The Changing Face of Money Laundering


According to Black’s Law Dictionary, the term “money laundering” is defined as “the act of transferring illegally obtained money through legitimate people or accounts so that its original source cannot be traced”.    This means that typical money laundering schemes function to make money that comes from Source A to look like it comes from Source B.

RECENT HISTORICAL CONTEXT  (see Saviano, Robert.  “Where the Mob Keeps its Money”.  The New York Times. 25 August 2012.) Background information not assigned.

For those who money launder, teaming up with a bank is the most effective way to propagate the scheme because both parties benefit.  The period of time surrounding the Great Recession brought this relationship to new heights.  In In 2010, the American bank, Wachovia (now Wells Fargo) agreed to pay $160 million in fines and penalties for tolerating laundering occurring between 2004 and 2007 which served to finance Mexican drug cartels.  Wachovia was not alone; other institutions such as Barclays and ING reached settlements with regulators after they admitted to transactions with disreputable countries like Cuba and Iran.  The United Nations estimated that, in 2009, $1.6 million was laundered globally.


In the midst of the Great Recession and continuing to this day, there has been a political movement towards regulating financial institutions in an effort to curb some of the behavior described above and the some of the recklessness that brought the economy to its knees.  With the being said, one would hope that the days of banks turning a blind eye to criminals and their illegal laundering schemes are numbered.

This seems like a fanciful argument because it is.  When there is a will, there is a way.  Our government functions in such a way that criminals are able evolve their conduct quicker than the law can address it.  With technology moving at a screaming pace, this principle is only exaggerated further. Criminals, though brazen, are not necessarily obtuse.  So while stricter regulations on banks may hinder the traditional role banks play in money laundering systems, the criminals will adapt and move their enterprises to new forums-ones that are outside the scope of public knowledge and ahead of the law-to a new kinds of banks.

The internet provides criminals a convenient medium to conduct their affairs.  Virtual currency schemes are something like the wild-west.   The territory is uncharted and the limited law that exists is untested.   World wide-access to the internet is increasing, meaning more people in more places have access to virtual currency systems.  Often times, the systems transcend national boundaries and currency-areas, thereby making for an environment which is very difficult to govern.





Liberty Reserve is (or was) one of the preeminent virtual currencies.  It is believed to have had a million or more users throughout the world, with at least 200,000 in the United States.  Those 1 million users have executed in excess of 12 million transactions annually.   Those transactions had a combined value of $1.4 billion annually.  From 2006 to May of 2013, Liberty Reserve processed somewhere in the neighborhood of 55 million separate financial transactions.

That all came to end in May of 2013 when and four other domain names were seized by American federal authorities.  The authorities allege in a 27 page indictment t that virtually all of the business generated by Liberty Reserve derived from suspected criminal activity:  “…LIBERTY RESERVE has emerged as one of the principal means by which cyber-criminals around the world distribute, store, and launder the proceeds of their illegal activity. Indeed, LIBERTY RESERVE has become a financial hub of the cyber-crime world, facilitating a broad range of online criminal activity, including credit card fraud, identity theft, investment fraud, computer hacking, child pornography, and narcotics trafficking…LIBERTY RESERVE…is believed to have laundered more than $6 billion in criminal proceeds.”

Deception is at the core of the money laundering operation.  To that end, it is inherently beneficial to remain anonymous as illicit transactions are made.

The first step in using Liberty Reserve was to make an account with the website.  This should come as no shocker, as we are all familiar with that process.  Like most account set-ups, basic identifying information was needed, such as name, address, DOB, etc.  But the process deviated from the normal protocol in one important way-the identifying information did not need to be validated (in normal settings, this is often done by filing a credit card).  Thus, users could establish accounts with anonymous identities.  How convenient!

