My introduction to the name John Cassara 13 years ago created an early and instantly classic memory in my emerging career as a counter–illicit financing policy official at the U.S. Department of the Treasury. I was traveling through the Middle East on a Treasury mission to facilitate implementation of anti–money laundering (AML) systems and to explain and inform our evolving strategy to counter the financing of terrorism (CFT). Working with allies and other financial centers, the United States had recently fused many elements of the CFT strategy with global AML standards and was pressing for worldwide implementation as a collective security priority following the terrorist attacks of 9/11. After joining the Treasury mission only months before, I was both honored and a bit anxious participating in these pivotal discussions with experienced senior policymakers and AML/CFT practitioners from such a crucial region. On the margins of these discussions, and on more than one occasion, I was asked an unusual question: “Are you John Cassara?”

The clear respect, bordering on awe, with which the question was asked made the answer as disappointing as it was awkward. I returned to Washington with some frustration and abundant curiosity—who is John Cassara?

Upon my return, I quickly learned that being confused with John Cassara was a tremendous compliment. John's legendary status in the global financial investigative community at that time was mirrored by his reputation among peers across the U.S. federal government. In John's storied if not unique career in public service, he served a combined 26 years as a clandestine case officer with the Central Intelligence Agency and as a Treasury special agent with both the U.S. Secret Service and U.S. Customs.

In the 13 years since the trip that introduced me to the name John Cassara, I have had the privilege of working directly with John on multiple cases and issues. John's insights and advice, including after his retirement from government service, helped shape my perspective as I assisted Treasury leadership in creating a new strategic policy office focusing on all aspects of the counter–illicit financing mission. John's thinking informed our efforts to strengthen and expand the global commitment to combat illicit finance, including in partnership with the interagency community, the Financial Action Task Force and the global AML/CFT community, and the private sector. I have continued to rely on John's experience, talents, and insights since joining the private sector in 2013.

Throughout our relationship, John has demonstrated consistent leadership in pushing for urgent reforms required to strengthen the counter–illicit financing mission. And yet, John has never alienated those of us who might take a different view on particularly complex challenges or dimensions of this evolving mission.

I am immensely proud to call John a friend and deeply honored that he asked me to write the foreword for Trade-Based Money Laundering: The Next Frontier in International Money Laundering Enforcement, his fourth book.

John's latest writing comes at a crucial time in the evolution of AML/CFT regimes and the expanding role of financial and economic power as instruments of national and collective security. In the generation since the 9/11 terrorist attacks, there is no doubt that U.S. leadership and global commitments have successfully demonstrated the effectiveness—and indeed, the increasing necessity—of financial power in combating the greatest collective security threats we face. From al Qaeda and global terrorism to the proliferation of weapons of mass destruction and the threatening activities of rogue states such as North Korea, Iran, and Syria, the United States has increasingly relied on financial power to protect and advance our national and collective security.

Despite these unequivocal successes in the evolution and application of financial power to help combat our gravest threats, the global AML/CFT community continues to struggle in systematically advancing more fundamental objectives of AML regimes. As John clearly demonstrates, traditional quantitative and qualitative metrics on money-laundering prosecutions and forfeitures present a troubling picture of relative stagnation. More fundamentally, we lack a clear, systemic, and shared understanding of the nature and scope of money laundering risks. These fundamental shortcomings exacerbate increasingly evident challenges of the private sector in applying a risk-based approach to AML/CFT programs and controls.

These concerns are particularly troubling given the ongoing expansion of transnational organized crime and the illicit financing networks that support such activity. Numerous threat assessments and corresponding strategies document the continued growth and reach of these networks and the criminal groups they support. Such growth includes opportunistic convergence and increasing infiltration of legitimate economic activities, strategically important industries, and governing elites in a number of states around the world. This is a grim picture.

Fresh thinking is needed to change this reality and address longstanding cracks in global AML/CFT regimes. In this book, John makes a compelling case to begin necessary AML/CFT reform by focusing on trade-based money laundering. He is incredibly well-suited for this, bringing his career AML/CFT investigative experience together with his expert understanding of global trade controls. John's insights on trade-based money laundering, gained from over three decades of professional experience investigating illicit finance, will be invaluable to the full range of AML/CFT stakeholders seeking to strengthen the counter–illicit financing mission.

The AML/CFT world is ready to listen. As John describes, recent developments across the regulatory, law enforcement, financial intelligence, and counter–illicit financing policy communities indicate a renewed interest in trade-based money laundering. From regulatory guidance and examination to FinCEN advisories and the 2015 U.S. National Money Laundering Risk Assessment, authorities are refocusing on the deep-seated, systemic AML/CFT vulnerabilities presented by various forms of trade-based money laundering. My consulting experience over the past two years has indicated this renewed interest is shared by the private sector, particularly in the global banking industry.

This book will encourage the continuation and intensification of these efforts. It stands alone as a comprehensive and practical guide on trade-based money laundering and value transfer. And it will prove to be an invaluable resource for the global financial community and AML/CFT authorities as we collectively renew our efforts to better understand and attack money laundering systematically, beginning with trade-based money laundering—truly the next frontier in international money laundering enforcement.

— Chip Poncy