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A "cop book" bankers should absorb

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  • Written by  Holly A. Ford
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  • Comments:   DISQUS_COMMENTS
On the Trail of Terror Finance: What Law Enforcement and Intelligence Officers Need to Know, by John Cassara and Avi Jorisch, Red Cell IG, 272 pp., 2010 On the Trail of Terror Finance: What Law Enforcement and Intelligence Officers Need to Know, by John Cassara and Avi Jorisch, Red Cell IG, 272 pp., 2010
After hearing the title On the Trail of Terror Finance: What Law Enforcement and Intelligence Officers Need to Know, I wondered why a banker was asked to read it. I thought that a law enforcement agent would be better equipped to do so. After reading the book, however, I realize that it has been written thoughtfully to engage anyone with an interest in learning more about money laundering, related financial crimes, and the global relationship to terrorist plots.

As the book jacket tells the reader, “Money is the lifeblood of terrorism.” Whether you’re law enforcement, a banker, or simply an American patriot still angry over 9/11, it is our duty to understand this dark side of the world. Books like these educate us. And with that knowledge comes the power to make our world a safer place for everyone.

The authors, John Cassara and Avi Jorisch, have presented the information in a textbook format and their backgrounds qualify them as teachers. Cassara is a former federal agent, including service in the CIA, FinCEN, and investigatory branches of the Treasury Department. Jorisch is a noted counter-terrorism advisor and a former consultant to Treasury on these issues.

The book is perfect for training purposes. Each chapter describes the content, provides case studies and definitions, and ends with a “cheat sheet” so the reader can review the highlights of each chapter. If you, like me, have the responsibility of teaching your staff or others about these issues, the book can be used as a tool for creating your classroom curriculum and testing. Having said that, the book is also an interesting “read read.”

Effective text that sticks

I’ve spent the last 30 years in banking, the last 12 focused on risk management issues such as consumer protection compliance, money laundering, information security, and fraud. So I know that ongoing education is a must and this book didn’t let me down. While some bankers may find it directed to law enforcement, I made several notes to address various issues and red flags for my bank’s own Bank Secrecy Act program.

I am also a firm believer of case studies. If the reader can relate to actual cases, they will retain and apply the information much better than if it’s presented in the abstract. The book provides various real-life examples and actual case studies throughout each chapter.

I’ve always wondered how law enforcement comes up with the names of their task force investigations. Case studies like “Operation Dragon” about drug trafficking and bulk cash smuggling, where $207 million was seized in Mexico City in March of 2007, made me wonder how the name related. Then I learned that the head of the criminal organization was from Shanghai. Or maybe….Was 2007 the Year of the Dragon?

Education for law enforcement partners

As the title would indicate, this book is targeted to law enforcement, and if you’re a rookie with the FBI, Drug Enforcement Administration (DEA), or Immigration and Customs Enforcement (ICE), I suggest you pick up this book.

Not only will you get some insight into the banking business and how money moves globally in these situations, the authors provide sample questions for interviewing businesses, such as gold dealers and hawalas. The questions can help to determine their legitimacy and identify possible red flags to terrorist financing or other criminal activity.

(Oh, by the way, in case you were wondering, “Hawala” is not a new dance step; it’s an alternative financial system common in some cultures that lends itself to bartering and anonymity, making money laundering much harder to detect.)

Tips, tricks, and travesties

On the Trail of Terror Finance offers practical tips and warnings. Some of them include:

• Charity charlatans.
For those average folks looking for a new charitable entity to give hard-earned dollars to…beware! Some innocent-sounding groups have been tied to Al Qaeda and other terrorist organizations. Read the chapter on charities and Zakat (Islamic law on charitable giving) and then do your homework before donations are made.

• Prescriptions for terror. What about “boosters”? You thought that was just the club to support your kid’s sports team, right? Not so. These are organized rings who shoplift items such as over-the-counter medicines, baby formula, or film. They later traffic or resell it to dispatch funds for terrorist funding.

• Lowest crime of all--human trafficking. Darkest of all the illicit activities described in the book is human trafficking. “Snakehead,” subject of the relevant case study, is really an appropriate label.

I have two daughters who have travelled extensively, and as a mother I can’t think of anything more fearful to me than one or both of them being sold into slavery and trafficked somewhere in the world to be abused emotionally and physically for someone’s profit.

The story Cassara and Jorisch tell here is truly disturbing. People being sold into a world of debasement for the privilege of coming to America? To serve who? Corporations looking for a larger profit margin and consumers looking for a cheap deal on the latest trends set by reality stars who we didn't know 15 minutes ago.

I recommend this book, but I had one small pet peeve, regarding footnotes. They were not at the bottom of the page or even at the end of each chapter, but in a separate section at the back of the book. To me, that was a little annoying because I had to flip back and forth to get my answers. I also would have liked the chapter numbers to be listed on each page. I’m one of those control freaks who likes to know where they are at all times.

Postscript to Ponder:

Holly Ford was moved, after reading this book, to write this note to Congress:

Dear Congress:
Read this book. Educate yourself and then put forth legislation based on factual knowledge of what’s happened and what’s going on so that we have a fighting chance to deflate whatever is going to happen in the future. Please provide the tools and authorities that help law enforcement stop these crimes and horrors; and use your political power to reach out internationally to even the playing field. The legal inconsistencies between borders are probably the biggest challenge we face and must be leveled if we are to ever make significant headway against these terrorist and criminal organizations.
Sincerely,
Holly Ford


Holly Ford and former FBI senior official Dennis Lormel spoke at ABA’s 2010 Regulatory Compliance Conference on the subject of investigations. Read “Inside the bad guys’ heads,” from the digital edition of the October 2010 ABA Banking Journal, for coverage of their presentation.
  
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