Having established an account, the user was then free to transact with any other user on Liberty Reserve.  Liberty Reserve would charge a 1% fee every time a user transferred LR to another user through the Liberty Reserve system.  The system that was in place was such that tracing even a basic transaction was difficult.  But wait, there is more!  As the indictment explains, “For a fee of 75 cents per transaction, a user could hide his own Liberty Reserve Account number when transferring funds, effectively making the transfer  completely untraceable, even with Liberty reserve’s already opaque system.”  In this sense, Liberty Reserve made illicit exchanges a premium service which offered the company higher profit margins.  But wait, there is even more!  In the words of the indictment, “To add an additional layer of anonymity, LIBERTY RESERVE did not permit users to fund their accounts by transferring money to LIBERTY RESERVE directly, such as by issuing a credit card payment or wire transfer to LIBERTY RESERVE. Nor could LIBERTY RESERVE users withdraw funds from their accounts directly, such as through an ATM withdrawal. Instead, LIBERTY RESERVE users were required to make any deposits or withdrawals through the use of third-party “exchangers,” thus enabling LIBERTY RESERVE to avoid collecting any information about its users through banking transactions or other activity that would leave a centralized financial paper trail.”


31 U.S.C. 310 establishes the Financial Crimes Enforcement Network (FinCen) as  bureau of the United States Department of the Treasury.  Among its responsibilities are to determine emerging trends and methods in money laundering and other financial crimes and to serve as the Financial Intelligence Unit of the United Sates.

The “Bank Secrecy Act” was passed by Congress in 1970.  It is actually the legislative framework of the Currency and Foreign Transactions Reporting Act of 1970 and sometimes referred to as the “anti-money laundering law”.  The Bank Secrecy Act compels U.S. financial institutions to take part in the prevention on various financial crimes, including money laundering.  To this end, it requires that financial institutions take certain steps to maintain transparency and flag behavior that seems suspicious.  Among these obligations are to “…detect and prevent money laundering. Specifically, the act requires financial institutions to keep records of cash purchases of negotiable instruments, file reports of cash transactions exceeding $10,000 (daily aggregate amount), and to report suspicious activity that might signify money laundering, tax evasion, or other criminal activities.”  (see

Several acts (found in Title III of the USA Patriot Act of 2001) have been enacted to amend the original Bank Secrecy Act.  In fact, it was these provisions of the Patriot Act that were used by federal officials to freeze Liberty Reserve out of the American Financial System.  Because Liberty Reserve is an “Administrator” according to FinCEN, ( a person engaged as a business in issuing (putting into circulation) a virtual currency, and who has the authority to redeem (to withdraw from circulation) such virtual currency), it is a money services business (MSB) and therefore  Liberty Reserve is subject to MSB registration, reporting, and  recordkeeping regulations .

According to Fact Sheet released by the U.S. Treasury Department Office of Public Affairs dated May 28, 2013,

“Section 311 of the USA PATRIOT Act (Section 311) grants the Secretary of the Treasury the authority, upon finding that reasonable grounds exist for concluding that a foreign jurisdiction, foreign financial institution, class of transaction, or type of account is of “primary money laundering concern,” to require domestic financial institutions and financial agencies (e.g., banks) to take certain “special measures” against the entity identified as a primary money laundering concern. This authority provides the Secretary with a range of options that can be adapted to protect the U.S. financial system from specific money laundering and terrorist financing risks. The Secretary has delegated implementation of Section 311 to the Director of the Financial Crimes Enforcement Network (“FinCEN”)…Once the Director of FinCEN determines that a foreign financial institution is of “primary money laundering concern,” the Director has the authority to require domestic financial institutions and financial agencies to take certain special measures against the entity determined to be a primary money laundering concern. These special measures range from requiring U.S. financial institutions to conduct additional due diligence and pay special attention to particular account transactions to prohibiting the opening or maintenance of any correspondent or payable-through accounts.”  See

On May 28, 2013, the Press Center of the Department of the Treasury issued another press release that explained that “ The U.S. Department of the Treasury today named Liberty Reserve S.A. as a financial institution of primary money laundering concern under Section 311 of the USA PATRIOT Act (Section 311).   Liberty Reserve – a web-based money transfer system or “virtual currency” – is specifically designed and frequently used to facilitate money laundering in cyber space.  This is the first use of Section 311 authorities by Treasury against a virtual currency provider.”  See

18 U.S.C § 1956 establishes money laundering as a federal crime.  Those indicted in the Liberty reserve case above are alleged to have violated 18 U.S.C. §1956 (a)(1)(B)(i) and  (a)(2)(B)(i), which are provided below.[1]

It should be noted that the Liberty Reserve indictment contained another count-Conspiracy to Operate Unlicensed Money Transmitting Business under 18 U.S.C § 1960.



