GoKawiilIcan’t remember the last time I used cash. My bank statements show that I haven’t made a withdrawal from a cashpoint in the last twelve months. That’s just as well, since it’s significantly more of an effort to get hold of cash than it used to be. Before the pandemic, there were seven cashpoints within a five-minute walk from my house. All of them have now gone: the four attached to banks disappeared when the branches closed, the two in supermarkets were removed, the random one outside a building that used to be a bank but is now a bar has also vanished. Nerds like to say that the plural of anecdote is not data, but in this case, it kind of is, since the general decline in the use of cash is a marked phenomenon across the developed world, and especially in the UK. According to UK Finance, the sector’s trade association, in 2009 cash was used in 58 per cent of all transactions. The figure today is 9 per cent.
Since fewer and fewer people are using banknotes, it follows logically that fewer banknotes are needed, and therefore that fewer banknotes are being printed and put into circulation. Right? Wrong. In the UK, there is £1300 cash in circulation for every single one of us, but the amount of cash we actually hold is one seventh of that figure. The value of banknotes in circulation has been rising sharply for decades, and not just in the UK. In 2005, the total value of all the dollar bills in circulation was $759 billion. By 2015, it was $1.38 trillion. Last year, it hit $2.395 trillion. As Kenneth Rogoff put it in The Curse of Cash (2016), the dumbfounding thing is that ‘no one quite knows where exactly most of it lives or what it is used for.’ According to Oliver Bullough, in his alarming and unsettling book Everybody Loves Our Dollars, in 2022 the average American held $418 in cash, but there was $7357 of cash in circulation for every American man, woman and child. That means that a typical household of four represents $27,756 of missing cash, 80 per cent of which is in the form of the highest denomination US banknote, the $100 bill. That is a hell of a lot of $100 notes unaccounted for, especially when you bear in mind how seldom most people use, or even see, a $100 bill. There are 1.552 trillion euros in circulation, half of it again in the highest denomination banknotes, €100, €200 and €500. (The €500 bill ceased printing in 2019, but is still legal tender. Its nickname gives a clue to its main use: it’s called the ‘bin Laden’.) In Switzerland, 90 per cent of the value of outstanding cash resides in ludicrously valuable CHF 1000 banknotes – a single note is worth £943, or $1285.
So where is all that cash, who’s using it, and for what? The answer proposed by Bullough is bizarre: nobody knows. ‘The number of banknotes is increasing, and the question of why the value of banknotes has increased so markedly remains unanswered.’ Central bankers don’t have much interest in the question. It is immensely valuable for any country to be able to produce currency that’s in worldwide demand: for the cost of printing a few bits of paper, a developed economy receives billions of dollars of value in pounds, dollars or euros. This is called seigniorage, and central bankers are as keen as anyone else on what is in effect free money. But the incuriosity they’ve developed around the question is remarkable. Especially when you home in on what all that cash is actually being used for. According to the Financial Action Task Force, which was set up in 1989 to fight financial crime at a global level, ‘it does not seem unreasonable to suggest that the total amount of cash physically transported for money laundering purposes globally is in the order of hundreds of billions of dollars.’ This seems to be the amazing answer to the question of the missing cash: it’s being used in criminal transactions.
This theme – something not fully understood is going on at a massive scale right under the noses of governments – is dominant in Everybody Loves Our Dollars and in How to Launder Money by George Cottrell and Lawrence Burke Files. Bullough is a star investigative journalist with a long track record in writing about illicit financial flows. Cottrell and Files are also expert witnesses, though they’re an unlikely pairing. Files is an American financial investigator and specialist in due diligence, a veteran in the field – his name comes up in Bullough’s book. Cottrell is a young British man, born in 1993, with an aromatic CV. He was brought up on the toff-infested Caribbean hellhole of Mustique, sent to and then expelled from boarding school in England, supposedly worked in banking for a while, became deputy treasurer of Nigel Farage’s Ukip in 2015, was arrested by IRS agents at Chicago O’Hare in 2016 and charged with 21 counts of money laundering, pleaded guilty to one of them, did eight months’ federal time, went to work for the Brexit Party and currently lives in Montenegro, though he’s still often seen with Farage. He owns a company called Geostrategy, whose website has the unimprovable tagline ‘Reputation is built brick by brick.’ How to Launder Money is no masterpiece, but it is full of good stories and juicy details, and together with the vastly superior Everybody Loves Our Dollars helps us, if not to understand what’s going on (nobody does, apart from the money launderers themselves), at least to begin to understand the known unknowns.
The first of these is how much money laundering takes place. Bullough quotes Jason Sharman, a professor at Cambridge, whose estimate is ‘squillions’. That is an accurate summary of the current state of knowledge. An informed guess, from Michel Camdessus, the longest-serving head of the International Monetary Fund, is that it is somewhere between 2 and 5 per cent of global GDP. The lower figure puts criminal activity at $2 trillion, or the same size as the Russian economy. The higher puts it at $5 trillion, or the same size as the German economy, the third largest in the world. (Cottrell and Files use the higher number.) If it were an industry, money laundering would be the third biggest business in the world, behind commercial property and ahead of pensions.
