The Money Laundering Control Act of 1986, codified at Title 18, U.S. Code Section 1956. The MLCA was the first law in the world to make money laundering a crime. It is one of the most powerful anti-money laundering laws in the world. Listed among the more than 220 “specified unlawful activities” (SUA) that can serve as predicates to a US money laundering prosecution is Section 206 of the International Emergency Economic Powers Act (Title 50, US Code Sec. 1705). This Act prescribes penalties for violating the sanctions requirements of the US Treasury Department under the authority delegated by the president to Treasury and the Office of Foreign Assets Control (OFAC). As an “SUA,” penalties for sanctions violations under Section 206 can activate a US money laundering prosecution. The money laundering law, which is one of the most powerful such laws in the world, carries a maximum penalty of 20 years in prison and criminal fines of up to $500,000 for each violation.

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