In the world of virtual currency schemes, The Department of the Treasury Financial Crimes Enforcement Network (FinCen) has said that there are three main players in the virtual currency context: users, administrators, and exchangers.  FinCen defines an exchanger as “a person engaged as a business in the exchange of virtual currency for real currency, funds, or other currency.  Whereas the above discussion of Liberty Reserve dealt in part with Liberty Reserve as an administrator, Mt., Gox is an exchanger.

Mt. Gox is the world’s largest bitcoin exchange; it handles about 63 percent of all Bitcoin purchases.  Mt. Gox is being investigated by the Department of Homeland Security (DHS) in connection with Dwolla, a key mobile payments account associated with Mt. Gox, for allegedly violating federal laws related to money exchanges and money transfers.

The Department of Homeland Security (DHS) has taken the lead role in investigating Mt. Gox and Mutum Sigillum, a subsidiary of Mt. Gox.  A confidential informant played a key role in the investigation.  The informant created accounts with Mt. Gox. and Dwolla, bought Bitcoins, then changed them back into dollars.  That is a process of currency exchange, which the President and CEO of Mt. Gox,Mark Karpeles, specifically denied he was getting into when he entered into a relationship with Wells Fargo Bank, as explained by the following excerpt from the warrant application:

“As part of the account opening process, Wells Fargo required Karpeles and Mutum Sigillum LLC to complete a “Money Services Business (MSB) Accounts, Identification of an MSB Customer” form. That document was completed on May 20, 2011 and identified Mutum Sigillum LLC as a business not engaged in money services. The application asks several questions; to include, “Do you deal in or exchange currency for your customer?” and “Does your business accept funds from customers and send the funds based on customers’ instructions (Money Transmitter)?” Karpeles answered these questions “no,” indicating that Mutum Sigillum LLC does not deal in or exchange money, and that it does not send funds based on customer instructions.”

Mt. Gox is alleged to have violated 31 USC §5330 because it is operating as a money transmitting businesses without registering with FinCEN.  DHS also alleges in a seizure warrant application that there is probable cause to allege that Mt. Gox has violated 18 U.S.C. §1960.  The statutes are set forth below.[2]






[1] (a)

(1) Whoever, knowing that the property involved in a financial transaction represents the proceeds of some form of unlawful activity, conducts or attempts to conduct such a financial transaction which in fact involves the proceeds of specified unlawful activity—

(B) knowing that the transaction is designed in whole or in part—

(i) to conceal or disguise the nature, the location, the source, the ownership, or the control of the proceeds of specified unlawful activity;

shall be sentenced to a fine of not more than $500,000 or twice the value of the property involved in the transaction, whichever is greater, or imprisonment for not more than twenty years, or both. For purposes of this paragraph, a financial transaction shall be considered to be one involving the proceeds of specified unlawful activity if it is part of a set of parallel or dependent transactions, any one of which involves the proceeds of specified unlawful activity, and all of which are part of a single plan or arrangement.


(2) Whoever transports, transmits, or transfers, or attempts to transport, transmit, or transfer a monetary instrument or funds from a place in the United States to or through a place outside the United States or to a place in the United States from or through a place outside the United States—

(B) knowing that the monetary instrument or funds involved in the transportation, transmission, or transfer represent the proceeds of some form of unlawful activity and knowing that such transportation, transmission, or transfer is designed in whole or in part—

(i) to conceal or disguise the nature, the location, the source, the ownership, or the control of the proceeds of specified unlawful activity.

shall be sentenced to a fine of not more than $500,000 or twice the value of the property involved in the transaction, whichever is greater, or imprisonment for not more than twenty years, or both. For purposes of this paragraph, a financial transaction shall be considered to be one involving the proceeds of specified unlawful activity if it is part of a set of parallel or dependent transactions, any one of which involves the proceeds of specified unlawful activity, and all of which are part of a single plan or arrangement.


[2] 31 USC § 5330 – Registration of money transmitting businesses

(a) Registration With Secretary of the Treasury Required.—

(1) In general.— Any person who owns or controls a money transmitting business shall register the business (whether or not the business is licensed as a money transmitting business in any State) with the Secretary of the Treasury not later than the end of the 180-day period beginning on the later of—

(A) the date of enactment of the Money Laundering Suppression Act of 1994; or

(B) the date on which the business is established.

