Information Technologies for the Control of Money Laundering
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Information Technologies for the Control of Money Laundering September 1995 OTA-ITC-630 GPO stock #052-003-01436-0 Recommended Citation: U.S. Congress, Office of Technology Assessment, Information Technologies for Control of Money Laundering, OTA-ITC-630 (Washington, DC: U.S. Government Printing Office, September 1995). oreword he key to control of international crime may depend on cutting off the flow of illegal profits to criminal organizations. It is esti- mated that $300 billion of “dirty money” may be laundered each year, its origin and ownership obscured as it passes through fi- nancial institutions and across national boundaries in an effort to hide and protect it from law enforcement authorities. Criminal organizations, like legitimate businesses, enjoy a swift and nearly risk-free conduit for moving money between countries—wire transfer systems. Illicit wire transfers are easily hidden among the 700,000 mostly legitimate wire transfers that occur daily in the United States, moving well over $2 trillion. OTA was asked by the Permanent Subcommittee on Investigations of the Senate Committee on Governmental Affairs to assess the proposed use of techniques derived from artificial intelligence research to monitor wire transfer traffic and recognize suspicious transfers. Fully automated computer screening of wire transfers was found to be virtually impossi- ble for technical reasons. However, OTA analysts developed and eval- uated a number of alternative configurations of technology that, com- bined with certain legal and institutional innovations, could greatly enhance the capability of law enforcement agencies to detect and prose- cute money launders seeking to exploit U.S. financial institutions and wire transfer systems. Although all of these proposed configurations en- tail some economic and social costs, including possible diminution of financial privacy, strategies are suggested for minimizing these costs while enhancing the potential usefulness of information technology in control of money laundering. ROGER C. HERDMAN Director iii dvisory Panel Eloy Garcia Priscilla Regan John Stern Assistant Special Agent in Charge Assistant Professor The Francis M. Hipp Building Operational Commander Department of Public & College of Business International Affairs Administration W. Douglas Johnson George Mason University University of South Carolina Assistant Director Division of Banking Joel Reidenberg David Vogt Office of the Comptroller Associate Professor of Law Assistant Director Fordham University School of Financial Crimes Enforcement Robert MacAllister Law Network (FinCEN) Vice President & Senior Associate Counsel Robert Serino Sarah Welling The Chase Manhattan Bank, N.A. Deputy Chief Counsel Professor of Law Office of the Comptroller of the College of Law Bruce Porter Currency University of Kentucky Associate Professor of Computer U.S. Department of the Treasury Science University of Texas at Austin Note: OTA appreciates and is grateful for the valuable assistance and thoughtful critiques provided by the advisory panel members. The panel does not, however, necessarily approve, disapprove, or endorse this report. OTA assumes full responsibility for the report and the accuracy of its contents. iv roject Staff Peter D. Blair Vary Coates, ADMINISTRATIVE STAFF Assistant Director, OTA Project Director Liz Emanuel Industry, Commerce, and Office Administrator International Security Division David Jensen Analyst Karry Fornshill Andrew W. Wyckoff Secretary Program Director Steven Bonorris Industry, Telecommunications, Analyst Diane Jackson and Commerce Program Administrative Secretary Karolyn St. Clair PC Specialist PUBLISHING STAFF Mary Lou Higgs Manager, Publishing Services Chip Moore Production Editor Cheryl Davis Electronic Publishing Specialist Chris Onrubia Senior Graphic Designer v eviewers and Contributors Joseph Alexander Fred Cate John Forbes New York Clearing House University of Indiana School of Office of the Special Agent in Law Charge Alfredo Arellano U.S. Customs Service Popular Bank of Florida Michael Corcoran Citibank, N.A. Areg Gharakhanian F. Robert Armentrout National Command and Control Internal Revenue Service Frank Curren Systems Criminal Investigations Division Treasury Management The MITRE Corporation Association Jim Atchley Joyce Goletz Atchley Systems, Inc. Michael D’Ambrosio Chase Manhattan Bank, N.A. Citibank, N.A. Jack Blum Theodore Greenberg Lobel, Novins, Lamont & Frug Kawika Daguio Department of Justice American Bankers Association Al Brandenstein Edmond Gueguen CTAC Randall Davis Citibank, N.A. Office of National Drug Control Massachusetts Institute of Policy Technology Richard Harms Vincent Brannigan Jim Dear Michael Harrington