Some money laundering placement methods specifically attempt to evade Bank Secrecy Act requirements. These include:



During the layering phase of money laundering, criminals often take advantage of legitimate financial mechanisms in attempts to hide the source of their funds. A few of the many mechanisms that may be misused during layering are currency exchanges, wire transmitting services, prepaid cards that offer global access to cash via automated teller machines and goods at point of sale, internet-based e-value systems, casino services, and domestic shell corporations lacking real assets and business activity that are set up to hold and move illicit funds.

Money launderers may also attempt to mix "dirty" funds with clean. For example, criminals may take over or invest in businesses that generate large cash proceeds and mix illicit funds with those of the legitimate business. In addition, money launderers may take part in criminal activity specifically designed to hide the proceeds of other criminal acts. For instance, they may set up fraudulent invoicing schemes that over- or undervalue goods being traded.

Criminal organizations and terrorists sometimes employ the services of the same professionals, including personal services providers such as accountants and lawyers, to help disguise their funds.

Terrorist operatives may attempt to smuggle cash - or precious metals, stones, or jewels - across borders or may use couriers to attempt to transport these items. Likewise, terrorists may rely on currency exchangers to transfer funds, especially in countries where cash is typically used to settle accounts.

Terrorists have used informal value transfer systems, such as those known as “hawala” or "hundi." These systems use trusted networks of people who move funds and settle accounts with little or no documentation. Such systems are prevalent throughout Asia and the Middle East as well as within expatriate communities in other regions. In the United States, money transmitters involved in informal value transfer systems are required, under the Bank Secrecy Act, to register as money services businesses, develop anti-money laundering programs, and report suspicious activity.

Terrorists also use traditional financial institutions and mechanisms to move their funds. The 9/11 Commission found that Al Qaeda funded the hijackers in the United States through wire transfers from overseas, by physically moving cash and traveler's checks into the country, and by accessing funds held in foreign accounts through debit or credit cards. Suspicious Activity Reports filed under the Bank Secrecy Act are a valuable source of information about potential terrorist financing activity.

Enforcement Network provides authorized law enforcement agencies controlled access to reported Bank Secrecy Act data so that investigators of these crimes can "follow the money." We also identify and refer to appropriate authorities potential evidence of financial crimes, provide analytical support for cases with a significant financial component, and assist in managing cases with a large number of subjects and/or large numbers of relevant Bank Secrecy Act reports.