RESOURCE MATERIAL SERIES No. 58

GROUP 3CURRENT SITUATION, PROBLEMS AND SOLUTIONS FOR
SPECIAL INVESTIGATIVE TOOLS IN COMBATING MONEY
LAUNDERING
Chairperson
Co-Chairperson
Rapporteur
Co-Rapporteur
Members

Visiting Expert
Advisors

Mr. Ahmed Nasim
Mr. Takashi Itoyama
Ms. Ronel Van Wyk
Mr. Saidi Ally Mwema
Mr. Soeparno Adi Soeryo
Mr. Mitsuru Nishikori
Mr. Pisan Mookjang
Mr. Peter H Wilkitzki
Director Mikinao Kitada
Prof. Hiroshi Iitsuka
Prof. Hiroshi Tsutomi

I. INTRODUCTION
Money laundering, which briefly means“making dirty money look clean”, occurs inevery crime where there is a financial
motive. The problem of laundering money
derived from illicit trafficking in drugs, aswell as other serious crimes, has become a
global threat to the integrity, reliability andstability of financial and trade systems andeven government structures. This growing
threat requires countermeasures by theinternational community as a whole, inorder to deny safe havens to criminals andtheir illicit proceeds. The proceeds of crime,
particularly cash, are laundered forreinvestment. This involves a series ofcomplicated financial transactions i.e. wiretransfers, purchase of money orders or
cashiers cheques, underground banking
etc, which ultimately results in criminal
money become “clean” and accepted for
legitimate business purposes.
Over the past few years, we havewitnessed the benefits of industrializationand globalization of transport and466(Pakistan)(Japan)(South Africa)(Tanzania)(Indonesia)(Japan)(Thailand)(Germany)(UNAFEI)(UNAFEI)(UNAFEI)

communication. However, on the negativeside we see criminals crossing borders withan ease unknown in the past and are
expanding their area of criminal activity
and become ever more intelligent andorganized. To meet the threats posed bydomestic and transnational organizedcrime and to enhance law enforcement’s
ability to succeed in combating money
laundering, we need national andinternational combined efforts.
It may also be noted that the newly
emerging forms of multilateral cooperation
among law enforcement agencies is, on the
one hand, necessitated by globalization ofcrime, but, on the other hand, it encountersproblems due to the insufficiency of laws
and regulations which would enable fuller
application of modern technology as an
instrument of special investigation
techniques.1
In proving money laundering offences it
is important to prove the link between themoney laundering offence and the fact thatthe criminal was aware that the proceeds

117TH INTERNATIONAL SEMINARREPORTS OF THE COURSE
had been obtained illegally. Through thecontinuous surveillance of these offences
we will also be able to effectively
investigate and prove the money
laundering offences.
In this paper we intent to examine thethree special investigation techniques
namely (i) controlled delivery (ii) electronic
surveillance (wiretapping etc.); and (iii)
undercover operations as effective weapons
in combating money laundering. In thisregard our discussion will cover a brief
analysis of each of the three investigativetechniques. We shall also explore the legal
framework and identify current problems
encountered in the use of these tools in
facilitating the investigation of money
laundering. Finally, we shall recommend
albeit briefly, the use of the above
mentioned investigation techniques andcall for change of provisions of domestic
laws.
II. CONTROLLED DELIVERY
A. Introduction
In terms of Article 2(i) of the United
Nations Convention Against Transnational
Organized Crime, controlled delivery shallmean the technique of allowing an illicit
or suspect consignment to pass out of,through or into the territory of one or morestates, with the knowledge and under thesupervision of their competent authorities
with a view to the investigation of an
offence and the identification of persons
involved in the commission of the offence.2
This is done for the purpose of furthering
the investigation of an offence and thepossible identification of persons involvedin the commission of the offence.

