CONTENTS
Preface = ⅶ
Acknowledgements = ⅸ
Introduction = xi
1 The last will and testament of Lucky Luciano = 1
1.1 Historical background = 1
1.2 The heroin pipeline = 5
1.3 Extending the criminal franchise = 11
1.4 The British experience = 17
2 The sources of dirty money = 25
2.1 The finances of organized crime = 25
2.2 The nature of organized crime = 29
2.3 Terrorism = 33
2.4 Drug trafficking = 36
2.5 Organized crime in other sectors = 46
3 Financial institutions at risk = 53
3.1 The scale of the threat = 53
3.2 The British experience = 63
3.3 Underground banking = 74
4 The money laundering process = 79
4.1 The placement stage = 79
4.2 The Pizza Connection = 82
4.3 The layering stage = 87
4.4 The Brinks Mat robbery = 91
4.5 The integration stage = 98
4.6 Manipulating the institutions = 102
5 The offences of money laundering = 107
5.1 The development of the legislative philosophy = 107
5.2 U.S. anti-money laundering legislation = 113
5.3 Extending the British legislation = 115
5.4 The European directive on money laundering = 119
5.5 The new offences = 121
6 The money laundering regulations = 135
6.1 Defining the regulatory climate = 135
6.2 Regulation 2 - Interpretation = 137
6.3 Regulation 3 - Business relationships = 139
6.4 Regulation 4 - Relevant financial business = 139
6.5 Regulation 5 - Systems and training to prevent money laundering = 143
6.6 Regulation 6 - Offences by bodies corporate, partnerships and unincorporated associations = 147
6.7 Regulation 7 - The establishment of identification procedures, business relationships and transactions = 148
6.8 Regulation 8 - Payment by post = 153
6.9 Regulation 9 - Identification procedures: transaction on behalf of another = 154
6.10 Regulation 10 - Identification procedures: exemptions = 157
6.11 Regulation 12 - Record keeping procedures = 159
6.12 Regulation 14 - Internal reporting procedures = 162
6.13 Regulation 15 - Duty of supervisory authorities to report money laundering = 163
6.14 Regulation 16 - Supervisors to report evidence of money laundering = 165
6.15 Regulation 17 - Transitional provisions = 167
6.16 Summary = 167
7 Practical compliance guidelines = 171
7.1 The philosophy of compliance = 171
7.2 The practicalities of compliance = 177
7.3 Identifying the launderer = 183
7.4 The authorized person = 188
7.5 Production orders = 190
8 The international dimension = 195
8.1 Foreign initiatives = 195
8.2 The financial action task force = 204
8.3 Practical implementation = 212
Appendix A Criminal offences which possess money laundering characteristics = 219
Appendix B Organized crime threat assessment = 253
Appendix C The European directive on money laundering = 281
Appendix D Production orders = 289
References = 293
Index = 299
