The events of September
11 brought into sharp focus the true scope of the objectives,
capabilities and resolve of anti-American terrorist
groups. September 11 was not a singular event, but the
culmination of a series of globally orchestrated terrorist
activities. The post-September 11 investigation revealed
a large and complicated network of support nodes that
included a series of money laundering steps buried within
legitimate business activities including, among others,
real estate transactions and real estate investment
funds.
In response, Congress passed the USA PATRIOT Act and
the President issued Executive Order 13224. Incorporated
into these initiatives are specific measures designed
to reduce terrorists' abilities to launder or move funds
through otherwise legitimate transactions. Practically
speaking, these measures impact ARDA's membership in
three main ways:
First, at the point of sale, the timeshare
company must ensure that it is not doing business with
those identified by the government as being involved
in terrorism or other criminal activity.
Second, regulations currently under
consideration may require timeshare companies to implement
an anti-money laundering compliance program that includes
the establishment of criteria to avoid banned transactions.
Third, the developers of resort properties,
both in the U.S. and overseas, need to perform due diligence
on their investors, vendors, and buyers. This type of
development presents opportunities for those wishing
to launder money through a legitimate business, especially
in foreign countries where there may be less attention
paid to money laundering and terrorist funding.
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