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On May 3, 2007, the US Departments of Treasury, Justice and Homeland Security issued the 2007 National Money Laundering Strategy (NMLS). The NMLS sets several sweeping goals to further the United States AML efforts. It was developed in response to the December 2005 interagency Money Laundering Threat Assessment, which analyzed 13 different money laundering methods ranging from long-used techniques such as smuggling of bulk cash to newer methods such as use of stored value cards which are used by consumers for legitimate reasons and criminals for illegal activities.

The NMLS identifies nine goals:

• Continue to Safeguard the Banking System
  
• Enhance Financial Transparency in Money Services Businesses
  
• Stem the Flow of Illicit Bulk Cash out of the United States
  
• Attack Trade-Based Money Laundering at Home and Abroad
  
• Promote Transparency in the Ownership of Legal Entities
  
• Examine Anti-Money Laundering Regulatory Oversight and Enforcement at Casinos
  
• Implement and Enforce Anti-Money Laundering Regulations for the Insurance Industry
  
• Support Global Anti-Money Laundering Capacity Building and Enforcement Efforts
  
• Improve How We Measure Our Progress

Each of the goals is accompanied by a discussion of threats and underlying vulnerabilities showing a need for the goal, as well as specific strategies and action items needed to achieve it. Many of the strategies and action items focus on improved outreach to the financial community, increased information-sharing among federal, state and international regulators and law enforcement, more sophisticated analysis of information derived from AML regulatory filings and investigations, additional regulation where necessary to combat new methods of money laundering and a more effective means of measuring the progress the United States has made in its AML programs.

The NMLS, which includes a copy of the 2005 Threat Assessment, may be accessed here (PDF).

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© 2007 White & Case LLP