Financial Action Task Force Groupe D'action Financière
Financial Action Task ForceGroupe d'action financièreANNEXESTHIRD MUTUAL EVALUATION REPORT ONANTI-MONEY LAUNDERING ANDCOMBATING THE FINANCING OF TERRORISMUNITED STATES OF AMERICA23 JUNE 20061
ANNEX 1Acronyms and Abbreviations1267 Committee1373 PSCIFCIPCMAAsCMAMCMIRCNPCommerceCOPSCPOTCRSCSBCUN Security Council Committee established pursuant to resolution 1267(1999)UN Security Council Committee established pursuant to resolution 1373(2001)Acquisition and Assistance Policy Directive (USAID)American Bar AssociationAutomated Clearing HouseAntiterrorism and Effective Death Penalty Act of 1996Asset Forfeiture Coordinator (IRS)Asset Forfeiture Money Laundering Section (DOJ)Attorney GeneralAttorney General Exempted OperationsAmerican Institute of Certified Public AccountantsAdministrative Law JudgeAnti-money launderingAdvance Notice of Proposed Rule MakingAdministrative Procedure ActAsia Pacific GroupAdvanced Passenger Information SystemAsset Protection TrustAlternative Remittance SystemsAnnual Report of Trust AssetsAnti-Terrorism Certification (USAID)Bureau of Alcohol, Tobacco, Firearms, and Explosives (DOJ)Automatic Teller MachineBetter Business BureauBulk Cash SmugglingBank Holding CompanyBlack Market Peso ExchangeBureau of PrisonsBank Secrecy Act (Currency and Foreign Transactions Reporting Act)Bank Secrecy Act Advisory GroupCivil Asset Reform Act of 2000Customs and Border Protection (DHS)Currency and Banking Query SystemCurrency and Banking Retrieval SystemCustomer Due DiligenceCommodity Exchange ActCaribbean Financial Action Task ForceCode of Federal RegulationsCombating the financing of terrorism / Counter-terrorist financingCommodity Futures Trading CommissionClearing House Interbank Payments SystemCustomer Information FileCustomer Identification ProgramCustoms Mutual Assistance AgreementCustoms Mutual Assistance ManualReport of International Transportation of Currency or Monetary InstrumentsColombian National PoliceDepartment of CommerceCommunity Oriented Policing ServicesConsolidated Priority Organizational TargetCommunity Relations ServiceConference of State Bank Supervisors2
AECNEFTEINEOEO 13224EOIREPICEUExchange ActFBAFBARFBIFBOFCMFDI ActFDICFDSSFederal ReserveFFIECFILFATFFinCENFITFIUFOForm X 1Counter Terrorism Committee (UN)Currency Transaction ReportCurrency Transaction Report by a CasinoCounterterrorism Section (DOJ)District of ColumbiaDetroit Computing CenterDocument Control NumberDrug Enforcement AdministrationU.S. Department of Homeland SecurityDesignated non-financial businesses and professionsU.S. Department of JusticeDepartment of Public SafetyEnforcement Action Report SystemBureau of Economic and Business Affairs (State)Evangelical Council for Financial AccountabilityElectronic Communications NetworkElectronic Funds TransferEmployer Identification NumberExecutive OrderExecutive Order 13224 on Blocking Property and Prohibiting Transactionswith Persons Who Commit, Threaten to Commit, or Support TerrorismExecutive Office for Immigration ReviewEl Paso Intelligence CenterEuropean UnionSecurities Exchange Act of 1934Federal Banking AgencyReport of Foreign Bank or Financial AccountFederal Bureau of InvestigationForeign Banking OrganizationFutures Commission MerchantFederal Deposit Insurance ActFederal Deposit Insurance CorporationFederal Drug Seizure SystemFederal Reserve System/Board of Governors of the Federal Reserve SystemFederal Financial Institutions Examination CouncilFinancial Institution LetterFinancial Action Task ForceFinancial Crimes Enforcement Network (Treasury)Field Investigative TeamFinancial intelligence unitOffice of Financial Operations (DEA)Report of Cash Payments over 10,000 Received in a Trade or BusinessFederal RegisterFederal Reserve BankFATF-style regional bodyFinancing of terrorismForeign Terrorist Asset Targeting GroupFederal Trade CommissionFederal tax depositFinancial Trade Investigations Division (ICE)Fiscal Year (October 1- September 30)Foreign Terrorist OrganizationFinancial Action Task Force on Money Laundering in South AmericaU.S. Government Accountability Office3