(2) Form and manner of registration.— Subject to the requirements of subsection (b), the Secretary of the Treasury shall prescribe, by regulation, the form and manner for registering a money transmitting business pursuant to paragraph (1).

(3) Businesses remain subject to state law.— This section shall not be construed as superseding any requirement of State law relating to money transmitting businesses operating in such State.

(4) False and incomplete information.— The filing of false or materially incomplete information in connection with the registration of a money transmitting business shall be considered as a failure to comply with the requirements of this subchapter.

(b) Contents of Registration.— The registration of a money transmitting business under subsection (a) shall include the following information:

(1) The name and location of the business.

(2) The name and address of each person who—

(A) owns or controls the business;

(B) is a director or officer of the business; or

(C) otherwise participates in the conduct of the affairs of the business.

(3) The name and address of any depository institution at which the business maintains a transaction account (as defined in section 19(b)(1)(C) of the Federal Reserve Act).

(4) An estimate of the volume of business in the coming year (which shall be reported annually to the Secretary).

(5) Such other information as the Secretary of the Treasury may require.

(c) Agents of Money Transmitting Businesses.—

(1) Maintenance of lists of agents of money transmitting businesses.—Pursuant to regulations which the Secretary of the Treasury shall prescribe, each money transmitting business shall—

(A) maintain a list containing the names and addresses of all persons authorized to act as an agent for such business in connection with activities described in subsection (d)(1)(A) and such other information about such agents as the Secretary may require; and

(B) make the list and other information available on request to any appropriate law enforcement agency.

(2) Treatment of agent as money transmitting business.— The Secretary of the Treasury shall prescribe regulations establishing, on the basis of such criteria as the Secretary determines to be appropriate, a threshold point for treating an agent of a money transmitting business as a money transmitting business for purposes of this section.

(d) Definitions.— For purposes of this section, the following definitions shall apply:

(1) Money transmitting business.— The term “money transmitting business” means any business other than the United States Postal Service which—

(A) provides check cashing, currency exchange, or money transmitting or remittance services, or issues or redeems money orders, travelers’ checks, and other similar instruments or any other person who engages as a business in the transmission of funds, including any person who engages as a business in an informal money transfer system or any network of people who engage as a business in facilitating the transfer of money domestically or internationally outside of the conventional financial institutions system;;  [1]

(B) is required to file reports under section 5313; and

(C) is not a depository institution (as defined in section 5313 (g)).

(2) Money transmitting service.— The term “money transmitting service” includes accepting currency or funds denominated in the currency of any country and transmitting the currency or funds, or the value of the currency or funds, by any means through a financial agency or institution, a Federal reserve bank or other facility of the Board of Governors of the Federal Reserve System, or an electronic funds transfer network.

(e) Civil Penalty for Failure To Comply With Registration Requirements.—

(1) In general.— Any person who fails to comply with any requirement of this section or any regulation prescribed under this section shall be liable to the United States for a civil penalty of $5,000 for each such violation.

(2) Continuing violation.— Each day a violation described in paragraph (1) continues shall constitute a separate violation for purposes of such paragraph.

(3) Assessments.— Any penalty imposed under this subsection shall be assessed and collected by the Secretary of the Treasury in the manner provided in section 5321 and any such assessment shall be subject to the provisions of such section.


18 USC § 1960 – Prohibition of unlicensed money transmitting businesses

(a) Whoever knowingly conducts, controls, manages, supervises, directs, or owns all or part of an unlicensed money transmitting business, shall be fined in accordance with this title or imprisoned not more than 5 years, or both.

(b) As used in this section—

(1) the term “unlicensed money transmitting business” means a money transmitting business which affects interstate or foreign commerce in any manner or degree and—

(A) is operated without an appropriate money transmitting license in a State where such operation is punishable as a misdemeanor or a felony under State law, whether or not the defendant knew that the operation was required to be licensed or that the operation was so punishable;

(B) fails to comply with the money transmitting business registration requirements under section 5330 of title 31, United States Code, or regulations prescribed under such section; or

(C) otherwise involves the transportation or transmission of funds that are known to the defendant to have been derived from a criminal offense or are intended to be used to promote or support unlawful activity;

(2) the term “money transmitting” includes transferring funds on behalf of the public by any and all means including but not limited to transfers within this country or to locations abroad by wire, check, draft, facsimile, or courier; and

(3) the term “State” means any State of the United States, the District of Columbia, the Northern Mariana Islands, and any commonwealth, territory, or possession of the United States.




