McDonald was a 27-year veteran of the Internal Revenue Service, Criminal Investigation Division. He is currently a consultant for Alert Advisors in Miami, FL. McDonald specializes in international money laundering issues and currently teaches legitimate companies how to avoid becoming involved with money laundering. This is the edited transcript of an interview conducted in 2000.

About the same time in the mid-1970s, a few things hit globally that impacted south Florida and the United States forever. You had the marijuana fields in Mexico sprayed with paraquat, which pretty much slammed the door on Mexican marijuana. You had marijuana in Jamaica and Colombia that had difficulty getting through the marketplace.

And at the same time or thereabouts, you had the Bahamas come through. And we had a very industrious Cuban fishing fleet in Miami--still do. Very hard-working people who came over from Cuba. They fished the waters and the Bahamas saw too many vessels coming into their reefs, so they closed the door to commercial fishing from the US waters for this fishing fleet. So a lot of fishermen were thrown into economic despair, for lack of a better term, and the Colombians came up and said, "Do we have a deal for you!" There was a huge demand in the United States for marijuana at the time. They spoke the language. They had the restaurants, the culture. The boats were there. So that relationship developed. And immediately, south Florida became the smuggling capital for marijuana. And that's how they got the term "square groupers." The fishing boats, instead of going into the Bahamian banks and fishing for grouper, were running down to the Florida straits and taking offloads, and bringing tons of marijuana from Key West all the way up to the Florida panhandle.

And that's how the drug trade started up in south Florida. Once the smuggling routes were in place, it was not a quantum leap to jump from marijuana to cocaine. And the cartel leaders--no one called them cartels at that point yet--would come into Miami, pop themselves in a restaurant, celebrate their newfound wealth, and have all the money come to Miami. And they said, "Okay, if someone out of Detroit owes me a million dollars for a load of cocaine or marijuana, bring it to Miami. New York? Bring it to Miami." And so Miami very quickly became not only the import capital of the United States for marijuana and cocaine, but also became the financial center for it. That was evidenced by the enormous unconscionable flow of currency into south Florida in the late 1970s and early 1980s.

And where there's money, there's a role for IRS. We got involved. Treasury came in and said that we need to participate in this war on drugs. Because in the late 1970s . . . it became apparent of the drug takeover in the streets of Miami--machine-gunnings on the streets, shootouts in malls. And DEA was overtaxed. DEA was trying to keep up with the pace. They couldn't. We still only had a handful of federal agents down there from all the agencies. Treasury came in late 1979 and said, "Let's see if we can apply a financial approach to some of this," because of the . . . billions of dollars in currency that came walking into Miami banks. "Let's look at the currency laws. Let's look at the financial investigative techniques that were so successful over the years against the traditional Mafia in the United States, and see if we can't apply them here and make some impact."

How did you see the money? What was so dramatic?

Well, it's dramatic when you see people standing in line with boxes of money on dollies and a deposit slip in their teeth. People joke about that, but that's real. We had people walking in with rope-handled shopping bags and deposit slips going into banks. We had 12 individuals in Miami who were depositing $250 million or more annually into non-interest bearing checking accounts. And no reports were being filed, or very few reports were being filed. There were no Currency Transaction Reports, CTRs that banks had to file.

So the banks were breaking the law?

The banks were breaking the law, but at that time banks all over the United States were breaking the law. No one was complying with the law. No one really understood that the law was there. That law was passed in 1970 as a vehicle to combat organized crime in the United States and to trace cash flow. It was challenged by the Supreme Court, it didn't go into effect until 1974, and when it did go into effect it went into effect quietly. Bank regulators weren't pushing banks and bank examinations. No one was investigating whether banks filed these reports. It wasn't until the drug war hit south Florida that we looked at the Bank Secrecy Act, as we called it, and the tracing of currency--to look at these reports. That's when we realized banks aren't filing them--not just in Miami, but all over. I think there were 129,000 CTRs filed by banks in 1979. And in comparison today, I believe that it's about 12 million a year.

What impact was all that cash having on Miami?

All the cash that was coming in wasn't staying in Miami. However, the drug profits in Miami blew the economy right out the window. I could go into an automobile dealership and if I was looking for a car that was a popular car and I wanted to negotiate the price down . . . I had no chance, because the guy behind me with a briefcase full of cash was willing to pay market price for it.

