The “Big” Picture Surrounding BSA/AML: Issues of Concern Presented by Mary Meile, President The Anti-Money Laundering Assoc. The Anti-Money Laundering

The “Big” Picture The “Big” Picture Surrounding BSA/AML: Surrounding BSA/AML:

Issues of Concern Issues of Concern

Presented byPresented byMary Meile, PresidentMary Meile, President

The Anti-Money Laundering The Anti-Money Laundering Assoc.Assoc.

A world of financial instability. A world of financial instability. Weaknesses in our nation’s security Weaknesses in our nation’s security

tracking systems. tracking systems. Cyber security attacks. Cyber security attacks. American born extremists within our American born extremists within our

nation seeking to perform Jihad, and nation seeking to perform Jihad, and New terrorist strategies to bring New terrorist strategies to bring

America down. America down.

Different EraDifferent Era

US DOJ HEADLINESUS DOJ HEADLINES Pennsylvania Woman Indicted in Plot to RePennsylvania Woman Indicted in Plot to Re

cruit Violent Jihadist Fighters and to Commcruit Violent Jihadist Fighters and to Commit Murder Overseasit Murder Overseas

Two Charged with Terror Violations in Two Charged with Terror Violations in Connection with New York Subway PlotConnection with New York Subway Plot

Najibullah Zazi Pleads Guilty to Conspiracy Najibullah Zazi Pleads Guilty to Conspiracy to Use Explosives Against Persons or to Use Explosives Against Persons or Property in U.S., Conspiracy to Murder Property in U.S., Conspiracy to Murder Abroad and Providing Material Support to Abroad and Providing Material Support to Al-QaedaAl-Qaeda

Tahawwur Rana and David Headley Tahawwur Rana and David Headley Indicted for Alleged Roles in India and Indicted for Alleged Roles in India and Denmark Terrorism ConspiraciesDenmark Terrorism Conspiracies

US DOJ HEADLINESUS DOJ HEADLINES

Umar Farouk Abdulmutallab Indicted for Umar Farouk Abdulmutallab Indicted for Attempted Bombing of Flight 253 on Attempted Bombing of Flight 253 on Christmas DayChristmas Day

Nigerian National Charged with Attempting Nigerian National Charged with Attempting to Destroy Northwest Airlines Aircraftto Destroy Northwest Airlines Aircraft

Terrorism Defendants Sentenced in Terrorism Defendants Sentenced in AtlantaAtlanta

Chicagoan Charged with Conspiracy in Chicagoan Charged with Conspiracy in 2008 Mumbai Attacks in Addition to 2008 Mumbai Attacks in Addition to Foreign Terror Plot in DenmarkForeign Terror Plot in Denmark

New Terrorist StrategyNew Terrorist Strategy

Terrorism expert Bruce Hoffman, was Terrorism expert Bruce Hoffman, was quoted as saying, “the attack on the CIA quoted as saying, “the attack on the CIA base in Khost, Afghanistan, as well as the base in Khost, Afghanistan, as well as the al-Qaeda-backed attempt to blow up a U.S. al-Qaeda-backed attempt to blow up a U.S. airliner on Christmas Day, airliner on Christmas Day, show that the show that the international terrorist movement has international terrorist movement has substantiallysubstantially changed its strategychanged its strategy compared to attacks like Sept. 11 which compared to attacks like Sept. 11 which were designed to "deliver a knock-out were designed to "deliver a knock-out blow. Instead, Hoffman said, "al-Qaeda's blow. Instead, Hoffman said, "al-Qaeda's leadership leadership has now adopted a 'death by a has now adopted a 'death by a thousand cuts' approach."thousand cuts' approach."

Hoffman Expert WarningHoffman Expert Warning

““Death by a thousand cuts” means Death by a thousand cuts” means slow and subtle.slow and subtle.


