Sir,

This is to express our appreciation for your insights in an essential segment of the economy, and to solicit your prompt assistance for obtaining state-of-the-art data, perspectives and leads on respective money flows. Following are some related observations and questions.

1.    For discerning users, your informative general-purpose subsite "Money Laundering FAQ" could be more helpful if some of the sources used - e.g. IMF - were identified more precisely, possibly by hyperlinks which you use already and which are truly helpful. Also, there would be no harm in having key data regularly updated, with the latest date somewhere mentioned on the subsite.

2.    Your FAQ text specifically mentions that "International Monetary Fund, for example, has stated in 1996 that the aggregate size of money laundering in the world could be somewhere between two and five percent of the world’s gross domestic product. Using 1996 statistics, these percentages would indicate that money laundering ranged between US Dollar (USD) 590 billion and USD 1.5 trillion." Could you please indicate the precise source(s)?

3.    Wikipedia currently gives the world's GDP for 2006 to be USD 48.144466 trillion (IMF source), and 48.244879 trillion (World Bank source). If the 1996 IMF estimate you rely on still were correct, the 2-5% range would now work out at global money laundering activities involving some USD 0.96 to 2.4 trillion. We understand these figures to be key for your organization's businesses. Accordingly, one would expect someone in the FATF to have, by now, developed a more detailed grasp of these figures than your website suggests. What are the - more recent and narrower-margined - figures worked out by FATF and/or other sources?

4.    What are the FATF's current findings on the pathways, methods and instruments used for recycling the "illicit", underground or black funds into the "white economy"? Specifically, what are FATF's figures and estimates for these black funds to have fueled both the subprime mortage and loan markets and the private equity and hedge funds? In the event of no such data to be available, can the FATF rule out subprime markets, private equity and hedge funds to have been fueled by these underground funds? Which articles, papers and reports are available from or known to FATF to address these or related questions?

5.    Anti-money laundering efforts being your organizations' apparent raison d'être, we'd appreciate your indication of where, in one or more of your reports you're offering on the subject, the reader can find a scientific and generally accepted comprehensive definition of the core term money laundering - or a properly sourced list of proposed definitions. Also, please indicate the range of illicit behaviors currently covered by FATF as being targeted by its anti-money laundering efforts. In the event, how far does this FATF-sponsored list go beyond the 32 crimes listed in the EU's Arrest Warrent, notably does it include preparatory actions related to these crimes, and does it include tax avoidance which, in OECD-speak, is regularly - and confusingly so - translated into "évasion fiscale"?

Thanking you in advance for your prompt consideration and reply. Sincerely yours

Philip Wainwright, Main Representative to the UN in New York
International Committee for European Security and Co-operation
icomeuroseccop@gmail.com

(url: www.solami.com/pwfatf.htm)