It is an investigative technique which
has been known for years as aninternationally and domestically accepted
method for the monitoring and thecombating of crimes including money
laundering and predicate offences such as
drug trafficking, illegal firearms,
smuggling, stolen motor vehicle etc.
There are two methods of controlled
delivery namely live control delivery andclean controlled delivery. If the illegal
goods or surrogates, at least in part, arriveat their final destination it is called live
control delivery. Where the circumstancesof the detection and concealment are as
such, that it is possible to remove all ormost of the illegal goods and substitutecounterfeit illegal goods before allowing theconsignment to proceeds, a clean controlled
delivery can be made. If the finaldestination of the consignment is within
the frontiers of the country in which theinitial detection occurred, “Internal
Controlled Delivery” is possible. If theintended final destination of theconsignment is in a country other than that
where the initial detection was made, thereis the potential for an “External Controlled
Delivery”.3
An example of a clean control delivery
in a money laundering investigation canbe found in ‘Operation Mule Train’, an
undercover operation which was conductedin the United states. On July 1, 1998, theChief Financial Officer, President, and Vice
President of Supermail International, Inc.,cheque cashing company, were arrested on
money laundering charges stemming froma two-year investigation conducted by theLos Angeles office of the FBI and the Los
Angeles Police Department. According tocorporate filings, the company was one of1

Statement of Slawomir Redo at the Central Asian
Seminar on TOC, 22-23 March 2000.
2 Art 2 of the UN Convention against Transnational
Organized Crime: September 2000

3

PD Curring: The technique of controlled delivery
as a weapon in dealing with illicit traffic in narcotic
dugs and psychotropic substance: 2000/06/07/

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RESOURCE MATERIAL SERIES No. 58
the largest cheque enterprises operating in
the western U.S., and purported to be oneof the leading U.S. money transfers agents
providing services to Mexico and Latin
America. It was considered a significant
and growing company among theincreasing number of independent nonbank financial institutions operating inmany inner-city neighborhoods wherebanks have reduced their presence.
The three executives, along with six
other employees and associates, werearrested after a federal grand jury returned
a 6 7 - c o u n t i n d i c t m e n t a g a i n s t 11
defendants, including the Supermail
corporation, charging multiple
conspiracies, money laundering, evading
currency reporting requirements, aiding
and abetting, and criminal forfeiture. The
initial target of the investigation was acompany store in Reseda, California.
Investigators, working in an undercovercapacity, approached the manager, who
agreed to launder “drug” money inexchange for a cash fee. The undercover
officers then delivered cash which herepresented to be drug proceeds to the
managers and he converted the cash intomoney orders issued by the company. As
larger sums were launched, the manager
sought the assistance of his associates
working at other store locations. When a
new manager took over operations at the
Reseda store in April 1997, he brought inthe company’s corporate officers, including
the CEO, the President and the Senior Vice
President. Pocketing the cash fee, thecorporate officers authorized the issuanceof money orders and the wire transfers oflarge sums of “drug” money to a secret bankaccount in Miami, Florida while the cash
was used to maintain operations at thecompany stores.
To avoid detection by law enforcement,
no Suspicious Activity Reports (SAR) formsof Currency Transaction Reports (CTR)

468

were filed by the company for any of thesetransactions; however, SAR forms and
CTR’S were filed by the banks into which
the cash deposits were made, and thesefiling significantly enhanced the value ofother information received. In total, thedefendants laundered over $3.2 million
dollars of “drug” money. The investigation
is believed to be one of the largest money
laundering “sting” operations targeting acheque cashing business in U.S. history.4
B. Common Issues and Problems
In many countries the controlled
delivery technique is used as a method for
conducting criminal investigation but there
is no specific legal authorization provided
in the domestic laws. In those countries,
controlled delivery operations are
conducted in accordance withdepartmental guidelines in the relevant
law enforcement agency i.e. police,prosecutors, customs etc. These authorities
have employed the technique mainly in thefight against money laundering, drugtrafficking, illegal firearms, stolen
properties trafficking and humantrafficking. However, as criminals employ
modern technologies to assist in theircriminal activities, there is a need to enact
new laws which allow law enforcement to
use the same modern technologies in theirinvestigative techniques.
Due to the economic and technological
gap between developed and developing
countries, there is often a lack of resources
such as skilled personnel and modern
investigation equipment for evidencecollection. This, in a way, affects the efforts
made in combating money laundering.
Certainly combating money laundering
requires resources both physical andhuman. Controlled delivery as an effective
investigative tool is being used in many
4

Susan L Smith: Money Laundering: Trends andTechniques: February 2, 2001

117TH INTERNATIONAL SEMINARREPORTS OF THE COURSE
countries. However, law enforcement
agencies are reluctant to reveal their useof this investigative technique as not to tip
off criminals.

