Chairman ST GERMAIN. While operating, did you restrict yourself to the greater Miami area for your purchase of cashiers checks?

Mr. FRIEDBERG. I did. I had approximately 8 to 12 bank accounts under my own name. That's another thing. Not realizing I was committing any crime, I opened bank accounts in my own name. Every time I went into a bank, it was in the name of Herbert Friedberg. I didn't go in there looking to-

Chairman ST GERMAIN. So you identified yourself as Herbert Friedberg?

Mr. FRIEDBERG. That's correct.

Chairman ST GERMAIN. And then you would purchase a cashiers check?

Mr. FRIEDBERG. That's correct.

Chairman ST GERMAIN. You would then put the phony names on, for both the remitter and the payee?

Mr. FRIEDBERG. Yes, sir.

Chairman ST GERMAIN. Now, you worked with eight or nine different banks?

Mr. FRIEDBERG. Almost 12 banks.

Chairman ST GERMAIN. Twelve banks; is that it?

Mr. FRIEDBERG. Yes, sir.

Chairman ST GERMAIN. Which means you were going in on a regular basis?

Mr. FRIEDBERG. Continuously.

Chairman ST GERMAIN. Were you using the same tellers, pretty much the same tellers in those banks?

Mr. FRIEDBERG. They got to know me on a first-name basis.

Chairman ST GERMAIN. And they never questioned you and said, Mr. Friedberg, what kind of business are you in that you have so much cash?

Mr. FRIEDBERG. It never was questioned, sir.

Chairman ST GERMAIN. Would you say that one teller in a period of 2 weeks might have seen you come in five or six times with $5,000?

Mr. FRIEDBERG. Not quite that much frequency. I would say at least two to three times.

If I might voice an opinion, sir, again having listened to Mr. Pickle and the members of the committee and the questioning, I realize the direction you were going.

The banks are obligated to report a transaction over $10,000 and the tellers are told that any transaction over $10,000 they should be aware of. When you walk in with $9,000, even though they might suspect that you are a money launderer or where the money has come from, their obligation is not to report it.

Because they are not obligated, they feel they are within their rights not to say anything.

Chairman ST GERMAIN. You see what you are referring to is the fact that they were looking the other way on aggregation.

Mr. FRIEDBERG. Correct, sir.

Chairman ST GERMAIN. Did they ever say to you, "Mr. Friedberg, where is all this cash coming from?"

Mr. FRIEDBERG. No, sir.

Chairman ST GERMAIN. They never asked you what kind of business you were in?

Mr. FRIEDBERG. It was not within their realm to ask that question.

Chairman ST GERMAIN. Wait a second. That is your opinion.

Mr. FRIEDBERG. No, sir. They felt that it was not within their realm.

Chairman ST GERMAIN. You say that they felt it wasn't within their realm. Let's face it. If you were a bank teller and this fellow, Mr. Bandstra, came in to see you twice a week or once every 2 weeks with $9,000 on a regular basis, wouldn't you say to yourself, "I wonder where that guy is getting all this cash?"

Mr. FRIEDBERG. I certainly would.

Chairman ST GERMAIN. You would?

Mr. FRIEDBERG. Absolutely.

Chairman ST GERMAIN. That is our point.

Mr. FRIEDBERG. Yes, sir. I would be very curious. Again, your question

Chairman ST GERMAIN. Did you not at some point in time feel a little queasy that they might ask you, some of these tellers that you would see more than one time?

Mr. FRIEDBERG. Yes, sir-

Chairman ST GERMAIN. But you figured as long as they didn't, you could keep going; right?

Mr. FRIEDBERG. I am losing the question.

Chairman ST GERMAIN. In other words, if you felt that perhaps they might put the finger on you and start asking you questions, where is this cash coming from, how come, A, B, C, D, that then you would have said to yourself, "I better not hit that bank again for a month or so?" Did that ever happen?

Mr. FRIEDBERG. No, sir. I just again

Chairman ST GERMAIN. So you felt perfectly free to go back into the bank?

Mr. FRIEDBERG. The problem again, sir, never arose.

Chairman ST GERMAIN. It never occurred to you that there would be a problem?

Mr. FRIEDBERG. No, sir.