Hoffman Hoffman warnedwarned that al-Qaeda is that al-Qaeda is trying to confound U.S. efforts to trying to confound U.S. efforts to connect dots of intelligence by: connect dots of intelligence by: overwhelming, distracting and overwhelming, distracting and exhausting us. They seek to flood our exhausting us. They seek to flood our already information-overloaded already information-overloaded national intelligence systems with national intelligence systems with myriad threats and background noise. myriad threats and background noise. They hope we will overlook key clues.They hope we will overlook key clues.

Can You Relate?Can You Relate?

Many BSA and AML Officers are Many BSA and AML Officers are overburdened and exhausted.overburdened and exhausted.


Hoffman states, “oddly enough for a Hoffman states, “oddly enough for a terrorist movement supposedly on its terrorist movement supposedly on its last legs, al-Qaeda (December) last legs, al-Qaeda (December) launched two separate attacks less launched two separate attacks less than a week apart -- one failed and than a week apart -- one failed and one successful -- one successful -- triggering the most triggering the most extensive review of U.S. national extensive review of U.S. national security policies since 2001.security policies since 2001.


al-Qaeda is covetously seeking recruits al-Qaeda is covetously seeking recruits from non-Muslim countries who can be from non-Muslim countries who can be easily deployed for attacks in the West. easily deployed for attacks in the West.

Citizens of countries that participate in Citizens of countries that participate in the U.S. visa-waiver program are the U.S. visa-waiver program are especially prized because they can especially prized because they can move freely between Western countries move freely between Western countries and blend easily into these societies. and blend easily into these societies.


al-Qaeda is shrewdly opportunistic. It al-Qaeda is shrewdly opportunistic. It constantly monitors our defenses in an constantly monitors our defenses in an effort to identify new effort to identify new gaps and gaps and opportunitiesopportunities that can be exploited. Its that can be exploited. Its operatives track our congressional operatives track our congressional hearings, think-tank analyses and media hearings, think-tank analyses and media reports, all of which provide strategic reports, all of which provide strategic intelligence. By coupling this information intelligence. By coupling this information with surveillance efforts, the movement has with surveillance efforts, the movement has overcome many of the security measures overcome many of the security measures we have put in its path. we have put in its path.


Hoffman states, “Remarkably, more Hoffman states, “Remarkably, more than eight years after Sept. 11, we than eight years after Sept. 11, we still don't fully understand our still don't fully understand our dynamic and evolutionary enemy. dynamic and evolutionary enemy.

He explains how we need to He explains how we need to break break the cycle of radicalization and the cycle of radicalization and recruitment that sustains the recruitment that sustains the movement. movement.

Expert WarningExpert Warning

Bruce Hoffman continues, “With our Bruce Hoffman continues, “With our military overcommitted in Iraq and military overcommitted in Iraq and Afghanistan and our intelligence Afghanistan and our intelligence community overstretched by community overstretched by multiplying threats, a multiplying threats, a new approach new approach to counterterrorismto counterterrorism is essential”. is essential”.

New Threat Coming Of AgeNew Threat Coming Of Age

March 9, 2010- Colleen R. March 9, 2010- Colleen R. LaRose, aka "Fatima LaRose, aka "Fatima LaRose," aka "Jihad Jane.”LaRose," aka "Jihad Jane.”

Jihad JaneJihad Jane


1.1. Woman from suburban America Woman from suburban America

2.2. Agreed to carry out murder overseas Agreed to carry out murder overseas and to provide material support to and to provide material support to terrorists. terrorists.

3.3. Appearance an asset- can travel safely Appearance an asset- can travel safely without notice or suspicion-blends in.without notice or suspicion-blends in.

4.4. Used Internet to establish relationships Used Internet to establish relationships and communicate plans.and communicate plans.


Charged with: Conspiracy to provide Charged with: Conspiracy to provide material support to terrorists.material support to terrorists.

Conspiracy to kill in a foreign Conspiracy to kill in a foreign countrycountry

Making false statements to a Making false statements to a government official.government official.

Attempted identity theft. Attempted identity theft.


