12 ms·

Combating Money Laundering, Terrorist Financing, and Counterfeiting Act

120 points by ssijak 9y ago

SuperGent 9y ago
Does this mean that someone with a $10K credit card could be picked up and have their assets stripped? What about those business guys with oversea bank accounts that are undeclared? I wonder if anyone would use this law to stop political opponents..
- creepydata 9y ago
  The $10,000 applies to "monetary instruments" (not CCs) you are carrying over the boarder. Also that's already a thing, it's part of you customs declaration card you are required to fill out. - https://www.cbp.gov/travel/us-citizens/sample-declaration-form https://www.cbp.gov/travel/us-citizens/sample-declaration-fo...
- mabbo 9y ago
  It's reporting requirements, not making it illegal to have money. If you've ever bought a car or house, or really made any purchase over $10,000, your bank filed a report to the government with every detail they know about you and every detail about the transaction made. That's not paranoid delusions, that's publicly known law. https://en.m.wikipedia.org/wiki/Financial_intelligence#United_States_examples https://en.m.wikipedia.org/wiki/Financial_intelligence#Unite...
  - panarky 9y ago
    This is not true. The Currency Transaction Report only covers cash transactions. That means green pieces of paper with pictures of dead presidents on them, not electronic money in a bank account. Deposit or withdraw cash, buy money orders or cashiers checks with cash, buy a car or house with cash, and if it's over $10,000, it gets reported. But if you write use a check, credit card, ACH or wire transfer, that's not cash and the bank doesn't have to file a Currency Transaction Report. That's because these transactions are already in the banking system, so there's already a good audit trail of what money is moving where.
    - mabbo 9y ago
      Must depend on the country. In Canada, it's all transactions over 10k. I worked on the software that reads and analyzes the database of those records (a decade ago).
    - conductr 9y ago
      Partially true. In the US, there is also this thing called Suspicious Activity Reports. They are triggered with any transaction >$3,000 (typically cash-equivalents; but that can be wide reaching). There are some requirements where banks must report but there is also the discretionary part. This is where banks can be held liable for not reporting suspicious activity. Because of that, it is safe to assume most banks report every transaction above $3,000 of any type. But let's face it, most bank databases probably have something like this going on; GRANT SELECT ON Transactions TO USGOVT
- csydas 9y ago
  No, as the law is written for Customs, the 10k value is specifically about money going through the border to be declared. A credit card isn't an actual asset, and hence doesn't need to be declared. As for the undeclared accounts, theoretically this should be covered by the FBAR form that US citizens are supposed to file if they keep money in foreign banks. I'm not quite sure how involved the IRS gets in investigating undeclared accounts, but as of right now it looks to be on the honor system. When I filed my FBAR, it didn't even ask for any real verification of the assets I claimed in a foreign account, it just asked for the total value and to plug in the calculations to see if I owed anything. As for using this as a weapon, highly doubtful. The bill mostly modifies existing law to either modernize it or to add punctuation for clarity purposes, and the counterfitting/laundering claims are pretty straight forward. For example, for counterfitting, they want to add the clause: “ Whoever, with intent to defraud, has custody, control, or possession of any material, tool, machinery, or other equipment that can be used to make, alter, forge, or counterfeit any obligation or other security of any foreign government, bank, or corporation; or”. Basically, unless they were already doing some pretty suspect stuff, you'd have to go through a lot of work to set up a condition where you could attack an opponent with it. Same with the "funding terrorism" sections; the burden of proof it looks for is pretty high to use this as a political weapon, when shitposting on twitter and facebook would probably be just as effective.
tinus_hn 9y ago
Kind of silly given that with Bitcoin anyone can see all transactions ever made.
- zer0tonin 9y ago
  Mixing is a thing.
  - opportune 9y ago
    The thing I don't understand about mixing is that shouldn't it pretty much always be taken as an indication of money laundering? I can't think of any reason someone would need to mix / tumble coin if it were all legit. Seems to me that receiving bitcoin from an address known for mixing should be an automatic red flag.
    - diggan 9y ago
      You might not want to paint a target on yourself by making known how much cryptocurrency you have, hence you'd like to keep it a secret. You could say the same thing if you'd live in Sweden and with "normal" money: "Taking out money from the ATM should be automatic red flag, since no one uses fiat except criminals to buy drugs."
    - Rmilb 9y ago
