(1) educating companies on money laundering and how to prevent it; 

(2) requiring that all regulated companies comply with transaction reporting legislation and have appropriate polices and internal control procedures in place; and

(3) incorporating into compliance examinations and external audits as a mechanism to ensure that the above components are in place.

Pros: 

Regulatory approaches through proactive measures and considerable statutory powers, including civil and administrative sanctions

Cons:

Potential privacy concerns due to sensitive private information held by regulatory agencies

Provide more strategic intelligence, often from foreign sources, which will be critical to combating transnational crime. It can then detect more potential national security threats, will contribute to much needed multi-agency approach (i.e. Interpol, DEA, ATF all working together). If all can agencies can be on the same page it will complement the traditional (tactical) law enforcement operations to safely combat transnational crime.

Pros:

Law enforcement efforts greatly benefit from the private sector, which fills an important prevention and detection niche that can’t always be addressed by law enforcement

Cons:

There is often a reluctance by the private sector to dedicate appropriate resources; violent nature of organized crime may pose risks in such a partnership; organized crime may use internal conspiracies in private sector to capitalize on partnerships with law enforcement.

CJA/464

Shawn Cooper