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Cooperation with the Private Sector
The need for greater transparency Stefan D. Cassella Asset Forfeiture Law, LLC
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The Russian Laundromat
Contract fraud Tax evasion and tax fraud Embezzlement Flight Capital Organized Crime
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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
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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
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A B Mirror Trading A buys stock for $10 million in Moscow
B sells the same stock (at market rate) in London B
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Common Elements Use of shell companies
Lax AML compliance / failure to detect suspicious transactions Willingness of vendors / banks to accept payments from third parties
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Risks to National Security
Surrendering the high ground Facilitating future criminal activity / terrorist financing Integrity of institutions / skewing the marketplace
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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
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Cooperation with the Private Sector
The need for greater transparency Stefan D. Cassella Asset Forfeiture Law, LLC
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