Under the Annunzio-Wylie Act, the U.S. Treasury is authorized to require financial institutions to adopt anti-money laundering programs that include: (a) internal policies, procedures, and controls; (b) designation of a compliance officer; - continuation of an ongoing employee training program; and (d) an independent audit function to test the adequacy of the program.

Source: Zagaris, 1999, p. 1023.

Therefore, building a case against sophisticated money-laundering schemes begins with recognizing when a violation of one more of the controlling laws have been violated, and understanding which law enforcement organization is the most appropriate for handling it and these issues are discussed further below.

How a Case is Built against Money Launderers.

While any of the foregoing current laws could be used in building a case against money laundering operations, the Money Laundering Control Act's ("the Act") expanded definition of "money laundering" activities has provided investigators with the ability to reach the...
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