Chairman ST GERMAIN. They were very friendly and cordial and happy to get the fee you were paying them for the cashier's check?

Chairman ST GERMAIN. Hallelujah! My time has expired. Mr. Annunzio.

Mr. ANNUNZIO. I thank you, Mr. Chairman. I listened to the witness. When you walk into a bank and you have $9,000 and you ask for a cashier's check or a money order, you are not violating any law?

Mr. FRIEDBERG. That is correct, sir.

Mr. ANNUNZIO. You can repeat that 50 times per day?

Mr. FRIEDBERG. Yes, sir.

Mr. ANNUNZIO. And you are still not in violation of any law. I want to get this record straight. The chairman asked the question about the employees of the bank asking you about the money, but it is none of their business. They are working there and you pay x number of dollars for a cashier's check and they are making money. A bank is in the business of making money. You are in the business of not knowing you are laundering money. I don't think

there are many people in the country that know that $10,000 has to be reported. Do you agree with that statement?

Mr. FRIEDBERG. Yes, absolutely. I was going to inject that there is an education process. I was educated by the Miami Herald.

Mr. ANNUNZIO. You have been through this process. How would you advise the members of this committee. I voted for the $10,000 in the Bank Secrecy Act and it is a good thing that we had the Bank Secrecy Act on the statute books because when this thing came up, it was the only tool that Federal law enforcement officials have for going after the money launderers and the people who were in the drug business. What would you suggest? How do we overcome it?

Mr. FRIEDBERG. I found some roadblocks in the Miami area that I would like to pass on to you.

Mr. ANNUNZIO. Yes.

Mr. FRIEDBERG. We had one bank that when you walked in with a large amount of cash, first, all banks in Miami right now in order to purchase a cashier's check or money order, you must have an account with the bank. They will not sell you money orders or cashier's checks unless you have an account.

Mr. ANNUNZIO. That is a step in the right direction.

Mr. FRIEDBERG. Correct. Barnett Bank, if I am not mistaken, requires that you first deposit the money in your account and then write a check on it so that they can show the transaction there. Most people are a little reticent to deposit the money in their own account if you are in the laundering business.

Also, the currency reporting system and certainly $10,000 is a good figure, I think there should be something about unusual cash transactions. Don't you consider it unusual for me to come into your bank three times per week with $9,000 on each occasion?

You do have to report it if it is $10,000 but by law, you don't have to report the $9,000 I think three times in the same week with $9,000 is an unusual currency transaction which should be brought to somebody's attention.

Mr. ANNUNZIO. Maybe so, but they are in the banking business to make money. We are a Banking Committee and we have just been through a great deal of bank deregulation because there are too many regulations. There is too much oversight on the part of the Government, people complain.

Our President is one of the most popular Presidents in the history of this country because he wants the Government out of everybody's business.

Now you are here this morning telling me that we have to put the Government in the business of all people. If you need a cashier's check, you have to have an account or you can't get the check. Maybe we could say something like if the person presenting the cash wants a money order of an amount over $5,000 they at least have some sort of identification to identify themselves. But then you are putting the onus on the person who is asking for the check because he might be a legitimate person, and if he goes to one of these lawyers and his civil rights have been violated, then we are back to square one again. That is why we can't get liability insurance, you see. So it is quite a puzzle.

Mr. FRIEDBERG. I can sympathize with the situation, Mr. Annunzio. Having lived it, I understand it.

Mr. ANNUNZIO. You can sympathize with a Member of the committee. How do you write legislation? You have lawyers on malpractice with doctors. You have lawyers on malpractice with lawyers. You have liability insurance. If you sneeze with some people, they are in court with a civil rights suit. It is a tough problem. My time is up. Thank you, Mr. Chairman.

Chairman ST GERMAIN. Mr. Friedberg, the picture to the left with the piles of money, does that look familiar to you?

Mr. FRIEDBERG. It looks like Mr. Behar's warehouse on a Monday afternoon.

Chairman ST GERMAIN. Would you describe that to us? I think we need more testimony from you and Mr. Bandstra in order to help the Members.

Mr. FRIEDBERG. Yes, sir. Mr. Behar started out on a small scale. He had one or two people that he was handling their cash for. He was dealing with a Colombian by the name of Alex and Alex was making contacts here in Miami and sending these people to Mr. Behar.

