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Central Bank Lien
In January 2019, the United States Department of State removed control of financial assets in the United States owned by the Venezuelan government and handed it to the Venezuelan opposition leader, Juan Guaidó. With the stroke of a pen, Secretary of State Mike Pompeo invoked Section 25B of the Federal Reserve Act, certifying the authority of Guaidó over “certain property in accounts of the Government of Venezuela or Central Bank of Venezuela held by the Federal Reserve Bank of New York or any other U.S. insured banks”.
Both the volume and value of international trade are enormous. The number of products, importers, exporters, logistics companies and middlemen are unquantifiable. Professional money launderers manipulate these variables to camouflage their proceeds of crime while transferring value across borders. Given this complexity, how can regulators write effective rules to govern trade-based money laundering (TBML) risks within financial institutions?