He nodded. "You can create a sham company according to your specifications or you can buy one ready-made. Once you have a shell in place, you funnel money from the U.S. by way of the shell to any financial haven you choose. Or you can set up an offshore trust. Or you do what Beck did, which was to buy himself a bank-in-a-box and start accepting deposits."

"From whom?"

"He makes a point not to inquire too closely, but his primary client is a big-time Los Angeles drug dealer, ostensibly doing business in scrap gold. Beck also dry-cleans money for a major pornography mill and a syndicate that runs a network of hookers and whorehouses down in San Diego County. Guys in the sin trades accumulate millions in cash and what can they do with it? Live lavishly and your neighbors will start to wonder about the source of your wealth. So will the IRS, the DEA, and half a dozen other government agencies. There's never a shortage of folks who need to run dirty money through the sluice and have it come up clean. The neat thing from Beck's perspective is that, until recently, what he's doing wasn't illegal in and of itself."

"You're kidding."

"Nope. Last year Congress passed the Money Laundering Control Act. Before that, the same basic transactions might have been the focus of an investigation or subject to prosecution under some other statute, but the laundering itself wasn't a crime. Sorry to be so long-winded. Bear with me on this."

"Don't worry about it. Most of this is news to me."

"Me, too. From what I'm told, the groundwork was laid in 1970 when the Bank Secrecy Act was passed. The BSA established reporting regulations for financial institutions – banks, brokerage houses, currency dealers, anybody issuing traveler's checks, money orders, shit like that. They're required to report certain transactions to the Secretary of the Treasury within fifteen days on a form called the Currency Transaction Report – the CTR – for any transaction over ten thousand dollars. Are you following?"

"More or less. How do you know all this stuff?"

"Most of it I picked up from my IRS pal in the past couple of months. He says in addition to the CTR, there's something called a Currency and Monetary Instrument Report, the CMIR. This is for the people who physically receive or transport cash – carry it, mail it, ship it – again, that's in any amount over ten thousand dollars. There's another form for casinos, but we don't have to worry about that here. Far as we know, Beck doesn't have ties to any of the big gambling operations, though that's another nice way to scrub a load of cash and get it squeaky clean.