After Mr. Behar's May visit to Colombia, his business increased tremendously and he picked up a number of other clients. Money would come in to Mr. Behar's warehouse at 2 or 3 o'clock in the afternoon in duffel bags, suitcases and that is a typical picture.

This money would be placed in one of the back offices and Mr. Behar and his employees and his wife would sit and count this money and put it in $10,000 packets so it would make it easier to

count.

On an average afternoon, you would have in excess of $400,000 to $500,000. When Mr. Pickle mentioned that $90 billion figure and $50 billion, I was not surprised. On an average day while working for the Government, it was not inconceivable for me to handle $100,000 per day in laundering and that is a half a million dollars and I was just one little guy in Miami just doing that.

Chairman ST GERMAIN. Tell me. In this warehouse, he was an export/importer?

Mr. FRIEDBERG. Yes, sir.

Chairman ST GERMAIN. Did you have any duffel bags of coffee coming in?

Mr. FRIEDBERG. Nothing, sir.

Chairman ST GERMAIN. No coffee.

Mr. FRIEDBERG. Nothing.

Chairman ST GERMAIN. No Colombian coffee?

Mr. FRIEDBERG. No.

Chairman ST GERMAIN. Juan wasn't there?

Mr. FRIEDBERG. No, none at all. In fact, not seeing the denominations we would get money in various denominations and when we would get a load in of small bills, 5's or 10's, it would be referred to as marijuana money and the 20's and 50's and 100's was called cocaine money.

Chairman ST GERMAIN. Was that before or after your trip to California?

Mr. FRIEDBERG. After. This was after Mr. Behar made his contacts in Colombia in June. I started working for the Government in June.

Chairman ST GERMAIN. Just a quick question to Mr. Bandstra, and then we will go to Mr. Wylie.

We have met Mr. Friedberg and thanks to your cooperation, he is able to speak to us today, even though he has other cases he may be testifying in. How many Mr. Friedberg's were working with Mr. Behar?

Mr. BANDSTRA. Mr. Chairman, Mr. Friedberg was one of approximately 6 to 8 persons that we have identified, persons which subsequently were indicted, some of those cases have been completed and others are still pending.

But Mr. Behar had approximately 6 to 8 persons doing exactly what Mr. Friedberg was doing on a daily basis.

Chairman ST GERMAIN. So Mr. Friedberg was doing about $100,000 per day; correct?

Mr. FRIEDBERG. Yes, sir.

Chairman ST GERMAIN. Were these other people handling that amount of money, approximately the same amount of money?

Mr. BANDSTRA. To the best of my understanding, it is. Mr. Friedberg, of course, was with them. He met them and he dealt with them. I believe that is correct.

Chairman ST GERMAIN. Mr. Friedberg.

Mr. FRIEDBERG. Yes, sir.

Chairman ST GERMAIN. So that if there are six of you working on any given day, we are talking about $600,000?

Mr. FRIEDBERG. It is entirely possible, sir.

Mr. BANDSTRA. Mr. Chairman, I think it might be helpful also for the committee to know what was done with the checks once they were purchased if Mr. Friedberg could address that question.

Chairman ST GERMAIN. Oh, great.

Mr. FRIEDBERG. We were always to bring the checks back after the close of banks on that day. For example, if I took $125,000 and I laundered $100,000 I would turn in $100,000 to Mr. Behar and he would tally out, so-to-speak, and he would collect all these checks and they would fit into a regular legal size envelope.

On many occasions he had people coming to his office who were leaving for Colombia or Panama that afternoon and on a number of occasions, I personally drove them to the airport or they would be turned over to any of Mr. Behar's employees, myself included, for deposit in bank accounts in the Miami area the following day when we would continue with laundering of money on the next day.

Then Mr. Behar would keep certain checks and turn them over to individuals who gave them to him. I recall Mr. Behar sitting at his desk and endorsing these checks, looking at the name on the front and then forging the name on the back, Mr. Gonzalez or Mr. Gomez or whatever, and then putting them in an envelope.

It got to a point where one of the very large banking institutions in Miami was selling money orders up to $10,000 and we were buying $9,000 money orders and they loved these because there were no dates on them and you did not need a remitter's name or a purchaser's name.