Cooperation with the Private Sector The need for greater transparency Stefan D. Cassella Asset Forfeiture Law, LLC Cassella@assetforfeiturelaw.us

The Russian Laundromat Contract fraud Tax evasion and tax fraud Embezzlement Flight Capital Organized Crime

The Russian Laundromat Shell Company A Shell Company B Documents say A owes B money, Russian company guarantees the debt Company A defaults on the debt Moldovan judge orders the Russian company to pay Company B Company B’s Account in Moldova

Mirror Trading Shell Company B Broker says to Deutsche Bank: Company A wants to buy stock worth $10M in XYZ in Moscow and Company B wants to sell the same stock in London

A B Mirror Trading A buys stock for $10 million in Moscow B sells the same stock (at market rate) in London B

Common Elements Use of shell companies Lax AML compliance / failure to detect suspicious transactions Willingness of vendors / banks to accept payments from third parties

Risks to National Security Surrendering the high ground Facilitating future criminal activity / terrorist financing Integrity of institutions / skewing the marketplace

Recommendations Increase awareness of the risks of accepting third-party payments Prohibit transactions that are not transparent (ownership and source of funds) Require financial institutions to know the customer’s customer

Cooperation with the Private Sector The need for greater transparency Stefan D. Cassella Asset Forfeiture Law, LLC Cassella@assetforfeiturelaw.us