SRINLIOSCOIPR MSBMSB-WGNAAGNAICNAFTANASCONASDNasdaqANNEX 1Gross Domestic ProductGeographic Targeting OrdersHigh Intensity Drug Trafficking AreaHigh Intensity Financial Crime AreaHome Owners Loan ActOffice of International Affairs (Treasury)Immigration and Customs Enforcement (DHS)International Committee for Fundraising OrganizationsInternational Drug Enforcement ConferenceInternational Emergency Economic Powers ActInspectors GeneralInternational Law Enforcement AcademyInternational Monetary FundInternational Narcotics Control Strategy ReportBureau of International Narcotics and Law Enforcement AffairsInternational Organization of Securities CommissionsCommercial Fraud Unit and National Center for Intellectual Property Rights(ICE)Internal Revenue CodeInternal Revenue Service (Treasury)Internal Revenue Service - Criminal InvestigationIntelligence Reform and Terrorism Prevention Act of 2004Individual Taxpayer Identification NumberInformal Value Transfer SystemJustice Forfeiture Fund (DOJ)Justice Management DivisionJoint Terrorism Task Force (FBI)Joint Vetting Unit (FBI and ICE)Know Your CustomerLimited Background InvestigationLarge Complex Banking OrganizationLetter to Credit UnionsLead Development Center (IRS-CI)Limited Liability CompanyModel Business Corporation ActMinimum Background InvestigationMutual evaluation reportMoney launderingMutual legal assistanceMutual Legal Assistance TreatyMoney Laundering Coordination Center (ICE)Money Laundering Suppression Act of 1994Multilateral Memorandum of UnderstandingMemorandum of AgreementMemorandum of UnderstandingMoney Services BusinessMoney Services Business Working Group (ICE, IRS, FinCEN, Treasury, FBI,DEA and members of the intelligence community)National Association of Attorneys GeneralNational Association of Insurance CommissionersNorth American Free Trade AgreementNational Association of State Charities OfficialsNational Association of Securities DealersNational Association of Securities Dealers Automated Quotation Systems4
CCOCDETFOCDETF/OFCOCITOECDOECD Bribery alermo X 1Non-Bank Financial InstitutionNational Council on Charitable StatisticsNational Counterterrorism CenterNational Credit Union AdministrationNational Drug Intelligence Center (FBI)National Futures AssociationNon-Governmental OrganizationNumerical Integrated Profiling SystemNational Joint Terrorism Task ForceNon-Profit OrganizationNational Security CouncilNew York Police DepartmentNew York Stock ExchangeOffice of the Comptroller of the Currency (Treasury)Organized Crime Drug Enforcement Task Force (DOJ)OCDETF Fusion CenterOutbound Currency Interdiction Training program (CBP/ICE)Organisation for Economic Co-operation and Development1997 Convention on Combating Bribery of Foreign Public Officials inInternational TransactionsOffice of Foreign Assets Control (Treasury)Offshore Financial CenterOffice of the Federal Detention TrusteeOffice of International Affairs (DOJ)Office of Intelligence and Analysis (Treasury)Office of the Inspector GeneralOffice of Justice ProgramsOffice of National Drug Control Policy (NSC)Over the CounterOffice of Thrift Supervision (Treasury)Office on Violence Against WomenÙnited Nations Convention against Transnational Organized Crime (2001)Policy Co-ordinating Committee (NSC)Politically Exposed PersonProfessional Resources DatabasePublic Company Accounting Oversight BoardPrinciples of Federal ProsecutionPrinciples of Federal Prosecution of CorporationsPort of EntryPeople’s Republic of ChinaPriority Targeted OrganizationRegulatory AlertRoyal Canadian Mounted PoliceReal estate mortgage investment conduitRight to Financial Privacy ActRacketeer Influenced and Corrupt OrganizationRegional Priority Organizational TargetSavings Association Insurance FundSuspicious Activity ReportSuspicious Activity Report by CasinosSuspicious Activity Report by Money Services BusinessesSuspicious Activity Report by Securities & Futures IndustriesSmall Business and Self-Employment Division (IRS)Office of the Coordinator for Counterterrorism (State)5