There's one story where an individual trafficker called down to the local Rolls Royce dealer and said, "Do you have any white ones?" I love this story. It's true. "Do you have any white ones?" "Yes." "Bring a couple by. Let me take a look at them." Brought a couple by, his girlfriend liked one. He gave the guy a couple of shoeboxes of cash for the sales price and they drove away. Now, anybody can negotiate a few bucks off the sticker price, but they knew what they had. They called the guy up, and they said, "Look. You were two thousand dollars short." "Not a problem. Come on by." The guy came by, gave him two thousand dollars, plus a few bucks as a tip for the inconvenience. And that was the way things were done.

You go into a restaurant--cash. There was a delicatessen in Homestead, a south Florida city area. I used to go into it when I was going fishing down there. And they would have magnums of Don Perignon in the coolers with salamis. When the loads would come in, the boys would come in and order salami hoagies, and Don Perignon at market price was no object.

Once you've sold your drugs and you have that money, you don't have to hide. I mean, obviously you're visible as a drug dealer, but there seemed to be impunity.

Well, you're incredibly visible. But law enforcement was kind of knocked back on its heels down there. Tons of cocaine were coming in. Tons of marijuana were coming in. You had gravel trucks coming out of the Keys loaded with marijuana. The drug agencies had to deal with the influx of drugs coming in, and it was out of control. And just like we experienced in the 1990s with the Mexican border region, it takes time for the government to catch up and start getting resources in place and identify strategies and attack. It was suddenly overwhelming, and I guess it boiled down to ultimately being a "target-rich environment" down there. Because once we started getting into it and we started looking at these bank accounts and looking at the money that was moving, it was hard for us to convince people in our national office that these dollar figures that I was citing were valid. I was accused of being overly sensational about the amount of money that was being moved, until we sent copies of bank statements up with all the zeroes and all the commas and the money going through.

And that's when the Treasury Department came in and said, "We're going to back this thing to the teeth." We formed the first money laundering task force in south Florida in late 1979, and we kicked off Operation Greenback. We started that in early 1980, bringing the top-flight resources in, both agencies--Customs and IRS. The Department of Justice, Narcotics, and Dangerous Drug Section dedicated attorneys for it. We started this task force. We didn't quite know what we had, but we knew that we had enormous amounts of money. We had the possibility of applying the tax laws on it, but we had this Bank Secrecy Act and the currency laws that proved to be the most effective weapon against foreign national drug traffickers. That's when our task force was started.

The money comes off the street in small denominations, in those early days, and then gets sent back to Latin America. Can you explain that economy?

Yes. Back in the early days, the Medellin cartel controlled drug trade out of south Florida. And they like playing in the money. They want all the money coming in. So they had to get a portion of that cash back down to Colombia, because they were paying for cocaine base. They were paying for the prescriptions of chemicals. They were paying for what they needed to do to manufacture the drugs with currency--with US dollars, with greenbacks. So they needed that money down there. They were putting the balance of the money into bank accounts and wire-transferring it all over the world. There was really no sophistication involved. They were smuggling cash out. They were dumping cash into banks. There was little sophistication involved whatsoever in the early days.

As we started targeting the money launderers, we would take out one individual who'd do $250 million a year, and he would be replaced by five people doing $50 million a year. And they started getting smarter, once we targeted banks in south Florida. But our intention was to get the banks to comply with the law. If banks complied with the law, and the law says, "Who are you, bringing this cash into my bank and whose money is it?" . . . If they file the reports with the government, then we could do our job. We wanted the banks to comply. And in time, banks started getting the message. Through educational processes, banks realized how important they were to the drug trade. Because if I'm a trafficker out of New York and owe the cartel $2 million, I could come down to Miami, make a deposit into the appropriate account of $2 million in cash, and walk away. No one asks any questions and I've made payment. Safe, sound, not a problem.

Well, the banks started backing up and saying, "Who are you?" One bank in particular in Miami put a big copy of a Currency Transaction Report up in its lobby. And in English and in Spanish it said, "This is a report required by law for more than $10,000. If you are conducting such a transaction, please have your proper identification in hand, because we comply with the law and we have to report this to the government." And under surveillance photos and cameras, people would walk in with bags of money, read it, and walk out. And so that kicked us into a new phase of money laundering as it relates to the drug cartel's money.

So in a way, you forced them to find money launderers?