Her Story: Jihad Jane and 5 others Her Story: Jihad Jane and 5 others scattered across the globe recruited men scattered across the globe recruited men to to wage violent jihadwage violent jihad in South Asia and in South Asia and Europe, and recruited women who had Europe, and recruited women who had passports and the ability to travel to and passports and the ability to travel to and around Europe in support of around Europe in support of violent jihadviolent jihad. .

Plans for martyring themselves, soliciting Plans for martyring themselves, soliciting funds for terrorists, soliciting passports funds for terrorists, soliciting passports and avoiding travel restrictions (through and avoiding travel restrictions (through the collection of passports and through the collection of passports and through marriage) in order to marriage) in order to wage violent jihadwage violent jihad. .


Demonstrates the following:Demonstrates the following: Emerging trend in Emerging trend in homegrown homegrown

terrorismterrorism, virtual highway of internet , virtual highway of internet makes easy access, increase in makes easy access, increase in potential lone wolf operatives, and potential lone wolf operatives, and terrorists are openly speaking about terrorists are openly speaking about their pleasure and interest in the their pleasure and interest in the actions of such independent actors.actions of such independent actors.

We can not assume a terrorist based We can not assume a terrorist based on appearance.on appearance.

Homegrown JihadistHomegrown Jihadist

Najibullah ZaziNajibullah Zazi

Zazi is a legal permanent resident of Zazi is a legal permanent resident of the US from Afghanistan the US from Afghanistan

Zazi is a resident of Aurora, Colorado Zazi is a resident of Aurora, Colorado Zazi admitted, he and others agreed Zazi admitted, he and others agreed

to travel to Afghanistan to join the to travel to Afghanistan to join the Taliban and fight against United Taliban and fight against United States and allied forcesStates and allied forces

Najibullah ZaziNajibullah Zazi

The Justice Department announced The Justice Department announced that Najibullah Zazi pleaded guilty in that Najibullah Zazi pleaded guilty in a "conspiracy to use weapons of mass a "conspiracy to use weapons of mass destruction in the United States," in destruction in the United States," in connection with al-Qaeda. His main connection with al-Qaeda. His main attack targeted the New York subway attack targeted the New York subway system. system.

America is being penetrated by a America is being penetrated by a network that is producing the Jihadists network that is producing the Jihadists

Terrorist Identities Datamart Terrorist Identities Datamart Environment (TIDE)Environment (TIDE)

TIDE is the US Government’s (USG) TIDE is the US Government’s (USG) central repository of information on central repository of information on international terrorist identities as international terrorist identities as established by the Intelligence established by the Intelligence Reform and Terrorism Prevention Act Reform and Terrorism Prevention Act of 2004.of 2004.

Supports Supports the USG’s various terrorist the USG’s various terrorist screening systems or “watchlists” screening systems or “watchlists” and the US Intelligence Community’s and the US Intelligence Community’s overall counterterrorism mission.overall counterterrorism mission.


Consolidated watchlist a critical Consolidated watchlist a critical tool for homeland security, tool for homeland security, supports screening processes to supports screening processes to detect and interdict known and detect and interdict known and suspected terrorists at home and suspected terrorists at home and abroad.abroad.


As of January 2009, TIDE contained As of January 2009, TIDE contained more than 564,000 names, 500,000 more than 564,000 names, 500,000 separate “identities” because of the separate “identities” because of the use of aliases and name variants. use of aliases and name variants.

U.S. Persons (including both citizens U.S. Persons (including both citizens and legal permanent residents) make and legal permanent residents) make up less than five percent of the up less than five percent of the listings.listings.


Christmas Day AttackChristmas Day Attack

On Dec. 25, 2009, Nigerian Umar On Dec. 25, 2009, Nigerian Umar Farouk Abdulmutallab boarded Farouk Abdulmutallab boarded Northwest Flight 253 in Amsterdam Northwest Flight 253 in Amsterdam and attempted to detonate plastic and attempted to detonate plastic explosives he had hidden in his explosives he had hidden in his clothing. clothing.

Father alerted authorities he was Father alerted authorities he was concerned about involvement with concerned about involvement with religious extremists. religious extremists.

