Friday's filing of a FinCEN Final Rule*, which allows EU law enforcement agencies to to submit AML/CFT information requests to US banks, and American law enforcement to do the same in the countries of the European Union, will have a serious effect on international money launderers. These "professionals," who have been relying for decades on the inability of American and EU law enforcement to conduct effective transnational investigations, now have a potentially major problem; they will be at a higher level of risk for exposure, forfeiture and arrest. Like risk managers in the legitimate world, they abhor dangerously high levels of risk. So, what will their responses be? Good question.  

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