      Financial privacy. You can still report it on your taxes. Maybe some of the coins you now own were stolen and you just happened to get them from the exchange and you are concerned about the fungability of bitcoin in your legal jurisdiction.
    - PaulAJ 9y ago
      You might be running a business and not want to let your competitors know how much you are spending on advertising, R&D, and such like.
  - ac29 9y ago
    Doesn't really answer the Government's (legitimate IMO) question: "You just sold $25,000 of bitcoin on {US_Based_exchange}, where did it come from?" Mix it all you want, it wont save you from an IRS audit or other formal Government inquiry if they so choose. Attempts to obfuscate sources of assets on a completely public blockchain could probably qualify as money laundering, in and of itself. Its not really much different than the cash -> casino chips -> cash launder (which gets reported to the government, or is supposed to).
throwanem 9y ago
Is there an analysis somewhere that isn't so, uh, /r/bitcoin? There's a kind of occasional Chicken Little style there that seems to add more heat than light.
- csydas 9y ago
  Yes, and please don't take this as a snarky comment: ctrl+f "digital currencies" and you will see exactly how involved the bill is with Bitcoin. You are right to suspect this is the reddit crowd over-reacting, and the amendment to the title is probably better. Basically, there is a proposition to include the words "Digital Currenc(ies/y)" into a few places in the bill. I am somewhat reminded of an earlier court case from Florida where the judge dismissed charges involving Bitcoin because there was no legal definition for it. This bill is basically addressing that and presenting a legal framework for Money Laundering and Terrorist Financing investigations to allow investigation of Bitcoin as well. The fallout from this can be interpretted by others, but this isn't a specific bill or "1984" attack on Bitcoin, it's adding digital currencies as part of a legal framework for two specific crimes. edit: added "investigations" to the second paragraph to clarify that it presented a legal framework for such investigations.
  - mdinstuhl 9y ago
    But ETH is not a currency - it's GAS!
    - omginternets 9y ago
      Gas that acts very much like a currency insofar as it is a store of value due to its utility and scarcity. This is pedantry at its worst.
- aurelius12 9y ago
  Occasional?
stuntkite 9y ago
None of this is particularly new information. I mean he mentions that bill at the top but no real discussion about it's contents. John Oliver did a great piece on civil asset forfeiture a while back and the $10,000 rule has been around forever. I'm not saying this isn't a bill that we should care about but this post is useless bullshit.
- discombobulate 9y ago
  Did you read the link[0]? It seems there are amendments to the current bill. [0]: https://www.congress.gov/bill/115th-congress/senate-bill/1241/text#toc-idea0e9489fc8f46379f95bb56c8bbbda5 https://www.congress.gov/bill/115th-congress/senate-bill/124...
mabbo 9y ago
It sounds as though governments are simply trying to amend existing law around money laundering and terrorist financing to try to deal with the invention of digital currencies. This sort of thing has happened before. Back in '06 I was an intern in the tech department of FINTRAC, Canada's agency for stopping money laundering and terrorist financing, so my knowledge is outdated and only specific to one country- but everyone has roughly the same rules and goals with these laws- track large money movements to find money laundering operations and stop money from finding it's way to terror groups. They use the $10,000 rule- banks report your info if you move more than that in or out of your account and border security reports it if you move that much in cash across a border. Over time though, new tricks are always figured out, and laws updated. In '06, it was casinos ("yeah I won big last night, that's where the money came from"), currency exchanges ("oh yeah, we do a huge amount of business and over charge everyone"), and jewelry stores (buy diamonds in cash, carry them over borders instead of money). So reporting laws were updated. Now the trick is "I bought a lot of bitcoins in 2009 and finally sold them today, that's where the money came from". If the laws aren't updated, money laundering becomes easy again. What else do we expect governments to do? Now, are these laws well written and not overreaching? I'm not sure, and that's worth debating.
- discombobulate 9y ago
  > What else do we expect governments to do? Stop allying with Saudi Arabia & leave hard working people alone? End the bogus war on drugs? Allow innovation to take root? Not sure.
  - deleted 9y ago
    [deleted]
  - mabbo 9y ago
    I mean, yes to those things. I agree. I was sort of meaning what are they to do to stop money laundering. 'Cause like, criminals are always going to exist and the best place to catch them seems to be when they try to clean up the money.
    - 9y ago
lightbyte 9y ago
>detailing a strategy to interdict and detect [...] digital currencies [...] at border crossings and other ports of entry for the United States; Uh what? They want to detect the presence of crypto currency at the border? How would that even work? Something tells me none of the sponsors for this bill know any specifics for how bitcoin et al. work.