Incident ReportIncident Report

The US had enough intelligence prior The US had enough intelligence prior to the failed attempt to destroy an to the failed attempt to destroy an airliner bound for Detroit on Christmas airliner bound for Detroit on Christmas Day to indicate such a plot was under Day to indicate such a plot was under way, and to disrupt it, according to way, and to disrupt it, according to the administration review of the the administration review of the incident report released Jan. 7. The incident report released Jan. 7. The problem was that intelligence in problem was that intelligence in essence fell through the cracks. essence fell through the cracks.

Incident ReportIncident Report

Not a failure to collect or share Not a failure to collect or share intelligence.intelligence.

Failure to connect, integrate, and Failure to connect, integrate, and understand the intelligence we had.understand the intelligence we had.

Need to modify the existing policy Need to modify the existing policy standards for inclusion on lists. standards for inclusion on lists.

What Went Wrong?What Went Wrong?

"We didn't know they had progressed "We didn't know they had progressed to the point of actually launching to the point of actually launching individuals here," said John Brennan, individuals here," said John Brennan, the president's chief counterterrorism the president's chief counterterrorism adviser. adviser.

The government's counterterrorism The government's counterterrorism operations had been operations had been caught off guardcaught off guard by the sophistication of an al-Qaida cell by the sophistication of an al-Qaida cell in Yemen, where officials say the plot in Yemen, where officials say the plot against the United States originated. against the United States originated.

LISTLIST

Abdulmutallab's name was in TIDE Abdulmutallab's name was in TIDE database but his name was not database but his name was not added to the shorter lists of possibly added to the shorter lists of possibly more dangerous suspects, such as more dangerous suspects, such as the the no-fly listno-fly list maintained by the FBI’s maintained by the FBI’s Terrorist Screening Center. Terrorist Screening Center.

That list includes about 3,400 names.That list includes about 3,400 names.

Future Plan of ActionFuture Plan of Action

In laying out directives in four areas, the In laying out directives in four areas, the president spoke of “assigning clear lines of president spoke of “assigning clear lines of responsibility.” Specifically, he underscored the responsibility.” Specifically, he underscored the need to:need to:

Act aggressively when leads arise. Act aggressively when leads arise. Distribute intelligence reports more rapidly and Distribute intelligence reports more rapidly and

widely when threats become known. widely when threats become known. Strengthen the analytical process to allow Strengthen the analytical process to allow

security agencies to “connect the dots” of security agencies to “connect the dots” of possible threats.possible threats.

Strengthen of the criteria used to add individuals Strengthen of the criteria used to add individuals to terror watch lists, especially no-fly lists.to terror watch lists, especially no-fly lists.

CybersecurityCybersecurity

Cybersecurity Coordinator, Howard Cybersecurity Coordinator, Howard SchmidtSchmidt


President Obama has declared that President Obama has declared that the “cyber threat is one of the most the “cyber threat is one of the most serious economic and national serious economic and national security challenges we face as a security challenges we face as a nation” and that “America's nation” and that “America's economic prosperity in the 21st economic prosperity in the 21st century will depend on century will depend on cybersecurity.” cybersecurity.”


1.1. Cybercrime cost Americans more than $8 Billion Cybercrime cost Americans more than $8 Billion dollars for a 2 year period (2009 and 2008).dollars for a 2 year period (2009 and 2008).

2.2. A growing threat that encompasses national A growing threat that encompasses national security and public safety. security and public safety.

3.3. Computer networks deliver our oil and gas, our Computer networks deliver our oil and gas, our power and our water. power and our water.

4.4. Public transportationPublic transportation5.5. Air traffic control Air traffic control 6.6. Yet we know that cyber intruders have probed Yet we know that cyber intruders have probed

our electrical grid and that in other countries our electrical grid and that in other countries cyber attacks have plunged entire cities into cyber attacks have plunged entire cities into darkness. darkness.


Our Nation’s cybersecurity strategy Our Nation’s cybersecurity strategy is twofold: is twofold:

(1) improve our resilience to (1) improve our resilience to cyber incidentscyber incidents and and

(2) reduce the cyber threat. (2) reduce the cyber threat. President has established a plan of President has established a plan of

action.action.


