Abstract

Efforts by governments to control cross-border money laundering have intensified in recent years. Over the past decade, a broad political consensus appears to have arisen in favor of the implementation of effective anti-money-laundering policies, at least in most developing countries. However, the question has also arisen of whether, in some instances, the war against money laundering may be going too far. For example, a 1998 Wall Street Journal article entitled “How Money Laundering Hit a Wealthy Family”1 related the story of how $54 million—virtually the entire financial assets of a Chilean extended family—were effectively frozen by the U.S. Government under U.S. anti-money-laundering and civil forfeiture legislation.2 The family, formerly prized Citibank customers who held their wealth legitimately, lost control over their U.S.-based assets because the federal government asserted that they had helped to launder money for a Mexican drug lord.