2001)SROSSBISSNStateSUATCSPTECSTECS IITEGETELTEOAFTerrorist Financing TUTWEAUCEUITUNUNCACUNPAU.S.USA PATRIOT ActUSAIDUSAOUSAsUSCUSDUSMSUSSCUSSSVACISVienna ConventionANNEX 1Specially Designated Global TerroristSpecially Designated National or Blocked PersonU.S. Securities and Exchange CommissionSecure Electronic Network for Travelers Rapid InspectionStrategic Information Operations Center (FBI)Special Operations Division (DEA)United Nations Security Council Resolution 1267United Nations Security Council Resolution 1373Self Regulatory OrganizationSingle Scope Background InvestigationSocial Security NumberDepartment of StateSpecified Unlawful ActivityTrust company service providerTreasury Enforcement Communications SystemTreasury Enforcement Communications System IITax Exempt and Government Entities Division (IRS)Terrorism Exclusion ListTreasury Executive Office for Asset ForfeitureUnited Nations International Convention for the Suppression of the Financingof Terrorism (1999)Treasury Forfeiture FundOffice of Terrorist Financing and Financial Crimes (Treasury)Office of Terrorism and Financial Intelligence (Treasury)Terrorist Financing Operations Section (FBI)Terrorism Financial Review GroupTerrorist Financing Working GroupTaxpayer Identification NumberU.S. Department of the TreasuryTemporary Restraining OrderTrade Secrets ActTrade Transparency Unit (ICE)Trading With the Enemy ActUniform Commission ExaminationUnit Investment TrustUnited NationsUnited Nations Convention Against CorruptionUnited Nations Participation ActUnited States of AmericaUniting and Strengthening America by Providing Appropriate Tools Requiredto Intercept and Obstruct Terrorism Act of 2001U.S. Agency for International Development (State)U.S. Attorney’s OfficeUnited States AttorneysUnited States CodeUnited States dollarsU.S. Marshalls ServiceU.S. Sentencing CommissionU.S. Secret Service (DHS)Vehicle and Cargo Inspection SystemUnited Nations Convention against Illicit Traffic in Narcotic Drugs andPsychotropic Substances (1988)6
ANNEX 2LIST OF THE BODIES MET WITH DURINGTHE THIRD MUTUAL EVALUATION OF THE UNITED STATESFederal authoritiesBoard of Governors of the Federal Reserve SystemCommodity Futures Trading Commission (CFTC)Department of Homeland Security Customs and Border Protection (CBP)Department of Homeland Security Immigration and Customs Enforcement (ICE)Department of Justice Asset Forfeiture and Money Laundering Section (AFMLS)Department of Justice Counterterrorism SectionDepartment of Justice Criminal DivisionDepartment of Justice Office of International Affairs (OIA)Drug Enforcement Administration (DEA)Federal Bureau of Investigation (FBI)Federal Deposit Insurance Corporation (FDIC)Federal Reserve Bank of New YorkFinancial Crimes Enforcement Network (FinCEN)Financial Crimes Enforcement Network Office of Regulatory PolicyHigh Intensity Financial Crimes Area/El Dorado Task Force (New York)High Intensity Financial Crimes Area (Puerto Rico)High Intensity Drug Trafficking Area (South Florida)Immigration and Customs Enforcement (ICE)Internal Revenue Service – Criminal Investigation (IRS-CI)Internal Revenue Service – Small Business and Self-Employment Division (SBSE)Internal Revenue Service – Tax Exempt and Government Entities Division (TEGE)IRS-CI Lead Development Center (Garden City)National Credit Union Administration (NCUA)National Indian Gaming CommissionNational Security Council (NSC)Office of the Comptroller of the Currency (OCC)Office of Thrift Supervision (OTS)Organized Crime Drug Enforcement Task Force (OCDETF)Securities and Exchange Commission (SEC)Southwest Border Money Laundering and Financial Task Force (Arizona Department of Public Safety, ArizonaAttorney General’s Office)State Department Bureau of Economic and Business Affairs (EB)State Department Bureau of International