We squeezed them out of our target-rich environment. We fragmented their operation. It became more labor-intensive. They gained some sophistication. The way they do business changed, as well, because when we started taking out the money. We found very quickly that when we started seizing the money, the cash money, that did not go over well. And we reveled in that. We would hit these people. We would seize cash. We would walk into a house, and there was a card table with a money-counting machine, and hundreds and hundreds of thousands of dollars in cash. The money-counting machine is still warm and they would say, "I didn't know it was there." "Whose money?" "I don't know." It would be seized, it would be forfeited, and these people have serious problems explaining down South why they lost the man's money.

Back to Colombia?

Back to Colombia. If a load of coke gets seized, they kick out more coke at $1500 a kilo--cost. If you seize money, it's dollar for dollar, and then you've got to worry about whose fault is it. They're in business to make the money. And that's at the end of the cycle. This thing has gone from a plant, from a leaf, all the way to cocaine sold on the streets of New York and Chicago and Detroit and Miami and wherever. And now it's payday, and the man is always around at payday. The money comes in. . . . We whack the money, and he's not a happy camper. So disruption became a buzzword of ours.

Do you remember an "Ah ha" moment that you went through when you realized what you were looking at?

The moment was in late 1979, when Treasury came down to Miami with these cash flow studies that they had. What is a cash flow study? Well, Treasury had done an analysis of the flow of currency going into the Federal Reserve system, coming out. It showed that in 1978 and 1979, the entire currency surplus of the United States was attributed to south Florida. Billions and billions of dollars of currency was taken out of the economy into the banking system, put back into Federal Reserve, cash back to the Federal Reserves in San Francisco, New York, Chicago, to go back into circulation That's when I looked at that and said, not "Ah ha," but "Oh, my God. What we're dealing with here is beyond any imagination."

Then we started getting the bank records and going into them and targeting them. That's when it really hit. And when we did our first seizure, which was an airplane that was taking $1.2 million down to Colombia and it didn't make it--we seized the money, and there were two pilots that were taking that money down. Our reports are that each of them had a family member in Colombia killed because they lost the money. They were held responsible for it. That's when we started realizing who we were dealing with. We're dealing with top dogs down here by going after the money.

Do you know specifically how the Ochoas ran their money?

The Ochoas ran their money like every other cartel ran their money back then. They collected the money in Miami. They had money managers. They had people that were responsible, like any corporation. You have a subdivision here, responsible for selling the drugs, bringing the drugs to the distribution side of it. And then you have your financial side of it. The people they had responsible for finances were people who have family connections with Europe, connections with international banks, multi-lingual, educated in Europe or the United States--bright, bright people who were financial geniuses and who had a lot to lose if they ripped the man off. They had equity. They had family. They had a good sense of family. And the cartels trusted them, because they knew that if these people crossed them and took their money, they had a great deal to lose to the cartel.

What was Noriega doing in these early days for the cartel?

I don't know what Noriega was doing in the late 1970s. . . . When we looked at these cash flow studies regularly and we saw the normal currency flows coming in from Panama-- then we saw the spikes starting, the enormous jumps of US currency coming in from Panama. This coincided with our Operation Greenback seizures. DEA had an undercover operation going, and FBI had an undercover operation going in the money-laundering circles. These cases started to pop and break. And we saw the cash jumping, coming in from Panama.

What does that mean, "Money is coming back from Panama?"

In normal trade, normal business, if $100,000 in cash goes into a bank in the Grand Caymans, the Grand Caymans does not keep that money in its vault. It does it no good. The bank in the Caymans will have an account called a correspondent account in the US. It'll send that currency to the US to be deposited to that bank's bank account at the US bank. That's called a correspondent bank account. Once that deposit is made, there's that $100,000 in the account of the Grand Cayman bank.

So now you want to look at who's putting that money into those banks down in Panama?

Correct. Now we started taking a look at Panama. In 1983, a Lear jet was stopped as he was trying to fly $5.4 million in currency down to Panama. And it was funny, because the week before that we saw the guy--watched him--and he loaded so many boxes on his plane that time, we said, "That can't be money. It can't be all money." We let him go. The next time we watch him, he taxis to take off--he's not filing a Customs form, Customs stops the plane, and he has $5.4 million dollars in currency. And he had a ledger book, reflecting that the week before, he took down something like $12 million or $13 million. So it was all money that we saw go to Panama.

