Another Columbian scam: Taking out life insurance on people near death, changing the beneficiaries, and then either selling the claim, or just waiting for nature to take its course, and having the insurance company send the money to Bogota. “It’s a way of confusing the audit trail and providing these people with legitimate explanations for the sources of these funds,” he adds.

Treasury will also be adding gems and precious metals dealers to their purview this year. “These are organizations that have really been considered to be on the fringes of terrorist financing activity,” says Djinis. They, as well as automobile and boat dealers, will likewise be required to add the same AML programs that banks and their ilk have had in place since before 9/11.

The effect of this new scrutiny on the affected payments flows is an unknown, but, says Djinis, there are indications that AML compliance has slowed foreign investment in this country, and he wonders if the mission creep of these new areas of scrutiny will cut into those businesses, as well. “People just have to worry that their activities would come under scrutiny, or that they’d be inconvenienced, even if they’re legitimate,” he says.

The good news for 2006? It’s unlikely that Treasury will be given any new authority or AML weapons by Congress. “Call me naïve, but I can’t imagine that Treasury needs more authority at this point,” he says. “They had plenty of authority before the Patriot Act, but now it’s got statutory authority to regulate virtually any business that provides financial services to the public.” (Contact: Peter Djinis, 703-873-0884)