Federal agencies spend $6 billion a Federal agencies spend $6 billion a year on cybersecurity to protect the year on cybersecurity to protect the government's IT infrastructure and government's IT infrastructure and $356 million on research, according to $356 million on research, according to the Office of Management and Budget. the Office of Management and Budget.

Despite that funding, a government Despite that funding, a government review of its cybersecurity efforts last review of its cybersecurity efforts last year concluded that they are not year concluded that they are not adequate to prepare the country adequate to prepare the country against cyberattacks. against cyberattacks.

OPERATION PHISH PHRY-FBIOPERATION PHISH PHRY-FBIMajor Cyber Fraud TakedownMajor Cyber Fraud Takedown

The defendants in Operation Phish The defendants in Operation Phish Phry targeted U.S. banks and Phry targeted U.S. banks and victimized hundreds and possibly victimized hundreds and possibly thousands of account holders by thousands of account holders by stealing their financial information stealing their financial information and using it to transfer about $1.5 and using it to transfer about $1.5 million to bogus accounts they million to bogus accounts they controlled.controlled.


The FBI claims that the phishers' modus The FBI claims that the phishers' modus operandi was the following: hackers in operandi was the following: hackers in Egypt would gather personal information Egypt would gather personal information and banking details from the victims and and banking details from the victims and pass them on to their U.S. comrades. The pass them on to their U.S. comrades. The latter would then use the stolen latter would then use the stolen credentials to access the accounts, steal credentials to access the accounts, steal the money and send part of it to their the money and send part of it to their associates in Egypt.associates in Egypt.


It took two years of investigating and It took two years of investigating and the involvement of Egypt authorities, the involvement of Egypt authorities, but the FBI has reached its goal: 100 but the FBI has reached its goal: 100 people have been finally charged for people have been finally charged for their participation in a multinational their participation in a multinational phishing operation.phishing operation.

Albert Gonzalez (aka “Segvec”)Albert Gonzalez (aka “Segvec”)

““TJX” CASETJX” CASE

September 11, 2009September 11, 2009 Secret Service uncovered the theft Secret Service uncovered the theft

and sale of more than 40 million and sale of more than 40 million credit and debit card numbers from credit and debit card numbers from numerous U.S. retailers. The numerous U.S. retailers. The potential losses associated with this potential losses associated with this case total more than $21 billion.case total more than $21 billion.


Mastermind behind the elaborate Mastermind behind the elaborate fraud scheme- Miami, Florida, fraud scheme- Miami, Florida, pleaded guilty to 19 counts of pleaded guilty to 19 counts of conspiracy, computer fraud, wire conspiracy, computer fraud, wire fraud, access device fraud, and fraud, access device fraud, and aggravated identity theft. aggravated identity theft.

Allegedly sold some of the credit and Allegedly sold some of the credit and debit card numbers, via the Internet, debit card numbers, via the Internet, to other criminals in the United to other criminals in the United States and Eastern Europe.States and Eastern Europe.


Briefly an informant to the Secret Briefly an informant to the Secret Service before he allegedly returned Service before he allegedly returned to commit even bolder crimes. to commit even bolder crimes.

Threw himself a $75,000 birthday Threw himself a $75,000 birthday party and at one point lamented he party and at one point lamented he had to count more than $340,000 by had to count more than $340,000 by hand because his money counter had hand because his money counter had broken. broken.

Barclays programmer jailed over Barclays programmer jailed over TJX hack TJX hack

March 15, 2010: Humza Zaman March 15, 2010: Humza Zaman laundered between $600,000 and laundered between $600,000 and $800,000 for Gonzalez, who is $800,000 for Gonzalez, who is awaiting sentencing after pleading awaiting sentencing after pleading guilty to a string of cyber-attacks on guilty to a string of cyber-attacks on several firms, resulting in the theft of several firms, resulting in the theft of tens of millions of payment card tens of millions of payment card details.details.

