At the threat of dragging the thread so off topic as to make one's head spin...
PIRA (not IRA) used cash generated principally in UK & Ireland through illegal means, e.g. extortion, drug running etc to fund most of its operations, like wise, money generated in North America was used for the illegal purchase of guns. Both the accumulation and spending of funds were small amount cash only affairs. On the occasion that a big ticket item was needed, it was either stolen or bought via a helpful local business, who then had it stolen. Clever huh. Money laundering was never really an effective method of pursuit of PIRA or any NI terrorist group for that matter.
Al Qaida and the 9/11 murders were of such a size that USA PATRIOT act of November basically lashed out everywhere,
for the purposes of this post it specifically required Anti Money Laundering legislation. It is, almost entirely, ineffective. There are exceptions of course, but I'll keep it general.
USA PATRIOT applies to us in Europe, not because of the EU, but because the US has an nasty habit of writing other countries laws for them. For example, it says, and I paraphrase "if you want to do banking business in the US, you have to obey our laws everywhere, not just in your NY office, but in every office you have in every country". This is something the US can do of course because the US is a country that makes a lot of foreign banks a lot of money. Occasionally, USA PATRIOT and Swiss (for example) domestic legislation is in conflict. At which point, you have to decide which law you wish to break and which prison you wish to stay in. Personally I favour breaking US laws and never visiting the US. For example, USA PATRIOT says "if you identify possible money laundering involving a US person, or USD (dollars) you have to report it to a US regulator (either the Federal Reserve Bank or the Comptroller of the Currency) however if you are a Swiss Bank, with, say, a Danish customer, who is POSSIBLY laundering Euro's but wants, say US Dollars then Swiss Law says you don't report it to the EBK (Swiss regulator) and of course normal banking secrecy law applies so you cannot tell the Yanks = JAIL TIME! I had a good 2 hour meeting with
this lady about it in Bern, and then 6 bottles of wine (not with her, with a relevent VIP).
I could, if paid enough, tell you a lot more about USA PATRIOT irrelevance, political infighting, implementation, results and failures. But its probably not interesting for you so I won't. And much of it is illegal to share to non-relevant parties anyway. Suffice to say, the Hawala money broking system is largely beyond AML Legislation's touch and FWIW, the 9/11 terrorists used American Express and Western Union anyway. in 2005 a colleague caught AMEX sending Dollars to Iran, which is another story..
Where the legislation is very useful however, is drug money. For more on this very interesting legislation, check out the
FATF 40+9 recommendations. The website is very clear for the non-banking person. And in French also if that's preferable to English for you.
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