Cyberpayments and Money Laundering: Problems and Promise

At the request of the Financial Crimes Enforcement Network (FinCEN), an agency of the U.S. Department of the Treasury, RAND conducted and analyzed a strategic decisionmaking exercise to examine money laundering concerns raised by the deployment of cyberpayment systems. Participants in the exercise represented the Executive Branch, the cyberpayment and banking industries, Congress, and academia. The tasks of the exercise were to (1) describe current cyberpayment concepts and systems; (2) identify an initial set of cyberpayment characteristics of particular concern to law enforcement and payment system regulators; (3) identify major issues cyberpayment policies will need to address; and (4) array appropriate recommendations to address potential system abuse in a set of proposed action plans. While it is premature to draft a comprehensive regulatory regime for cyberpayment products, participants agreed that prompt collaborative action by industry and government–and among governments–is needed. Dialogue on standards, regulatory transparency, and vigorous surveillance can prevent the criminal exploitation of cyberpayment system vulnerabilities.