What is the Money Laundering Control Act?
The Money Laundering Control Act of 1986 (the “MCLA”) was the first law in the world to make money laundering a crime. The MLCA prohibits any person from knowingly engaging in a financial transaction which involves the proceeds of a “specified unlawful activity.”9 The law provides a long list of specified unlawful activities, including, for example, terrorism, drug trafficking and fraud. Most listed activities are crimes under U.S. law; however, in 2002, the USA PATRIOT Act expanded the list to include, among other items, foreign crimes involving corruption such as bribery and misappropriation of funds. The purpose of this addition was to make it illegal for a bank in the United States knowingly to accept funds that were the proceeds of foreign corruption. The addition of foreign corruption crimes to the list of specified unlawful activities was based primarily on previous government investigations into private banking activities which established that senior foreign political figures