~ by mjmilazzo on September 22, 2013.

12 Responses to “The Changing Face of Money Laundering”

  1. I think there is an obvious need for regulation of virtual currency. With Bitcoins currently trading at $130/1 Bitcoin, it is ripe for all types of money laundering schemes and illegal activity. The primary driver of the Bitcoin exchange rate is the news and speculation concerning its legal future, and because of this, the exchange rate fluctuates wildly. One interesting angle (and one that differentiates virtual currency from crowd funding) is that I think Bitcoin and other virtual currencies need regulation and a clearing up of the current legal ambiguity in order to thrive and ultimately survive.

    In the grand scheme of things, I think virtual currency is here to stay. It corresponds nicely with two economic trends: a global economy and paperless currency. What remains to be seen is whether Bitcoin will be the ‘myspace’ of virtual currency that paves the road for a more regulated and secure ‘facebook’ to establish itself down the line.

  2. I agree that virtual currency is here to stay and as such demands increased regulation. What I found to be interesting was that a few successful ‘Bitcoiners’ have begun to self-regulate. See Bailey Reutzel, Innovators Create Self-Regulating Body for Virtual Currency, Payments Source (July 30, 2013 12:01am ET), available at The creation of this committee is, what I assume, an attempt to legitimize the practice when it clearly ripe with the possibility of using it for money laundering purposes.
    To me, the question then becomes are these the right people to be investigating and deciding what best practices are when they have an obvious motivation (their own bitcoin businesses) that may be in direct contrast to what is best for consumers. As virtual currency becomes more commonplace, I believe the only answer is government creation of a distinct (objective) committee. Although input from successful Bitcoiners may be imperative to deciding what workable best practices may be, the ultimate decision must rest in the hands of an objective third party.

  3. The problem of crime committed using digital currencies is mind boggling. As a non-tech savvy person myself, I don’t even know where to begin to stay one step ahead of the criminals. I like the author’s note that technology is moving ahead at blazing speed and the law lags in keeping up. Technology is improving so fast that even many consumers can’t even keep up with the latest trends. So good luck to a cumbersome process of legislations and law enforcement policies in keeping ahead of the criminal uses for technology. The one thing I can think of that would help curb big players, like banks, from entertaining money laundering of digital currencies is to criminalize it. For example, instead of imposing fines on the banks who are found to have engaged in laundering, impose criminal sanctions on the executives of those banks. I think if executives face personal criminal responsibility, rather than just paying fines out of the company’s pocket, they will take more care to ensure that the company is not engaging in illegal activity.

    • The reason they do no criminally prosecute the banks is because if they won the case the banks would lose their banking licenses. These banks are so large that if one of them were to be successfully prosecuted the financial system would collapse. So essentially we have “too big to fail” and “too big to prosecute”.

      • Except I think Bank of America is actually being prosecuted now for the mortgage fraud it perpetuated during the housing collapse. I think that the general outrage that banks can do this sort of thing with just a slap on the wrist has finally gotten the attention of federal prosecutors.

        On a related note, I think it’s interesting that Liberty Reserve is pulling the same kind of stuff kickstarter does by forcing customers to use a third party payment processor to avoid liability.

        Finally, one commenter mentioned how bitcoiners are starting to self-regulate. Although there are some that are doing so, there are many more that are not and are simply not interested in doing so if they don’t have to. I definitely agree with that commenter that we need an independent body that can investigate and help define best practices in bitcoin usage.

      • What if the policy shifted to prosecuting the individuals responsible for making the calls that led to the fraudulent housing market, rather than prosecuting the banks themselves? Putting people, rather than the institutions, on the chopping block might incentivize more ethical deciison making. They could do this by having an organization similar to the bar that self-regulates effectively.