PenaltiesPenalties

Humza Zaman was sentenced to 46 months Humza Zaman was sentenced to 46 months incarceration and three years supervised incarceration and three years supervised release as well as given a $75,000 fine by a release as well as given a $75,000 fine by a court in Boston after pleading guilty to one court in Boston after pleading guilty to one count of conspiracy last April.count of conspiracy last April.

Gonzalez is facing a minimum 17-year Gonzalez is facing a minimum 17-year prison sentence after pleading guilty to a prison sentence after pleading guilty to a string of attacks on several firms, including string of attacks on several firms, including TJX and Heartland Payment Systems. TJX and Heartland Payment Systems.

Co-ConspiratorCo-Conspirator

In 2009, another of his co-In 2009, another of his co-conspirators, former Morgan Stanley conspirators, former Morgan Stanley software engineer Stephen Watt, was software engineer Stephen Watt, was sentenced to two years in prison for sentenced to two years in prison for developing the software used to developing the software used to capture payment card data. capture payment card data.

FinCEN-RegulatoryFinCEN-Regulatory

FinCEN Director Freis provides remarks FinCEN Director Freis provides remarks onon

emerging issuesemerging issues: : 1.1. Trade-based money laundering (TBML) Trade-based money laundering (TBML)

systems, such as the Black Market Peso systems, such as the Black Market Peso Exchange (to transfer value across Exchange (to transfer value across international borders in attempts to international borders in attempts to disguise the illicit origins of the criminal disguise the illicit origins of the criminal proceeds) are still prevalent. proceeds) are still prevalent.

2.2. FraudFraud


Basic schemes included misrepresenting Basic schemes included misrepresenting the price and quantity of goods and the price and quantity of goods and services (over-and under-invoicing), and services (over-and under-invoicing), and invoicing the same goods or services invoicing the same goods or services more than once (double invoicing). The more than once (double invoicing). The illicit activity was hidden in part by the illicit activity was hidden in part by the enormous volume of international trade enormous volume of international trade transactions, an estimated transactions, an estimated $15.7 trillion$15.7 trillion in global merchandise in global merchandise exportsexports in 20086. in 20086.


According to the 2009 International According to the 2009 International Narcotics Control Strategy Report, it is Narcotics Control Strategy Report, it is estimated that the annual dollar estimated that the annual dollar amount laundered through trade ranges amount laundered through trade ranges into the into the hundreds of billionshundreds of billions. . Additionally, U.S. Immigration and Additionally, U.S. Immigration and Customs Enforcement (ICE) reports that Customs Enforcement (ICE) reports that their trade-based money laundering their trade-based money laundering case initiations have increased by 348 case initiations have increased by 348 percent since 2004. percent since 2004.


FinCEN has seen inconsistent FinCEN has seen inconsistent identification of this activity in many identification of this activity in many SAR filings determined to be related SAR filings determined to be related to trade-based money laundering. to trade-based money laundering. For example, the use of the term For example, the use of the term “trade-based money laundering” or “trade-based money laundering” or “TBML” as a key phrase in the “TBML” as a key phrase in the narrative is sometimes missing. narrative is sometimes missing.


FinCEN issued an advisory (FIN-2010FinCEN issued an advisory (FIN-2010

A001) on Feb 18, 2010 regarding SARs A001) on Feb 18, 2010 regarding SARs andand

Trade Based Money Laundering.Trade Based Money Laundering. The advisory includes potential The advisory includes potential

indicators of TBML, and indicators of TBML, and Potential Potential red flagsred flags for trade-based for trade-based

money laundering or black market money laundering or black market peso exchange activities.peso exchange activities.


Red flagsRed flags seen in conjunction with seen in conjunction with shipments of high dollar merchandise shipments of high dollar merchandise (such as electronics, auto parts and (such as electronics, auto parts and precious metals and gems) to duty precious metals and gems) to duty free trade zones, such as in the free trade zones, such as in the Colon Free Trade Zone in Panama, Colon Free Trade Zone in Panama, could be an indication of a trade-could be an indication of a trade-based money laundering or black based money laundering or black market peso exchange activity. market peso exchange activity.