(4) In case there will be need for external
control delivery there are additional
factors which will have to beconsidered including:

C. Proposed Solutions
Money laundering and other predicate
offences such as drug trafficking, fire arms
smuggling, corruption, fraud, extortion etc.
are extremely difficult to detect. It,
therefore, requires not only a high level ofskill, professionalism, team work andcooperation, but also as an special
investigative technique. In this regard, thefollowing points may be considered in acontrolled delivery operation :(i)The legal provisions in force inthe detecting country and thecountry of destination.

(ii) Whether there is sufficient time
to develop an acceptable action
plan between the law
enforcement agencies in thedetecting country and thecountry of destination.
(iii) Whether the authorities in the
country of destination are able tolaunch an operation given theidentification and detection
principles.5(1) Those controlling the operation must
make sure the information does notleak as premature publicity willrender controlled delivery operation
useless.

II. ELECTRONIC SURVEILLANCE(2) Whenever possible, removal of illegal
goods such as drugs, firearms etc
should be made and a harmless
substance substituted. It should be
noted that “clean controlled delivery”
eliminates not only the risk of illegal
goods being lost but also gives greater
freedom in organizing surveillance
and reduces the risk of alarming thecriminals who may have arranged
counter surveillance.
(3) T h e u l t i m a t e d e l i v e r y o f t h econsignment should be made with thecooperation of the firm that would
normally make such a delivery. A law
enforcement officer posing as adriver’s assistant should travel withthe delivery vehicle which should bemonitored by other operation teammembers who will take the necessary
evidence such as fingerprints,
photographs etc.

A. Introduction
Criminal investigations are becoming
increasingly more difficult as criminals use
advanced technologies and moresophisticated methods to commit theircrimes. In order for investigators to keep
pace, they must use sophisticatedinvestigative techniques. One extremely
successful technique has been electronic
surveillance, both silent video surveillance
and interception of wire, be it oral orelectronic communication. In fact,
recording criminals talking about theircrimes in their own voice not only helps toprove a case against them but also enables
law enforcement authorities to learn ofconspirator’s plans to commit crime and lay
a trap to prevent the occurrence of violent
crimes.
Electronic surveillance can be defined
simply as the interception of oral or
5

See Footnote 3, supra P4

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RESOURCE MATERIAL SERIES No. 58
electronic communication through wire,
telephone, computer etc. in order to listen
and record information by using technicalmeans. Electronic surveillance caneffectively be used in cases such as money
laundering, drug trafficking and extortion.

not to divulge information assuming any
information will be given to law
enforcement authorities. From theforegoing, it would appear that the court
will issue a warrant after evaluating thefollowing points:

B. Common Issues and Problems
The major problem in the use of thistechnique is the need to strike a balance
between the investigation of the criminal
activity and the constitutional rights of theindividual i.e. a persons’ reasonable
expectation of privacy. In an effort to strikesuch balance the domestic legislation ofvarious countries prohibits any
unauthorized electronic surveillance.
H o w e v e r, t h e r e a r e e s t a b l i s h e drequirements for obtaining authority tomake such interceptions. A warrant
authorizing electronic surveillance of oral,
wire- and electronic communications aswell as silent video can only be issued by ajudge. For example in the United States,
law enforcement officers are required toconfine their surveillance to only relevant
conversations or activities, specify thelength of time the technique will be usedand certify that normal investigativetechniques have either been tried andfailed or are reasonably unable to succeed,or too dangerous to attempt.
In other words, before obtaining aninterception warrant, law enforcement
officers are required to exhaust normal/
traditional investigation techniques unlesssuch techniques will alert the criminal of
an investigation. Another traditional
method is to search a person’s home under
the authority of a search warrant while theowner is present, but again it is notnecessarily true that criminals will hide or
keep valuable information of their criminal
activities in their homes. Even if the law
enforcement officers use an informer orundercover officer, the target can choose

470

(i)

Traditional/normal investigativetechniques have been tried andfailed,(ii)

Tr a d i t i o n a l i n v e s t i g a t i v etechniques are reasonably likely tofail, or(iii) T r a d i t i o n a l i n v e s t i g a t i v etechniques are too dangerous to
try.6
C. Proposed Solutions
While we see electronic surveillance isan effective investigative tool as thecriminals are not aware that their words
or actions are being recorded by law
enforcement agencies because of its
extraordinary invasiveness, the use ofelectronic surveillance should be limited toonly those times when it is necessary. The
necessary requirements can be shown if
investigators can satisfy the court thattraditional investigation techniques havebeen tried and failed and can explain howeach traditional technique i.e.
interrogation, physical surveillance, search
warrants etc. would be futile or dangerous
in their particular investigations.
Certainly, as electronic surveillance can be
conducted across border, the necessity of
having multilateral and bilateralagreements between member states cannot
be ignored.
In analyzing the use of electronic
surveillance among the participating
countries, there are countries, which have,6