And he told us--corroborated by the records that we seized from his CPA's office--that over a seven-year period, he had taken down about a billion dollars in currency to Panama. And that's one trafficker. That's not all of it. That's one trafficker. And his plane would be met by Noriega's troops. And the money would be--not him--the money would be escorted to the designated banks. . . .

As we started doing major seizures of currency and monetary instruments, in south Florida and New York particularly, then the cartel started finding other ways to return their loss. This is business. If you're taking a loss somewhere, then you're going to try to find a different way to do business. And they found a home in Panama, the Panamanian banks, right next to Colombia. Just jump right over there, no problem.

But taking that money, taking bulk currency, taking suitcases full of currency into a foreign country is not easy. It's high risk. Unless you have some clout, you're going to be ripped off. It's going to get stolen. It's going to get pilfered. So only the high levels, cartels, could go in and cut deals with somebody in Panama, to say, "We want to bring money in here. We don't want these planes being taken down. We don't want that money stolen. We'll pay for the protection." And it's in that period of time that Noriega's regime gained power and control. They oversaw the movement of funds coming into Panama.

Track that money for me.

Okay. The way the dollars work is that the drug cartel sells products for foreign currencies. They sell products for something other than their currency of choice, the peso. They sell them in the United States for dollars. So they need to get those dollars into a useable form. They sell them. They accumulate enormous amounts of cash. And, to put things in perspective, a kilo of cocaine today will generate approximately a kilo of $20-dollar bills. So when you read of a thousand kilos coming in of coke, then it's going to take a thousand kilos of $20-dollar bills just to pay the Colombian cartel for that load of coke. I'm not talking about domestic profits--it's just to pay for the drugs. And back then, when coke was going for 50,000 a kilo, it was twice as much, weight, size, bulk, and cash. How to deal with that logistically? The money would come into Miami to pay for the load of cocaine. When they could not easily dump it into the banks, they would take it offshore and they would put it into offshore banks--foreign banks.

Like Panama.

Like Panama. Why? Because Panama had a US dollar-based economy. Panamanian banks accepted US dollars, and maintained US dollar accounts. So that currency goes into Panama--

How do you describe a quantity of money? If I saw a box of $20-dollar bills, I'd have no idea how much it is.

A full-size Samsonite suitcase with wheels will hold a half a million dollars in US currency in $20-dollar bills. How many suitcases would it be in tens? Two. But back then, cocaine was expensive. Twenty-dollar bills and fifty-dollar bills were not unusual. Today it's a lot different because we have crack. Crack is a one- and five- and ten-dollar commodity, so it's a logistical nightmare to deal with a bulk currency. One million dollars in twenty-dollar bills weighs 114 pounds. The amount of currency that Carlos Lehder moved through the Bahamian bank accounts of his would have stacked up four [times] the height of the courthouse in which he was tried in Jacksonville, Florida. It is mind-boggling. You or I could launder $10,000 in a week and it wouldn't be a problem. We could do it simply and easily. But we're talking about people that were getting up to $7 million a day and had to launder it.

Crack really presented a new headache for them. It increased sales, but the smaller denominations became a real headache, didn't they?

Crack gave sales an opportunity to market cocaine product to a lower income level--$7, $8, 10 dollars a rock. And they could get the high and they could be happy and they would be hooked on cocaine. Seven and ten dollars--that's one-dollar bills and five-dollar bills. There are a lot of traffickers that won't take ones, or if they take ones, it's an incredible negotiation. I had an undercover operation going in Miami for a number of years. My undercover agent was out of New York, where the drug traffickers basically launder some of their money. And the guy calls my undercover agent and says, "I've got a question. I got a problem. I've got a million dollars in one-dollar bills. What would you suggest I do?" And my agent calmly said, "I suggest that you put a gun in your mouth and pull the trigger." What can you do? Nobody wants a million dollars in ones. What are you going to do with it? . . .

How big is that?

Twenty Samsonite suitcases for half a million. That'd be 40 Samsonite suitcases for one-dollar bills. It's a nightmare for them. But it has to be done. Somewhere along the line, it's being done. They're buying money orders. They're converting ones to fives, fives to tens, tens to twenties. Once they get to twenties, they're okay. The cartel really likes the fifties and hundreds, but they don't get too many of them from the US traffickers, because US traffickers keep those for themselves.



What were the routes for the money to get out of the US?

