Individuals who make sham transfers or fail to report transfers would not be punished under this provision.

Officials at the Financial Crimes Enforcement Network said banks were not required to report such transfers to the government.

Certainly bank managers, and banks in general, were required to report suspicious transfers of any value, and all transfers above a certain threshold, to the government.

Geneva authorities began an inquiry into suspect Russian money in Swiss accounts last year, and some banks reported suspicious transfers from the Bank of New York.

However there is no obligation on banking institutions to routinely report monetary deposits or transfers above a specified value.

There is however, under UK legislation, no obligation upon banks or others to routinely report all deposits or transfers having a value greater than a specified amount even in the absence of any suspicion that money laundering may be involved (as there is in some other countries).

The increase in remittances also occurred even as the federal government began demanding that companies report transfers and also check proof of customers' identities.

Off-site disposal or other releases show only net off-site disposal or other releases, that is, off-site disposal or other releases transferred to other TRI facilities reporting such transfers as on-site disposal or other releases are not included to avoid double counting.