- garrettdc 9y ago
  My assumption would be if they were to see someone with a foreign address come and try to cash out 1000 BTC in USD (or even 10BTC currently) on one of the exchanges, then they would want to know where those bitcoins came from. It would be able to combat another form of layering (with the normal process of placement, layering, and integration). So "at border crossings" here would probably mean any bitcoin exchange operating in the US that deals with foreign entities.
  - MichaelGG 9y ago
    That would be a strange way to word it, wouldn't it? More likely they want to scan your device and use it against you if you are "carrying" undeclared "currency".
    - lightbyte 9y ago
      You don't "carry" crypto currency though, you hold the private key to an address. I don't see how they could determine some random binary blob on your laptop/flash drive/etc. is in fact a private key that is responsible for a number of coins. What if I used an Electrum wallet and just kept the master seed saved, then it's just a string of random words. I could just as easily memorize that or physically write it down somewhere instead.
      - MichaelGG 9y ago
        I think that's why they have a part about determining if technology can be invented to detect this. And a lot of these laws seem to have a point of making easy things illegal, so they have more ways to go after you if they need to.
known 9y ago
There was no terrorism prior to bloom.bg/1O04ymn
- kps 9y ago
  > There was no terrorism prior to [1974] Simply false.
MichaelGG 9y ago
Just a reminder when talking about this with people: Money laundering is not an actual crime that harms anyone. It's a made-up thing to make prosecutors lives easier by lowering the bar on what they can go after people for. We need to undo the marketing that governments push out and media plays along with. It's sad that not telling the government your every financial move is seen as wrong in any remotely free society.
- freehunter 9y ago
  Money laundering itself might not be something that harms anyone, the problem is it's often done to conceal actions that have harmed someone or will harm someone. If I'm selling drugs or weapons, someone is going to start asking where all this money came from. It's easier for my legal case to say "my laundromat" or "my car wash" than it is for me to say "selling crack and Glocks". You could make the case that money laundering itself should not be considered a crime, but it should be strongly considered with other evidence of wrong-doing. There are very few legitimate reasons to go out of your way to conceal the source of your income, so in doing so you're already behaving suspiciously. Like it's not illegal to swerve back and forth in your car without ever leaving your lane, but if a cop see you doing it you're probably going to get pulled over. Because the only reasons you'd be swerving like that tend to be actual illegal activities.
  - 0xfeba 9y ago
    > Like it's not illegal to swerve back and forth in your car without ever leaving your lane, but if a cop see you doing it you're probably going to get pulled over. Well traffic law has similar catch-all like 'disorderly conduct' laws: 'careless driving'. Up to the officer's discretion, basically.
  - 2_listerine_pls 9y ago
    Cultivating, processing & producing drugs shouldn't be legal in the first place. Governments create cartels by making it illegal. In Mexico, cartels also run local some governments, states & also control many activities such as cattle sales, used auto parts, metals, meat, fish, flowers, etc... if you dare to buy from an unauthorized supplier or sell to someone other than them, you are beaten, extorted, or killed. On top of that they also kidnap, steal and require monthly payments to let businesses operate. Terrorism is state funded and preventing laundering won't do much. Laundering helps people in countries like Mexico, where a large part of the tax revenue goes into the hands of few. Why fund a state that is run by gangsters?
nubela 9y ago
The answer here is Monero.
eth0up 9y ago
Some other most wondrous endowments from the seraphic beneficence of Pecuniaria: 1. https://en.wikipedia.org/wiki/Know_your_customer https://en.wikipedia.org/wiki/Know_your_customer 2. https://en.wikipedia.org/wiki/Foreign_Account_Tax_Compliance_Act https://en.wikipedia.org/wiki/Foreign_Account_Tax_Compliance...
gehwartzen 9y ago
“(7) ‘prepaid access device’ means an electronic device or vehicle, such as a card, plate, code, number, electronic serial number, mobile identification number, personal identification number, or other instrument, that provides a portal to funds or the value of funds that have been paid in advance and can be retrievable and transferable at some point in the future.”. Would this not also cover carrying a debit card linked to an account that contains >$10k?
- spinlock 9y ago
  I don't think a debit card (linked to a bank account) would be considered "paid in advance". If you had a prepaid card, then it would.