T D Colbridge : Electronic surveillance. A matterof necessity: February 2000

117TH INTERNATIONAL SEMINARREPORTS OF THE COURSE
and those which have no legal provisions
governing electronics surveillance. For
example, Germany, 7 Japan, Pakistan,South Africa and the United States ofAmerica South Africa etc, have laws
concerning interception of communications
for the purpose of criminal investigation.
However, there are countries that do nothave legislation but still use the technique
as a criminal investigation tool.
Lastly it should be noted that as money
laundering offences are more likely to be
cross-border crimes there should beinternational cooperation in the use ofelectronic surveillance just as it is true forother special investigative techniques. A
minimum requirement for theadmissibility of cross-border surveillanceshould be that the conditions for applying
the methods are met under the law of either
State.
III. UNDERCOVER OPERATIONS
A. Introduction
Money laundering takes place in a
myriad of ways. A small-time criminal
might launder stolen money by purchasing
a valuable item in one country and selling
it at a later stage in another country. A
criminal with more funds to wash andcriminal organizations whose activities
generate large amounts of illicit profits
cannot rely with safety on one launderingtransaction only. They usually require amore complex money laundering scheme
which might utilize shell companies andan intricate web of international financialtransactions.
The methods used by criminals in theirtrade, whether it is narcotics, organizedcrime, money laundering etc., have become
more advanced and are sometimes
7

German Code on Criminal Procedure: Guidelines
set by the Prosecutions Service

extremely complex and difficult to detect.
Undercover policing is proving to be one of
the most successful investigative tools incombating money laundering. The use ofundercover investigative techniques
requires extensive planning, preparationand handling. This investigative techniquealso imposes heavy demands on police
officers on a professional as well as ethicallevel. They are faced with certain problems
which are not encountered in any othertype of enforcement activity. Undercoverwork is a useful technique for obtaining
information regarding the activities ofcriminal elements. The information
obtained is virtually indispensable in thedevelopment of intelligence that leads tothe identification, arrest and conviction of
offenders and recovery of stolen property,
and is also one of the most effective meansof detecting or preventing criminal activity.
An undercover operation is a method ofinvestigation where substantial
information and evidence on money
laundering activities are gathered over a
period of time, involving the use of lawful
measures by law enforcement and by using
undercover agents to obtain suchinformation and evidence.
Law enforcement agencies rely on theseundercover agents to infiltrate criminalorganizations to gather information to
dismantle them. Undercover assignments
come in many varieties. They include
everything from short-term, buy-bustscenarios to longer-term investigations
lasting months or years. There are twodimensions within undercover operations.
One being the utilization of a confidential
informant who provides insight andinformation concerning the activities ofcriminals, and the other is the utilizationof undercover police officers (agents) thatassume a different identity in order toobtain information and evidence. These
two dimensions are normally used

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RESOURCE MATERIAL SERIES No. 58
simultaneously in an effort to address thethreat effectively.
Undercover operations conducted in aproper manner are very expensive and insome instances, can be a controversial
investigative method. It is furthermore adangerous investigative technique which
may involve innocent members of the
public. Proper measures should therefore
be put into place in respect of the sensitivityof the information, the involvement of the
public, the security of the agent(s) and theinformant and the evidence gathered
during the operation.
A good example of a successful
undercover operation with regard to money
laundering is ‘Operation Casablanca’. The
United States Customs Service concluded
the operation in May 1998. It was thelargest, most comprehensive andsignificant drug money laundering case in
the history of the United State law
enforcement. This undercover money
laundering investigation resulted in the
seizure of more than $98 million in cashfrom drug traffickers, more than 4 tons ofmarijuana and two tons of cocaine. The
indictment, which was issued in UnitedState District court in Los Angeles, charged
26 Mexican bank officials and three
Mexican Banks, CONFIA, SERFIN, andBANCOMER with laundering drug money.
Additional, bankers from two Venezuelan
banks, BANCO INDUSTRIAL DE
VENEZUELA and BANCO DEL CARIBE
were charged in the money laundering
scheme. In ‘Operation Casablanca’,undercover agents were introduced tofinancial managers from drug cartels, andthey obtained contracts to “pick up” drug
proceeds on the streets of major UnitedStates cities. The agents were later
introduced to Mexican bankers who openedbank accounts for them. Funds that were
“picked up” were transported back to Los
Angeles, California where it was deposited472

