

Notes 405
“There’s no question that there’s more money laundering going
through the financial system of the United States than any other
country of the world.” Quoted in John Burgess, “15 Nations Cited as
Havens For Possible Money Crimes,” Washington Post, June 23,
2000.
17. Interviews by the author with a Swiss central banker, Zurich, Switzerland,
and a German private banker, Frankfurt, Germany, respectively,
not for attribution.
18. Suspicious Activity Reports (SARs) had been received earlier by the Federal
Reserve Board and the Comptroller of the Currency, but Annunzio-
Wylie strengthened reporting procedures and required banks to set up
in-house anti–money laundering programs. FinCEN became the repository
and analyst of SARs and currency transaction reports (CTRs)—
more than 10 million a year. Apparently, only a few hundred reports
annually are actively pursued. Furthermore, FinCEN has proven slow to
complete investigations referred to it by the Federal Reserve Board and
the Comptroller of the Currency and likewise slow to spread its reach to
nonbank money-service businesses.
19. Joseph Kahn and Kurt Eichenwald, “House and Senate Leaders Clash
on Banking Measure,” New York Times, October 17, 2001.
20. Kathleen Day, “Banks Seek to Alter Bill,” Washington Post, October 11,
2001.
21. Lucy Komisar, “Shell Game: Citibank Attacks Money-laundering Regulations,”
In These Times, November 12, 2001, 5.
22. Raymond W. Baker, letter to the editor, Foreign Affairs 80, no. 6
(November–December 2001): 198–199.
23. David Aufhauser, interview by the author, Washington, D.C., March 2,
2004.
24. David Aufhauser, at a conference entitled “Dirty Money and National
Security,” jointly sponsored by Center for International Policy, Caux
Round Table and the Brookings Institution, September 10, 2003,
Washington, D.C.
25. Mariano-Florentino Cuéllar, “The Tenuous Relationship between the
Fight against Money Laundering and the Disruption of Criminal Finance,”
Stanford Public Law and Legal Theory working paper no. 47,
September 2003, 414.
26. The U.S. Customs Service also launched “Operation Oasis” to interdict