• "Reaching Beyond Banks: How to Target Trade-based Money Laundering and Terrorist Financing Through Preventive Measures Outside the Financial Sector"
  • July 6, 2009 | Authors: Ross S. Delston; Stephen Walls
  • Law Firm: Delston, Ross S. - Washington Office
  • All those in the supply chain - exporters, importers, freight forwarders, carriers - should be subject to anti-money laundering and counter-terrorist financing (AML/CFT) preventive measures such as customer due diligence, appointment of a compliance officer, record-keeping and filing of suspicious activity reports or SARs. These requirements currently apply to financial institutions and related businesses such as banks, broker-dealers, insurance companies, mutual funds, and money services businesses. However, banks and other financial institutions are not well positioned to prevent or mitigate trade-based money laundering and/or trade-related terrorist financing or terrorist acts.