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move their profits out of the country; and second, they will develop more and more complex schemes to launder their money. Our investigative techniques and our laws must stay one step ahead if we are to have any truly meaningful impact on the availability of drugs in this country.

Mr. Chairman, I appreciate this Subcommittee's interest in the role of money laundering in drug trafficking. I will be pleased to answer any questions you may have.

Thank you.

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On April 23, 1986, the Subcommittee on Financial Institutions Supervision, Regulation and Insurance will continue its hearings on proposals to protect against financial institutions becoming havens for tax evaders, drug traffickers and launderers of funds derived from criminal activity.

As the lead Federal agency in enforcing narcotics and controlled substances laws and regulations and whose primary responsibilities include investigation of major narcotics violators (interstate and international), your testimony would be extremely helpful to the Subcommittee in its efforts to better understand the devastating effects that drug trafficking and money laundering have on the economic and social fabric of this nation.

It is requested that you or your designee appear and testify before the Subcommittee on Wednesday, April 23, 1986, at 10:00 a.m., in Room 2128 Rayburn House Office Building.

Please provide the Subcommittee with 175 copies of your testimony no later than 24 hours in advance of your appearance. Please have your staff contact Earl F. Rieger, Counsel of the Full Committee staff, if there are any questions.

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Sincerely,

Fernand J.St Germain
Chairman

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On April 23, 1986, the Subcommittee on Financial Institutions Supervision, Regulation and Insurance will continue its hearings on proposals to protect against financial institutions becoming havens for tax evaders, drug traffickers and launderers of funds derived from criminal activity.

As part of these hearings, the Subcommittee will conduct
hearings on the several bills dealing with money laundering,
including the Administration's bill, HR 2785. The other
bills the Subcommittee intends to review are: HR 1367 (Mr.
McCollum), HR 1945 (Mr. Hubbard), HR 1474 (Mr. Hughes), HR
3892 (Mr. Wortley), HR 4280 (Mr. Torres), and HR 4573
(Mr. Pickle).

The Subcommittee would appreciate the Department's analysis of these various proposals, and it is requested that Mr. Stephen S. Trott, Assistant Attorney General for the Criminal Division, appear and testify before the Subcommittee to discuss these matters on April 23, 1986, at 10:00 a.m. in Room 2128 Rayburn House Office Building.

In addition to the bills mentioned above, there are four
titles of the Financial Institutions Regulatory and Interest
Rate Control Act of 1978 (FIRICA), also known as the Safe
Banking Act of 1978, which the Subcommittee intends to review
and which we feel may lend support to our efforts to fight
those criminals who use our financial institutions for their
illegal gains. They are Titles I, VI, VII and XI
(Supervisory Authority Over Depository Institutions; Change
in Bank Control Act; Change in Savings and Loan Control Act;
and the Right to Financial Privacy Act, respectively).

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The Subcommittee would appreciate any comments or opinions which the Department might have with respect to the aforementioned Titles that you believe would provide guidance to us in these matters.

Please provide the

appearance.

Subcommittee with 175 copies of Mr.

Trott's testimony no later than 24 hours in advance of his Please have your staff contact Earl F. Rieger, Counsel of the Full Committee staff, if there are any questions.

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The Subcommittee appreciates your appearance at our hearings on April 23. Your testimony is of great assistance in our review of the Bank Secrecy Act and other pertinent issues.

There are several questions which the Subcommittee would like to have you answer and which will be submitted for the record. They are as follows:

1.

2.

3.

4.

5.

What is the justification for eliminating customer
notification requirements under the Right to Financial
Privacy Act when interagency transfers of financial
records are obtained?

The Department has had some recent setbacks regarding
prosecutions in "structuring" cases. Wouldn't the
Pickle bill, H.R. 4573, resolve those difficulties?

The Department already has an arsenal of primary
offenses utilized in Title 31 prosecutions, such as
false bank entries, defrauding the U.S., RICO, Title 26
offenses, Title 21 offenses, etc. Why is it necessary
to create a new criminal offense?

Under current regulations, the CTR filing duties are
placed solely upon the financial institution, not the
customer. Wouldn't placing a duty also on the customer
to file or to sign a sworn statement be an additional
effective law enforcement tool?

Why do you feel Treasury needs summons authority?
Specifically, what are they precluded from doing now
under existing authority?

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