120 points by ssijak 9y ago

Does this mean that someone with a $10K credit card could be picked up and have their assets stripped? What about those business guys with oversea bank accounts that are undeclared? I wonder if anyone would use this law to stop political opponents..

creepydata 9y ago
The $10,000 applies to "monetary instruments" (not CCs) you are carrying over the boarder. Also that's already a thing, it's part of you customs declaration card you are required to fill out. - https://www.cbp.gov/travel/us-citizens/sample-declaration-form https://www.cbp.gov/travel/us-citizens/sample-declaration-fo...
mabbo 9y ago
It's reporting requirements, not making it illegal to have money. If you've ever bought a car or house, or really made any purchase over $10,000, your bank filed a report to the government with every detail they know about you and every detail about the transaction made. That's not paranoid delusions, that's publicly known law. https://en.m.wikipedia.org/wiki/Financial_intelligence#United_States_examples https://en.m.wikipedia.org/wiki/Financial_intelligence#Unite...
- panarky 9y ago
  This is not true. The Currency Transaction Report only covers cash transactions. That means green pieces of paper with pictures of dead presidents on them, not electronic money in a bank account. Deposit or withdraw cash, buy money orders or cashiers checks with cash, buy a car or house with cash, and if it's over $10,000, it gets reported. But if you write use a check, credit card, ACH or wire transfer, that's not cash and the bank doesn't have to file a Currency Transaction Report. That's because these transactions are already in the banking system, so there's already a good audit trail of what money is moving where.
  - mabbo 9y ago
    Must depend on the country. In Canada, it's all transactions over 10k. I worked on the software that reads and analyzes the database of those records (a decade ago).
  - conductr 9y ago
    Partially true. In the US, there is also this thing called Suspicious Activity Reports. They are triggered with any transaction >$3,000 (typically cash-equivalents; but that can be wide reaching). There are some requirements where banks must report but there is also the discretionary part. This is where banks can be held liable for not reporting suspicious activity. Because of that, it is safe to assume most banks report every transaction above $3,000 of any type. But let's face it, most bank databases probably have something like this going on; GRANT SELECT ON Transactions TO USGOVT
csydas 9y ago
No, as the law is written for Customs, the 10k value is specifically about money going through the border to be declared. A credit card isn't an actual asset, and hence doesn't need to be declared. As for the undeclared accounts, theoretically this should be covered by the FBAR form that US citizens are supposed to file if they keep money in foreign banks. I'm not quite sure how involved the IRS gets in investigating undeclared accounts, but as of right now it looks to be on the honor system. When I filed my FBAR, it didn't even ask for any real verification of the assets I claimed in a foreign account, it just asked for the total value and to plug in the calculations to see if I owed anything. As for using this as a weapon, highly doubtful. The bill mostly modifies existing law to either modernize it or to add punctuation for clarity purposes, and the counterfitting/laundering claims are pretty straight forward. For example, for counterfitting, they want to add the clause: “ Whoever, with intent to defraud, has custody, control, or possession of any material, tool, machinery, or other equipment that can be used to make, alter, forge, or counterfeit any obligation or other security of any foreign government, bank, or corporation; or”. Basically, unless they were already doing some pretty suspect stuff, you'd have to go through a lot of work to set up a condition where you could attack an opponent with it. Same with the "funding terrorism" sections; the burden of proof it looks for is pretty high to use this as a political weapon, when shitposting on twitter and facebook would probably be just as effective.

tinus_hn 9y ago

Kind of silly given that with Bitcoin anyone can see all transactions ever made.

zer0tonin 9y ago
Mixing is a thing.
- opportune 9y ago
  The thing I don't understand about mixing is that shouldn't it pretty much always be taken as an indication of money laundering? I can't think of any reason someone would need to mix / tumble coin if it were all legit. Seems to me that receiving bitcoin from an address known for mixing should be an automatic red flag.
  - diggan 9y ago
    You might not want to paint a target on yourself by making known how much cryptocurrency you have, hence you'd like to keep it a secret. You could say the same thing if you'd live in Sweden and with "normal" money: "Taking out money from the ATM should be automatic red flag, since no one uses fiat except criminals to buy drugs."
  - Rmilb 9y ago
    Financial privacy. You can still report it on your taxes. Maybe some of the coins you now own were stolen and you just happened to get them from the exchange and you are concerned about the fungability of bitcoin in your legal jurisdiction.
  - PaulAJ 9y ago
    You might be running a business and not want to let your competitors know how much you are spending on advertising, R&D, and such like.
- ac29 9y ago
  Doesn't really answer the Government's (legitimate IMO) question: "You just sold $25,000 of bitcoin on {US_Based_exchange}, where did it come from?" Mix it all you want, it wont save you from an IRS audit or other formal Government inquiry if they so choose. Attempts to obfuscate sources of assets on a completely public blockchain could probably qualify as money laundering, in and of itself. Its not really much different than the cash -> casino chips -> cash launder (which gets reported to the government, or is supposed to).