Narcotics and Law Enforcement Affairs (INL)State Department Office of Terrorism Finance and Economic Sanctions PolicyState Department Office of the Coordinator for CounterterrorismTreasury Department Office of Domestic FinanceTreasury Department Office of Foreign Assets Control (OFAC)Treasury Department Office of the General CounselTreasury Department Office of Intelligence and Analysis (OIA-T)Treasury Department Office of International Affairs (IA)Treasury Department Office of Strategic PolicyTreasury Department Office of Tax PolicyTreasury Department Office of Terrorism and Financial Intelligence (TFI)Treasury Department Office of Terrorist Financing and Financial Crimes (TFFC)Treasury Executive Office for Asset Forfeiture (TEOAF)U.S. Attorney’s OfficeUnited States Postal Inspection ServiceUnited States Secret Service7
ANNEX 2National associations and self-regulatory organizationsAmerican Bankers AssociationAmerican Bar Association Corporate Laws CommitteeAmerican Bar Association Task Force on Gatekeeper Regulation and the ProfessionalAmerican Bar Association Task Section of Real Property, Probate and Trust LawAmerican Council of Life Insurers (ACLI)Conference of State Bank Supervisors (CSBS)Jewelers Vigilance Committee (JVC)Money Transmitters Regulators Association (MTRA)National Association of Insurance CommissionersNational Association of Securities DealersNational Futures AssociationNew York Stock ExchangeSecurities Industry AssociationState authoritiesArizona Department of Financial InstitutionsArizona Department of Public SafetyArizona Office of the Attorney GeneralCalifornia Department of InsuranceDelaware Department of FinanceDelaware Department of JusticeDelaware Secretary of State, Division of CorporationsDelaware Office of Disciplinary Counsel, Delaware Supreme CourtDelaware State Bank CommissionFlorida Department of Law Enforcement, Money Laundering Strike ForceFlorida State Office of Financial Regulation, Financial Services CommissionFlorida State Prosecutors OfficeGila River Indian Community Gaming CommissionNevada Gaming CommissionNevada Secretary of State, Corporations DivisionNew Jersey State Gaming CommissionNew York Charities Board (Attorney General’s Office)New York County District Attorney’s OfficeNew York High Intensity Financial Crimes Area (HIFCA) – El Dorado Task ForceNew York Police DepartmentNew York State Banking DepartmentNew York State PoliceQueen’s District Attorney’s OfficePrivate sector representativesDelaware lawyers, and trust and company formation agents (Corporation Service Company; Morris Nichols Arsht& Tunnell LLP; Richards, Layton & Finger P.A.; Steptoe & Johnson, LLP; Venable LLP; Wilmington TrustCompany; Young Conaway Stargatt & Taylor, LLP), Delaware State Bar AssociationBanco PopularBank of AmericaBorgota Hotel CasinoCaesars Palace CasinoCitigroupDolexGirosolGoldman SachsLionel Sawyer & Collins (Nevada Trust and Company Service Providers)8
ANNEX 2MastercardMGM Grand HotelSecurities Industry Association (SIA) (Barclays Capital, Citigroup, Goldman Sachs, JP Morgan Chase, LehmanBrothers, Merrill Lynch, Morgan Stanley, Prudential Equity Group, Schulte Roth & Zabel LLP, UBS)United Commercial BankWestern UnionWild Horse Pass Casino9
ANNEX 3KEY LAWS, REGULATIONS AND OTHER MEASURES18 U.S.C. § 1956. Laundering of monetary instruments.(a)(1) Whoever, knowing that the property involved in a financial transaction represents the proceeds of someform of unlawful activity, conducts or attempts to conduct such a financial transaction which in fact involves theproceeds of specified unlawful activity—(A)(i) with the intent to promote the carrying on of specified unlawful activity; or (ii) with intent to engagein conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986; or(B) knowing that the transaction is designed in whole or in part—(i) to conceal or disguise the nature, thelocation, the source, the ownership, or the control of the proceeds of specified unlawful activity; or (ii) toavoid a transaction reporting requirement under State or Federal law, shall be sentenced to a fine of notmore than 500,000 or twice the value of the property involved in the transaction, whichever is greater, orimprisonment for not more than twenty years, or both.