s, foreign bank certification, and forfeiture of funds in interbank accounts and implementation of anti-money laundering programs by financial institutions are all expanding or new policies and legislation due to the USA Patriot Act. Under federal law, a financial transaction only represents a money laundering offense if the funds involved in the transaction are proceeds of a criminal offense. The nature of two or more transactions conducted in parallel represents a factor of uncertainty in such law, and the issue has been dealt with in several court cases: U.S. v. Covey (2000) , U.S. v. Mankarious (1998) and U.S. v. Farrington (2000) .
IMPACT OF USA PATRIOT ACT (Before & After)
The impact on Offshore Financial Centers (OFCs) stems primarily from the impact of the PATRIOT Act on U.S. banks and financial institutions. Title III (IMLFA) of the USA PATRIOT Act stems from H.R. 3004. With respect to mo
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