in United State Customs Servicescontrolled undercover bank accounts.
Funds were then wire transferred toaccounts opened by the Mexican banking
officials. After taking out their commission,
the officials then issued Mexican bankdrafts drawn on the U.S. accounts of the
Mexican banks. These bank drafts weredelivered back to the undercover agents in
the U.S. either in person or via courier.
The funds were then disbursed at thedirection of the money launderers.
Court orders were obtained allowing forthe seizure of the total amount of drugmoney laundered through the accounts andthe amount of commissions paid to thebankers. Because the Mexican bank drafts
were drawn on the U.S. accounts of the
Mexican banks, court orders were obtained
allowing for the seizure of theaforementioned funds from those U.S.
accounts. As a result of the investigation,
BANCOMER and SERFIN each pled guilty
to criminal money laundering violations
and together forfeited a total of $16 million
to the government. Each bank was also
fined $500,000. CONFIA settled theindictment with a civil plea and forfeited$12 million.
Twenty individuals, including 12
Mexican bankers and their associates, havepled guilty to money laundering and/or
drug smuggling charges. Three Mexican
bankers were convicted after a jury trial,
and three Mexican bankers were acquitted.
Three Venezuelan bankers were convicted
in December 1999 on money launderingcharges. An amount of $64 million of the$98 million originally seized during thisinvestigation has been forfeited to thegovernment of the United States.8
B. Common Issues and Problems
The most common problem thatcountries have to deal with is the questionof whether an undercover operation is

117TH INTERNATIONAL SEMINARREPORTS OF THE COURSE
justifiable and whether it has been
executed within the boundaries of the law.
Furthermore, the methods employedduring the operation should not infringeon the constitutional rights of the person(s)involved. The Supreme Court in the UnitedStates has long upheld the validity ofundercover and reverse sting operations aslong as outrageous governmental conduct
is avoided. Four factors can be considered
in determining whether outrageous
conduct exists: (i) the need for the type of
conduct in relationship to the criminal
activity; (ii) the preexistence of the criminal
enterprise; (iii) the level of discretion orcontrol of the criminal enterprise by thegovernment; and (iv) the impact of thegovernment activity creating thecommission of the criminal activity.9

Another issue which is the subject of alegal debate is the question of the role ofthe undercover agent. Instead ofpreventing crime there is some possibility
that a police agent may further andfacilitate the commitment of crime. In
money laundering cases, the agent has toparticipate. The involvement of the agent
in this case is not a question of committing
the offence, but of intent. The agent does
not help the money laundering offence, but
he rather assists in preventing further
crimes. A line should be drawn between
the legal participation of an undercoveragent in illegal activities and the legal
inducement of a crime during theoperation. The courts of the countries
should in terms of their own legal
frameworks deal with this matter.

Additionally it is important that anundercover operation be approved andmonitored. The approval must require
written documentation, stating supporting
facts and circumstances, that: (i) initiationof investigative activity regarding thealleged criminal conduct or enterprise iswarranted under applicable departmental
guidelines; (ii) the proposed undercover
operation appears to be an effective meansof obtaining evidence or necessary
information; (iii) the undercover operation
will be conducted with minimal intrusionconsistent with the need to collect theevidence or information in a timely andeffective manner; (iv) approval for the useof an informant or confidential source has
been obtained as required by Attorney
Generals or National Public Prosecutors;and (v) any foreseeable participation by anundercover employee in illegal activities isjustified.10

Undercover operations as a method ofinvestigation have proved successful in the
United States and in other countries. The
participating countries have also
acknowledged the importance of theseinvestigative techniques. A majority of thecountries represented have employed thetechnique of undercover operations forinvestigating crimes which include drug
and firearms trafficking, money
laundering, stolen properties, woman
trafficking etc. Japan (for narcotics andfirearms trafficking only) and Malaysia
have some special laws or regulations
pertaining to conducting undercover
operations.