FinCEN-RegulatoryFinCEN-RegulatorySAR Filing:SAR Filing: FinCEN requests: FinCEN requests:

1.1. Check the appropriate box in the Check the appropriate box in the Suspicious Activity Information section of Suspicious Activity Information section of the SAR form and include the abbreviation the SAR form and include the abbreviation “TBML” or “BMPE” in the narrative portion “TBML” or “BMPE” in the narrative portion of all relevant SARs filed. of all relevant SARs filed.

2.2. The narrative should include an The narrative should include an explanation of why the institution explanation of why the institution suspects, or has reason to suspect, that suspects, or has reason to suspect, that the customer is participating in this type the customer is participating in this type of activity. of activity.


FRAUD & AMLFRAUD & AML Fraud and acts of money laundering are Fraud and acts of money laundering are

interconnected as ML is often a product of interconnected as ML is often a product of fraud. fraud.

Customer and transactional information Customer and transactional information used for AML purposes is often the same used for AML purposes is often the same customer and transactional information customer and transactional information needed for fraud investigations.needed for fraud investigations.

FinCEN encourages 314b information FinCEN encourages 314b information sharing as an effort to fight fraud. sharing as an effort to fight fraud.

Resources and CreditsResources and Credits Washington Post: Article by Bruce Hoffman, Washington Post: Article by Bruce Hoffman, Al-Qaeda has a Al-Qaeda has a

new strategy. Obama needs one, toonew strategy. Obama needs one, too. January 10, 2010. . January 10, 2010. Prepared remarks of James H. Freis, Jr. Director, Financial Prepared remarks of James H. Freis, Jr. Director, Financial

Crimes Enforcement NetworK. Florida International Bankers Crimes Enforcement NetworK. Florida International Bankers Association 2010 AML Conference. Feb 8, 2010 Association 2010 AML Conference. Feb 8, 2010

John-Brennan-We-failed-on-Christmas-Day-terrorist-John-Brennan-We-failed-on-Christmas-Day-terrorist-intelligence http://www.csmonitor.com/USA/2010/0107/John-intelligence http://www.csmonitor.com/USA/2010/0107/John-Brennan-We-failed-on-Christmas-Day-terrorist-intelligenceBrennan-We-failed-on-Christmas-Day-terrorist-intelligence

President Obama remarks from the National Security Council President Obama remarks from the National Security Council http://www.whitehouse.gov/administration/eop/nsc/cybersechttp://www.whitehouse.gov/administration/eop/nsc/cybersecurity.urity.

President Barack Obama greets his new White House Cyber President Barack Obama greets his new White House Cyber Security Chief Howard A. Schmidt in the Cross Hall of the Security Chief Howard A. Schmidt in the Cross Hall of the White House. December 17, 2009. (Official White House White House. December 17, 2009. (Official White House Photo by Lawrence Jackson) Photo by Lawrence Jackson) http://www.whitehouse.gov/blog/2009/12/22/introducing-http://www.whitehouse.gov/blog/2009/12/22/introducing-new-cybersecurity-coordinatornew-cybersecurity-coordinator

Resources and CreditsResources and Credits

Colleen R. LaRoseColleen R. LaRose (AFP/Getty Images) This undated (AFP/Getty Images) This undated

image obtained on March 9, 2010 image obtained on March 9, 2010 courtesy of Fox News shows a photo courtesy of Fox News shows a photo from a website authorities say was from a website authorities say was maintained by terror suspect Colleen maintained by terror suspect Colleen R. LaRose. R. LaRose.

http://www.mcall.com/photos/all-http://www.mcall.com/photos/all-jihad-jane-pictures-jihad-jane-pictures-031010,0,4301319.photogallery031010,0,4301319.photogallery

Documents

The “Big” Picture Surrounding BSA/AML: Issues of Concern Presented by Mary Meile, President The Anti-Money Laundering Assoc. The Anti-Money Laundering