throwanem 9y ago

Is there an analysis somewhere that isn't so, uh, /r/bitcoin? There's a kind of occasional Chicken Little style there that seems to add more heat than light.

csydas 9y ago
Yes, and please don't take this as a snarky comment: ctrl+f "digital currencies" and you will see exactly how involved the bill is with Bitcoin. You are right to suspect this is the reddit crowd over-reacting, and the amendment to the title is probably better. Basically, there is a proposition to include the words "Digital Currenc(ies/y)" into a few places in the bill. I am somewhat reminded of an earlier court case from Florida where the judge dismissed charges involving Bitcoin because there was no legal definition for it. This bill is basically addressing that and presenting a legal framework for Money Laundering and Terrorist Financing investigations to allow investigation of Bitcoin as well. The fallout from this can be interpretted by others, but this isn't a specific bill or "1984" attack on Bitcoin, it's adding digital currencies as part of a legal framework for two specific crimes. edit: added "investigations" to the second paragraph to clarify that it presented a legal framework for such investigations.
- mdinstuhl 9y ago
  But ETH is not a currency - it's GAS!
  - omginternets 9y ago
    Gas that acts very much like a currency insofar as it is a store of value due to its utility and scarcity. This is pedantry at its worst.
aurelius12 9y ago
Occasional?

stuntkite 9y ago

None of this is particularly new information. I mean he mentions that bill at the top but no real discussion about it's contents. John Oliver did a great piece on civil asset forfeiture a while back and the $10,000 rule has been around forever. I'm not saying this isn't a bill that we should care about but this post is useless bullshit.

discombobulate 9y ago
Did you read the link[0]? It seems there are amendments to the current bill. [0]: https://www.congress.gov/bill/115th-congress/senate-bill/1241/text#toc-idea0e9489fc8f46379f95bb56c8bbbda5 https://www.congress.gov/bill/115th-congress/senate-bill/124...

mabbo 9y ago

It sounds as though governments are simply trying to amend existing law around money laundering and terrorist financing to try to deal with the invention of digital currencies. This sort of thing has happened before. Back in '06 I was an intern in the tech department of FINTRAC, Canada's agency for stopping money laundering and terrorist financing, so my knowledge is outdated and only specific to one country- but everyone has roughly the same rules and goals with these laws- track large money movements to find money laundering operations and stop money from finding it's way to terror groups. They use the $10,000 rule- banks report your info if you move more than that in or out of your account and border security reports it if you move that much in cash across a border. Over time though, new tricks are always figured out, and laws updated. In '06, it was casinos ("yeah I won big last night, that's where the money came from"), currency exchanges ("oh yeah, we do a huge amount of business and over charge everyone"), and jewelry stores (buy diamonds in cash, carry them over borders instead of money). So reporting laws were updated. Now the trick is "I bought a lot of bitcoins in 2009 and finally sold them today, that's where the money came from". If the laws aren't updated, money laundering becomes easy again. What else do we expect governments to do? Now, are these laws well written and not overreaching? I'm not sure, and that's worth debating.

discombobulate 9y ago
> What else do we expect governments to do? Stop allying with Saudi Arabia & leave hard working people alone? End the bogus war on drugs? Allow innovation to take root? Not sure.
- deleted 9y ago
  [deleted]
- mabbo 9y ago
  I mean, yes to those things. I agree. I was sort of meaning what are they to do to stop money laundering. 'Cause like, criminals are always going to exist and the best place to catch them seems to be when they try to clean up the money.
  - 9y ago

lightbyte 9y ago

>detailing a strategy to interdict and detect [...] digital currencies [...] at border crossings and other ports of entry for the United States; Uh what? They want to detect the presence of crypto currency at the border? How would that even work? Something tells me none of the sponsors for this bill know any specifics for how bitcoin et al. work.