8

Susan L Smith: The Fight against Money
Laundering: The U.S. Perspective: February, 1
2000
9 William P Schaefer: Combating organized crime: thelegislative and regulatory framework

The German Code on Criminal
Procedure makes provision for the use ofundercover investigators where there issufficient factual indications showing thata criminal offence of considerable
importance has been committed and ifclearing up this using other means would
offer no prospects of success or be much
10 US Attorney General Guidelines on FBI UndercoverOperations Revised: 11/13/93

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RESOURCE MATERIAL SERIES No. 58
more difficult. Some problems with
undercover agents and the due process
requirements have led to stringent court
practice concerning the sentencing ofoffenders that have been induced byundercover agents to commit the offence,but not to a broad questioning of the tactic
itself. In the United States and in manyother countries the use of this method ofinvestigation is not regulated by law but isconsidered a valuable investigative tool.
Countries should not permit undercover
operations where agents are required tocommit violent acts. In cases where thiscannot be avoided, necessary measures
should be taken to prevent the violencefrom occurring. Countries should, however,consider the regulation of investigativetechniques such as undercover operations,by law in day to day judicial practice.
Law enforcement agencies often find it
necessary to use information provided byindividuals of less than sterling characterand reputation, who live and function
within the criminal element itself.
Although a multitude of factors may
motivate these individuals to provide
information to the police, the use of
informants remains one of law
enforcement’s oldest and most essential
investigative tools. The rights andobligations of the informant should beprotected and an assurance ofconfidentiality should be given. Proper
records on informants should bemaintained and the identity of each
informant should be concealed.
Informants should have an explicit
understanding of what they may and may
not do while working for a law enforcement
agency. By granting limited and specificauthority, law enforcement agencies caneffectively control the activities of theinformant. It, however, often becomes
necessary for informants to visit locations

474

where criminal activities, such as thebuying and selling of narcotics takes place,where they are subjected to arrests by otheragencies and prosecuted for the offences.
The officer in charge of the informant
should therefore effectively control theactivities of the informant and times should
be limited where informants can become
involved in such activities.
C. Proposed Solutions
In this regard countries should consider
and adopt the recommendations made by
the United Nations to create an obligation
under international law to criminalize
money laundering. Article 4 of the Councilof Europe Convention on Laundering,
Search and Seizure and Confiscation of theProceeds of Crime (1990) refers to special
investigative powers and techniques. It
places an obligation on the member states
to consider adopting legislative and othermeasures as may be necessary to enable it
to use special investigative techniques.
The approach of courts when presenting
evidence, which was obtained during
undercover operations, is very important.
Courts must recognize the importance of
not disclosing certain information on the
persons involved and the techniques used.
The disclosure of this information can leadto the endangerment of the lives of law
enforcement officers, the persons who allow
their properties to be used and will reveal
the methods used during undercover
operations, thus making it difficult to use
the methods in the future.
In terms of article 14 of the Convention
on Mutual Assistance in Criminal Matters
between the Members States of theEuropean Union (2000), member countries
may agree to assist one another in the
conduct of investigations into crime by
officers acting covertly or with a false
identity.

117TH INTERNATIONAL SEMINARREPORTS OF THE COURSE
IV. CONCLUSION
It is our considered view that special
investigative techniques such as controlled
delivery, electronic surveillance andundercover operation should be included
in domestic laws with a view ofstrengthening enforcement of money
laundering laws and to intensify law
enforcement efforts in detecting money
launderers and prosecute them. Thisaction will, however, not eradicate
traditional investigation techniques but
will supplement detection efforts.
As global communications and world
trade agreements are increasing due totechnological development, the ability toinvestigate money laundering cases issomething that will continue to challenge
law enforcement officers for the foreseeable
future. It is therefore, important that as
criminals employ modern technologies toassist their criminal activities, there is aneed to enact new laws which allow law
enforcement agencies to use such modern
technologies in their investigating
techniques.
Money laundering techniques will makeprogress as technology advances. We
should make joint efforts worldwide toestablish anti-money laundering laws andsystems. We must also combat money
laundering through training and exchange
of information among countries.
Additionally, each country should continue
to work closely with its international
partners in bilateral and multilateralassistance agreements to promote further
actions to effectively address money
laundering and other criminal activities
and to win the fight against money
laundering.

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