There are all kinds of routes to take to get the drugs into the United States. But the routes of moving money in 1978 and 1979 weren't sophisticated. When the Cali cartel came to power with the demise of the Medellin cartel, they looked at it much more businesslike than the Medellin cartel did. They looked at their routes. They identified where their losses were. They negotiated with Mexican criminal organizations to bring drugs in through Mexico. Why? Where were the cops? The cops were in south Florida. You had the Seventh Fleet in south Florida. So let's go to a less-patrolled area.

The Cali cartel is more sophisticated, and figures out a way to reduce the risk on the money side. So they start paying the Mexicans to do their work for them. But basically, they're not going to lose as much to interdiction?

That's correct. They were losing nothing to interdiction. That's how the Mexican drug routes were born, and that's how the Mexican drug cartels were born. You don't make cocaine in Mexico. The cocaine that's from the Mexican drug cartels comes from Colombia. They got ten percent of the load.

We had this phenomenon out of Latin America--some people believe it's a relatively new thing--called the black market in foreign exchange, or black market peso. In fact, all over the world there's a black market in foreign exchange. If you go into Mexico you can give a cab driver dollars, and he'll give you pesos. You can go into London and you have US dollars, and you can go up to a little kiosk or a little window at the airport and you buy pounds with dollars. And you walk out with pounds. That's foreign exchange, and that goes on all the time. It's been very, very prevalent in Latin America. It's part of their culture. It's part of trade. It's been going on for at least 40 or 50 years down there, because all the countries have very restrictive currency controls and taxation policies. That's caused the evolution of a sophisticated black market in foreign currencies and foreign exchange. These were not developed for the drug traffickers or by the drug traffickers, but they are vital to the survival of the drug traffickers.

But there is an enormous, insatiable demand in Latin America for US dollars, for a wide variety of reasons. To buy television sets in the United States. To buy Scotch liquor from Aruba. To buy gold chains from Panama. They're all legitimate transactions and legitimate purchases. That's where the demand for the dollar comes. Where are they going to buy these dollars? These brokers have been around for a long time and they used to buy dollars--there are plenty of dollars out there--from legal sources of dollars. But we have a different phenomenon now. We have an operation. We have a lifestyle. The drug traffickers are a source of dollars in Colombia who have dollars that they don't want. Why don't they want them? Because you can't buy power in Colombia with dollars, you don't spend dollars in Colombia. You spend pesos.

I'm talking about functioning in Colombia. I'm talking about the Colombian drug cartels buying gasoline for their cars, buying their cars, buying their fincas, their ranches, down there, paying their protection. They want to get paid in pesos because they're going to party in pesos. They're going to buy cattle for their ranches in pesos. They're going to buy horses with pesos. They're going to buy everything that they need with pesos. They're going to buy political strength. They're going to buy protection.

They're going to pay bribes.

They're going to pay bribes. They're going to pay off whoever they need to pay off. They're going to gain power and wealth with pesos. And they sell their product for foreign currencies.

So they've got a lot of dollars and no pesos. Now they've got to make a change?

. . . They had to buy pesos in Colombia so they could function in Colombia. And instead of going into the bank in Bogota, Colombia, and using a check drawn on the Ochoa bank account in Panama to convert that to pesos, they would go to black market currency brokers and say, "I've got cash in the United States. Cut it. I want to buy pesos." And they would buy pesos from the broker by paying in cash.

So what did they do?

So what they did is they went back to the same currency brokers that were prevalent in Latin America--and there are maybe about a thousand of them right now in Colombia, small-time, big-time--and said, "Here's the deal. We need pesos in Colombia and we will sell you dollars. Same way as the last time--except we're not going to collect all $10 million and sell you $3 million. We're going to sell you the rights to $3 million. Then they put up for bid--who wants to buy $3 million? You may have three separate exchange brokers, currency brokers, bid and say, "I'll take a million." "I'll take a million." "I'll take a million." And they'll negotiate the exchange rates. But because they now have to do more with the money, they negotiate a better deal for them, the broker. And the broker now may pay, if it's 2, 000 pesos per dollar--the broker may pay 1,600 pesos per dollar.

Because he's assuming the risk, he's going to take a cut?