garrettdc 9y ago
My assumption would be if they were to see someone with a foreign address come and try to cash out 1000 BTC in USD (or even 10BTC currently) on one of the exchanges, then they would want to know where those bitcoins came from. It would be able to combat another form of layering (with the normal process of placement, layering, and integration). So "at border crossings" here would probably mean any bitcoin exchange operating in the US that deals with foreign entities.
- MichaelGG 9y ago
  That would be a strange way to word it, wouldn't it? More likely they want to scan your device and use it against you if you are "carrying" undeclared "currency".
  - lightbyte 9y ago
    You don't "carry" crypto currency though, you hold the private key to an address. I don't see how they could determine some random binary blob on your laptop/flash drive/etc. is in fact a private key that is responsible for a number of coins. What if I used an Electrum wallet and just kept the master seed saved, then it's just a string of random words. I could just as easily memorize that or physically write it down somewhere instead.
    - MichaelGG 9y ago
      I think that's why they have a part about determining if technology can be invented to detect this. And a lot of these laws seem to have a point of making easy things illegal, so they have more ways to go after you if they need to.

known 9y ago

There was no terrorism prior to bloom.bg/1O04ymn

kps 9y ago
> There was no terrorism prior to [1974] Simply false.

MichaelGG 9y ago

Just a reminder when talking about this with people: Money laundering is not an actual crime that harms anyone. It's a made-up thing to make prosecutors lives easier by lowering the bar on what they can go after people for. We need to undo the marketing that governments push out and media plays along with. It's sad that not telling the government your every financial move is seen as wrong in any remotely free society.

freehunter 9y ago
Money laundering itself might not be something that harms anyone, the problem is it's often done to conceal actions that have harmed someone or will harm someone. If I'm selling drugs or weapons, someone is going to start asking where all this money came from. It's easier for my legal case to say "my laundromat" or "my car wash" than it is for me to say "selling crack and Glocks". You could make the case that money laundering itself should not be considered a crime, but it should be strongly considered with other evidence of wrong-doing. There are very few legitimate reasons to go out of your way to conceal the source of your income, so in doing so you're already behaving suspiciously. Like it's not illegal to swerve back and forth in your car without ever leaving your lane, but if a cop see you doing it you're probably going to get pulled over. Because the only reasons you'd be swerving like that tend to be actual illegal activities.
- 0xfeba 9y ago
  > Like it's not illegal to swerve back and forth in your car without ever leaving your lane, but if a cop see you doing it you're probably going to get pulled over. Well traffic law has similar catch-all like 'disorderly conduct' laws: 'careless driving'. Up to the officer's discretion, basically.
- 2_listerine_pls 9y ago
  Cultivating, processing & producing drugs shouldn't be legal in the first place. Governments create cartels by making it illegal. In Mexico, cartels also run local some governments, states & also control many activities such as cattle sales, used auto parts, metals, meat, fish, flowers, etc... if you dare to buy from an unauthorized supplier or sell to someone other than them, you are beaten, extorted, or killed. On top of that they also kidnap, steal and require monthly payments to let businesses operate. Terrorism is state funded and preventing laundering won't do much. Laundering helps people in countries like Mexico, where a large part of the tax revenue goes into the hands of few. Why fund a state that is run by gangsters?

nubela 9y ago

The answer here is Monero.

eth0up 9y ago

Some other most wondrous endowments from the seraphic beneficence of Pecuniaria: 1. https://en.wikipedia.org/wiki/Know_your_customer https://en.wikipedia.org/wiki/Know_your_customer 2. https://en.wikipedia.org/wiki/Foreign_Account_Tax_Compliance_Act https://en.wikipedia.org/wiki/Foreign_Account_Tax_Compliance...

gehwartzen 9y ago

“(7) ‘prepaid access device’ means an electronic device or vehicle, such as a card, plate, code, number, electronic serial number, mobile identification number, personal identification number, or other instrument, that provides a portal to funds or the value of funds that have been paid in advance and can be retrievable and transferable at some point in the future.”. Would this not also cover carrying a debit card linked to an account that contains >$10k?

spinlock 9y ago
I don't think a debit card (linked to a bank account) would be considered "paid in advance". If you had a prepaid card, then it would.