(2) Whoever transports, transmits, or transfers, or attempts to transport, transmit, or transfer a monetaryinstrument or funds from a place in the United States to or through a place outside the United States or to aplace in the United States from or through a place outside the United States—(A) with the intent to promote the carrying on of specified unlawful activity; or(B) knowing that the monetary instrument or funds involved in the transportation, transmission, or transferrepresent the proceeds of some form of unlawful activity and knowing that such transportation,transmission, or transfer is designed in whole or in part—(i) to conceal or disguise the nature, thelocation, the source, the ownership, or the control of the proceeds of specified unlawful activity; or (ii) toavoid a transaction reporting requirement under State or Federal law, shall be sentenced to a fine of notmore than 500,000 or twice the value of the monetary instrument or funds involved in the transportation,transmission, or transfer whichever is greater, or imprisonment for not more than twenty years, or both.For the purpose of the offense described in subparagraph (B), the defendant’s knowledge may beestablished by proof that a law enforcement officer represented the matter specified in subparagraph (B)as true, and the defendant’s subsequent statements or actions indicate that the defendant believed suchrepresentations to be true.(3) Whoever, with the intent—(A) to promote the carrying on of specified unlawful activity; (B) to conceal ordisguise the nature, location, source, ownership, or control of property believed to be the proceeds of specifiedunlawful activity; or (C) to avoid a transaction reporting requirement under State or Federal law, conducts orattempts to conduct a financial transaction involving property represented to be the proceeds of specifiedunlawful activity, or property used to conduct or facilitate specified unlawful activity, shall be fined under thistitle or imprisoned for not more than 20 years, or both. For purposes of this paragraph and paragraph (2), theterm “represented” means any representation made by a law enforcement officer or by another person at thedirection of, or with the approval of, a Federal official authorized to investigate or prosecute violations of thissection.(b) Penalties.—(1) In general.—Whoever conducts or attempts to conduct a transaction described in subsection (a)(1) or(a)(3), or section 1957, or a transportation, transmission, or transfer described in subsection (a)(2), is liable tothe United States for a civil penalty of not more than the greater of—(A) the value of the property, funds, ormonetary instruments involved in the transaction; or (B) 10,000.(2) Jurisdiction over foreign persons.—For purposes of adjudicating an action filed or enforcing a penaltyordered under this section, the district courts shall have jurisdiction over any foreign person, including anyfinancial institution authorized under the laws of a foreign country, against whom the
OFDT Office of the Federal Detention Trustee OIA Office of International Affairs (DOJ) OIA-T Office of Intelligence and Analysis (Treasury) OIG Office of the Inspector General OJP Office of Justice Programs ONDCP Office of National Drug Control Policy (NSC) OTC Over th
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WORKED EXAMPLES Task 1: Sum of the digits Task 2: Decimal number line Task 3: Rounding money Task 4: Rounding puzzles Task 5: Negatives on a number line Task 6: Number sequences Task 7: More, less, equal Task 8: Four number sentences Task 9: Subtraction number sentences Task 10: Missing digits addition Task 11: Missing digits subtraction
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