University of Maryland, College The MITRE Corporation The MITRE Corporation Park College of Engineering Michael Eid Patrick Harrison FinCEN Naval Research Laboratory Gail Brett Fedwire John Falvey Rayburn Hesse Division of Reserve Bank Drug Enforcement Agency Department of State Operations and Payment Systems Carl Felsenfeld Michael Hodge Board of Governors of the Federal Fordham University National Association of Attorneys Reserve System School of Law General Brian Bruh Richard Fischer Cameron Holmes Morrison and Foerster Attorney General’s Office John Byrne State of Arizona American Bankers Association vi Sara Jane Hughes Greg Meachem Neil Robinson School of Law Federal Bureau of Investigation Office of the Comptroller of the Indiana University Currency Paul Morawski Division of Enforcement and Charles Intriago The MITRE Corporation Compliance Alert Publications Partners Artificial Intelligence Technical U.S. Department of the Treasury Center Douglas Jeffrey Louise Roseman SWIFT Steve Mott Division of Reserve Bank Cognitive Systems, Inc. Operations and Payment Carl Jensen Systems Racketeering Records Analysis Howard Mulholland Board of Governors of the Federal Unit Internal Revenue Service Reserve System FBI Labs Joseph Myers Seymour Rosen Jeff Jordan Office of Legal Counsel Citibank, N.A. Office of Enforcement FinCEN U.S. Customs Service Michael Rosenberg Jose Ruben Pena Office of Strategic Analysis Graham Jordi U.S. GAO Financial Crimes Enforcement Network Thomas Judd Kevin Perkins U.S. Department of the Treasury National Association of Attorneys Federal Bureau of Investigation General Jeff Ross Gregory Piatetsky-Shapiro Money Laundering Section Louis Kallas GTE Laboratories, MS-45 Department of Justice Office of National Drug Congrol Polisy Graham Pinner Susan Sandler Australian Transaction Reports Citibank, N.A. Clifford Karchmer and Analysis Centre Police Executive Research Forum (AUSTRAC) Ernesto Savona National Institute of Justice Stephen Kroll Zelford Platt University of Trento Financial Crimes Enforcement Washington Metropolitan Police Network (FinCEN) Department Dan Schutzer Citibank Robert MacAllister Gregory Polvere The Chase Manhattan Bank, N.A. Internal Revenue Service Ted Senator Criminal Investigations Division Financial Crimes Enforcement Gary Marx Network (FinCEN) Department of Sociology Thomas Poplawski U.S. Department of the Treasury University of Colorado The Chase Manhatten Bank, N.A. Evangelos Simoudis John McDowell Ronald Rice IBM Research Comptroller of the Currency Financial Crimes Enforcement Almaden ResearchCenter U.S. Department of the Treasury Network U.S. Department of the Treasury Walter McGovern The Chase Manhatten Bank, N.A. vii Richard Small Dan Stepano Roger Weiner Division of Banking Supervision Office of the Comptroller of the Financial Crimes Enforcement and Regulation Currency (FinCEN) Board of Governors of the Federal U.S. Department of the Treasury Reserve System George Thomas CHIPS, New York Clearing House Alan Westin Columbia University Steven Smith George Trubow Thinking Machines Corporation John Marshall Law School Mark Westling The MITRE Corporation David Sobel Viveca Ware Artificial Intelligence Center EPIC Independent Bankers Association of America Christopher Westphal Malcolm Sparrow John F. Kennedy School of Robert Weber Steven Wisotsky Government Office of Enforcement School of Law Harvard University U.S. Customs Service Nova University viii orkshop Participants The Use of Wire Transfers For Privacy and Confidentiality in Dan Stepano Money Laundering Payment Systems Assistant Director, Enforcement June 21, 1994 September 28, 1994 and Compliance Division Office of the Comptroller of the John Byrne Vincent Brannigan Currency General Counsel University of Maryland, College Washington, DC American Bankers Association Park College of Engineering George Trubow Jim Dear College Park, MD Director, Center for Informatics The MITRE Corporation Law John Byrne John Marshall Law School Carl Felsenfeld General Counsel Chicago, IL Professor American Bankers Association Fordham University School of Washington, DC Steven Wisotsky Law School of Law Frank Curren Nova University Sara Jane Hughes Director, Government Relations Fort Lauderdale, FL Professor and Standards Indiana University School of Law Treasury Management Information Technologies for Association Analyzing Wire Transfers Charles Intriago Bethesda, MD September 29, 1994 Publisher Alert Publications Partners Stephen Kroll Joseph Collins Legal Counsel Naval Reseach Laboratory Jeff Jordan FinCEN Washington, DC Office of Enforcement Vienna, VA U.S. Customs Service Patrick Harrison Vicki Roberts Naval Research Laboratory Clifford Karchmer Treasurer Washington, DC Associate Director Centex Corporation Joseph Kielman Police Executive Research Forum Dallas, TX Chief Scientist