      • It used to be true that the banks were not prosecuted but rather the government relied on settlements with FinCen. However, this is no longer the case. The Wachovia practices were so blatant that the government insisted on a guilty plea from the institution. Last year HSBC, a huge international banking conglomerate was criminally prosecuted for money laundering (Mexican drug cartels) and allowing the potential for terrorists to use the banks. A guilty plea was obtained as well as record breaking fines. Government is starting to realize that the civil fines are ineffective because the banks just consider them a cost of doing business. A criminal plea however, does have serious implications to the stability of the institution’s banking charter

  4. Liberty Reserve perfectly illustrates the worrisome aspects of unregulated virtual currency. However, it is important to keep in mind that Liberty Reserve was a centralized digital currency – whereas Bitcoin is a decentralized digital currency. Liberty Reserve was owned by a private company that profited from every transfer; the same cannot be said about Bitcoin. Given the decentralized structure of Bitcoin, there is a question of whether Bitcoin could even be completely shut down in a manner similar to Liberty Reserve. I fully support the regulation of virtual currency, but I believe regulation should be implemented on a case-by-case base; i.e. Liberty Reserve’s obvious illicit nature should be dealt with differently than Bitcoin.

  5. As a person who is illiterate to the online world, the story of Liberty Reserve is mind blowing. The fact that it took so long for federal law enforcement to jump on this, only goes to show that a lot of people like me are working in DOJ. I agree with the author that sheer speed with which these new programs of developing is completely leaving law enforcement in the dust. The internet is new version of the wild west, except “Billy the Kid” is a nerdy computer genius, were laws are loosely enforced. While agree that virtual currency is here to stay, because my generation cannot stand anything that isn’t tech friendly, I do not necessarily think that is a good thing. Even the traditional banking system is plagued with criminal activity it is among one the most heavily regulated industries just imagine what a virtual banking system is going to look like. (A lot like Liberty Reserve)

  6. I agree with the above commenters when I say that I am mindblown by this story. I think that the problem is really lack of education to policy makers and those in positions of power. If the training and infastructure doesn’t exist to educate government staff on the up and coming ways that criminals are seeking to commit crimes, mostly in the virtual and technological world, we are doomed to see a virtual anarchy where those who wish to launder money will do so at a rapid pace until the government catches up.

    I was thinking of a soluiton to this, and thinking of a way that corporations, like Bitcoin, who provide a shelter to these activities could help. One way that they can do this is by providing a MOOC or tutorial. MOOCs (Massive Open Online Courses) might be a way for companies like bitcoin to appear coopertive to solving the problems that are created by their unregulated structure. A MOOC from bitcoin might just be a course tutorial that allowed staff members at the DOJ and even people like you and me to understand how to fully use their services, and help lawmakers to better understand the system of virtual currency. I know for me, I barely understand real currency. An online video tutorial to the basics would do wonders for me to understand what exactly Bitcoin does for the user and therefore lead me to better understand how to tackle those who are gaming the system.

  7. I am speechless. These people were making billions of dollars that was virtually untraceable! I guess it goes without saying if you can think it. It can be done. Unlike bitcoin and some of the other types of virtual currency this was real money. This really doesn’t make me feel all that great considering the fact that my Mortgage is through Wells Fargo and I do most of my banking with Bank of America. I am just appalled. I realize all things evolve and virtually everything is going virtual or online based but regulations have to be enforced.

    Liberty Serve allowed people to open accounts anonymously. Criminals are using this method to store, exchange, transfer illegal funds, which is bad in itself. But had someone decided to tap into Liberty Reserve and steal all of that money, they probably would have gotten away scott free since after all there was no way to trace these accounts.

  8. The portion of the government dealing with anti-money laundering has had a tough battle regulating entities that provide forums for the administration and/or exchange of virtual currencies as evidenced by the excessively long amount of time it took to take down the prominent Liberty Exchange network. I think that if government wants to step up to the plate and go after exchanges where underground criminal enterprises are obviously operating, they do need to significantly further their understanding of the cyberworld and how the general public are only increasing their involvement and integration of their daily lives into it. The government would do well to hire more technologically advanced personnel that have a keen comprehension and familiarity with these virtual operations. Hackers and other such tech-savvy people that are taken up by the government after a bust of a server room would be the ideal but these are few and far between specialist that you mainly see in movies. The most practical way is to feed more money and resources into tech education and emerging electronic fields so young people can go into these areas and have a more advanced grasp of the concept that will be key in the future. Some of these people will turn to the dark side, as it were, and funnel their time and energy into working on these underground operations but there will be many more who will then be capable of thwarting and regulating them.

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