Combating Transnational Organized Crime

On July 25, the White House hosted an event to launch the Strategy to Combat Transnational Organized Crime . This strategy seeks to build, balance, and integrate the tools of American power to combat transnational organized crime threats to national and international security. The strategy also seeks to disrupt and dismantle transnational illicit networks and converging threats – and to urge our foreign partners to do the same. 

The 19th annual Egmont Group Plenary included much discussion of global efforts to combat corruption. As stated in its press release , “In recent years the Egmont Group has also placed increased emphasis on the fight against corruption. This year’s plenary included further sessions devoted to combating corruption and asset recovery, as well as discussions on the impacts that corruption can have on efforts to establish new FIUs and to effectively carry out the FIU mission. The anti-corruption work of the World Bank, and more recently the FATF, has helped raise awareness of the intrinsic link between corruption and money laundering (e.g., where the proceeds from thefts of public funds are subsequently moved through the financial system). The G-20 also has identified fighting corruption among its current priorities. The Egmont Group of FIUs reaffirmed a commitment, including as specifically foreseen in the United Nations Conference Against Corruption, to fulfill their important role as part of each government’s anti-corruption work, in tracing and identifying possible illicit proceeds, and in facilitating and strengthening the international exchange of information in furtherance of anti-corruption efforts.” 

In February, the U.S. Department of the Treasury identified The Lebanese Canadian Bank SAL together with its subsidiaries (LCB) as a financial institution of primary money laundering concern  for the bank’s role in facilitating the money laundering activities of an international narcotics trafficking and money laundering network. FinCEN published a Notice of Proposed Rulemaking  seeking to impose special measures upon LCB. Currently, no final rule has been issued. Treasury is considering how the reported sale of LCB and the disposition of its assets and staff will inform the next steps in the Section 311 process.

The United Nations Office on Drugs and Crime released The Globalization of Crime: A Transnational Organized Crime Threat Assessment , which analyzed a range of key transnational crime threats, including human trafficking; migrant smuggling; the illicit heroin and cocaine trades; cybercrime; and maritime piracy and trafficking in environmental resources, firearms, and counterfeit goods. In 2011, the Egmont Group agreed to further pursue this initiative against transnational organized crime.

The International Mass-Marketing Fraud Working Group released a threat assessment on international mass-marketing fraud. The assessment was developed in collaboration with the Department of Justice, as well as law enforcement, regulatory, and consumer agencies in Australia, Belgium, Canada, EUROPOL, the Netherlands, Nigeria, and the United Kingdom, to provide governments and the public with a current assessment of the nature and scope of the threat that mass-marketing fraud poses around the world. FinCEN researched its data to identify the extent of SAR reporting relating to mass-marketing fraud. 

FinCEN Director Freis addressed a conference of the Committee on International Monetary Law of the International Law Association  (MOCOMILA) in Salamanca, Spain where he discussed fighting transnational crime through financial intelligence.

The United Nations Convention Against Transnational Organized Crime (Palermo Convention ) of 2000 adopted the Egmont Group’s definition of an FIU. It urged countries to combat money laundering and consider creating an FIU to serve as a central point for the collection, analysis, and dissemination of information regarding possible money laundering. (The Convention entered into force on September 29, 2003.)