How did we end up knowing so little about something so big? The answer can be found in the history of the Financial Action Task Force, founded at the G7 summit in 1989. The FATF is the proverbial 800-pound gorilla of anti-money laundering – or AML – activities. You may think that’s already too many acronyms, but brace yourself, because the AML focus of the FATF has led to the regulatory measures KYC (know your customer), SAR (suspicious activity reports), CTR (currency transaction reports), PEP (politically exposed person) and many more. If this sounds bureaucratic and process-based to the point of tragicomedy, that’s because it is. The sheer extent of the legal apparatus, juxtaposed with the sheer extent of the world’s third biggest business, represents failure on a colossal scale. Rich countries, trying to cut down on illicit flows of finance, have focused their energies on the one thing they can see and control: transfers and transactions inside the official financial system. Bullough comes up with an excellent metaphor for this: the FATF is like a drunk looking for his lost keys under a streetlight, not because that’s where he lost them, but because it’s the only place where he can see.
The problem is that most money laundering doesn’t take place under the streetlight. It doesn’t take the form of visible transfers within the official system. A caveat about what we know: money laundering is a little like drug cheating in sport, where the current state of legal enforcement always lags behind the current state of malfeasance. We don’t know what successful money launderers are doing in the present moment. All we do know is what unsuccessful ones have been caught doing in the past. We are drunks looking for our keys in a big empty space with a single torch, and all we can find is evidence of the rare occasions when other people lost their keys.
Some examples are at the simple end, most of them involving what is called ‘placement’: taking illicit cash flows and depositing them in the financial system. The most obvious methods involve businesses that take cash: casinos, construction, nail salons, barbers (and in the UK minicabs, many of which were notoriously under the control of crime families until Uber killed that particular laundry). On Cottrell and Files’s estimation, ‘it typically takes three nail salons to launder the money from a brothel.’ At its most basic, placement involves taking cash payments over the counter, mixing them with illegal cash and depositing them in the bank. One famous example was ‘La Mina’ (‘the gold mine’), a network of gold and jewellery stores in the US which laundered money for the Mexican cartels at a rate of $2 million per day, for two years, giving a total of $1.2 billion. When it was exposed in 1989, an FBI agent said it was ‘the biggest laundering operation we’ve ever seen’.
But it can get more imaginative. You live in Puerto Rico, buy a lottery ticket and win. Good news – but it gets better! At this point a criminal offers to buy your lottery ticket from you, for more than it’s worth, in cash. You get a cash bonus in excess of your win, and the crook gets to launder the money by depositing the apparently legitimate winnings in his bank account. Or say you’re a Chinese maker of porcelain pots. A criminal approaches you and asks you to make a fake antique. He ships the piece to the UK and creates a false backstory for it, according to which it is owned by a private trust ‘to protect the privacy of the owner’ – of course, it’s really owned by him. The trust puts it up for auction, where he gets proxies to bid up the price before buying it himself, for a huge sum. He ‘repatriates’ the fake to China. The Chinese government is keen to bring home high-value art, and offers a tax break to people who do it, so our crook not only gets to launder money and move it abroad, he gets 12 per cent off his tax for doing so. Why China? Because the government has stringent and energetically enforced controls against moving more than $50,000 out of the country. As a result, Chinese money laundering is such an extensive, ingenious and ever evolving industry that it has acronyms of its own: CUBS, or Chinese Underground Banking System, and IVTS, or Informal Value Transfer System. And why porcelain? Because, as Cottrell and Files explain, the age of ‘jade, paintings, books, metalwork etc … can be determined through non-destructive testing’.
Chinese money laundering is involved in some extremely dark gambling-related activities, which Bullough describes. Money is moved abroad not in the form of cash but in the form of credit transactions through overseas casinos. ‘Handing over control of both debt and debt collection to organised criminals was hugely profitable for everyone,’ he writes. Some Chinese money laundering is less sinister, verging even on the comic. Example: Bicester Village. This extremely successful shopping venue is, according to Bullough, a prime route for Chinese criminals to launder cash. It works like this. A Chinese gang sends drugs to the UK. British drug dealers sell the drugs for cash. British drug dealers give the cash to Chinese students. Chinese students buy luxury goods from Bicester Village. Chinese students ship the goods back to China, where they’re sold and the money given to the drug dealers. Bullough estimates that the Bicester trade is worth £2 billion a year, just from tourists arriving by train. This kind of activity is an issue for the whole luxury market. Bullough asks a police contact about luxury watches, which are a notoriously effective way of moving monetary value. ‘I reckon the luxury watch trade is 80 per cent money laundering. Why wouldn’t it be? You can carry a huge, big bag of money and be very noticeable, or have the same value strapped to your wrist, and be completely anonymous.’ All this is invisible to the modern AML apparatus, which is focused on money that moves through the official financial system.
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