Right, exactly. Now he puts the broker in touch with the drug trafficking organization in New York that has the $3 million. The drug cartel in Colombia says to the guy in New York, the trafficker, "You pay this guy. Here's his beeper number. You pay him one million dollars. And as soon as you pay him the million dollars, it's like paying me." Cool. They play beeper tag. The trafficker here meets the guy on a street corner, in a hotel room, in a shopping center. However they do it, they will deliver one million dollars in currency to the guy working for the broker--not the trafficker, the broker--and the drug trafficker here in New York? He's on the phone calling down South saying, "I made payment. We're cool. I made payment. Reduce my debt by a million." And it's done.

And the broker is sitting with some discounted dollars.

Keep in mind when he gets those dollars that his inventory of pesos is shrunk in Colombia because he's paid out pesos. He needs to make more pesos so he can do this again. So he's going to sell those dollars to individuals needing dollars anywhere in the world, and they'll come in. They may pay--depending on supply and demand--1,800, 1,850, 1,900 pesos per . . . It's still below the exchange rate.

Explain that mechanism.

A Colombian businessman will go to the broker and says, "I need to buy auto parts from Mike in Miami and he's going to ship these auto parts. He needs the $100,000 for his auto parts that I need for my auto parts store here in Bogota," or wherever. A legitimate transaction. In the past, he would have gone to the bank and exchanged from his corporate account pesos for dollars, and transferred $100,000 to Mike's Auto Parts for me to send the auto parts. Historically and legally and properly, that's how it's done. But there are a lot of reasons why it's not done that way. He'll go to the black market because he can buy dollars cheaper. He can avoid import duty taxes. He can avoid exposure to how much he's really worth to the kidnappers. The businessman in Colombia writes a check to the broker for pesos--in pesos--to pay for the dollars. What happened to the broker? The broker's inventory of dollars drops $100,000. His inventory of pesos goes up, so he now has more pesos and he can buy more dollars.

The whole thing is really financed, at the bottom, by the drug dealer willing to discount his dollars, because he wants someone to get them off his hands and assume the risk.

Right

So without drugs, this whole system doesn't work?

Without drugs, the system works--but on a much more narrow profit margin.

Let's talk about the compliance of major US corporations--Fortune 500 companies. After all, Mike's Auto Parts is a little bit misleading. This is GE selling appliances, it's Phillip Morris selling cigarettes. These are big companies that are receiving this drug money.

Law enforcement and these companies are on a collision course right now, because there's a legal principle called "willful blindness." That means if you totally disregard all the facts and circumstances that would lead you to believe and know that this is illegal money, that's the same as knowing it's illegal money.

What are we going to see with this collision course?

We are seeing right now law enforcement taking civil action by executing seizure warrants and seizing money that's traced to large corporations or small companies or individuals that came from the black market--which goes back to drug trafficking. . . .

Which US corporations are concerned about this?

Every business in the United States that does business, legitimate trade, with Latin America must be cognizant of this system. They are subject to their accounts being seized, and assets in those accounts being seized, under this theory. This is being used across the board. It is part of the 1999 money-laundering strategy that's been presented to Congress by Justice and Treasury to impact and go after the black market peso exchange as they call it, and the assets contained therein. There are a number of pieces of legislation on the floor of Congress right now that want to address and essentially make black market money illegal money. It may be good for the corporations if they did that, because then all the corporations would have to adjust at the same time and comply differently. The problem is if one corporation says, "I'm not going to take money that we know or suspect comes from the black market," then the competition's going to . . .

But they've got to do it all together or they're going to lose their money. You gave the example of General Electric.

Absolutely. General Electric took very aggressive steps to ward off the black market money coming into its company from sales to Colombia. And I believe the figure is about 25 percent of sales that they lost. Now, I assure you that 25 percent fewer refrigerators or washers and dryers were not bought in Colombia, but they just went to other businesses. And I've seen it in Miami. I've had people in Miami who are export companies who sell generic products--computer parts, pipe, clothing, denim, whatever it might be--say, "If I tell this guy I can't take these. . . . He'll go to the warehouse right next door and buy them from him. I'm out of a job. Everybody that works for me is out of a job." And is that right?

So we're all hooked on drug money.

That's right. The banks in 1980 said, "If I've got to file this report called a CTR, then you better make sure every bank has to file that. Because you know, if every bank has to do that, that's okay. Then there's no economic advantage one way or the other to going to one bank or the other. Then we're operating on a level playing field. Until we're operating on a level playing field we have a problem with this." And I agree with that.