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New York was made by the regulators once they realized the bank was a huge washing machine for laundered money.
FYI.
    I took out a yellow legal pad from my drawer, ready to begin planning
the investigation, although there wasn't much in the way of hard information. Obviously, my first step should be the perpetrator's last, Eagle
Bank of New York. That's where the money had landed. But complicated
banking regulations and the need for complete secrecy forced me to
reevaluate. I would have to settle for the penultimate step. Sling & Dewey
had made huge deposits into Eagle Bank in cash, wire transfers, and
checks drawn on a Seychelles bank. Let's see what I can find out about the
depositors, I said to myself, identifying my first challenge.
    I called Jim Lion, a postal inspector assigned to FinCEN in Vienna.
Jim and I went back a few years, and he'd always been helpful. I remembered him telling me about his work on a case in the South Pacific, but I
couldn't remember if it included Australia.
    "Jim, I need some help in Australia. Got any connections?"
    "Not personally," he said. "But tell me what you need, maybe I can
direct you."
    "I need to get info on an Australian company. You know, shareholders,
directors, managers, bankers ... the works."
    "Funny you should ask, because FinCEN has recently completed a cooperation project with AUSTRAC. That's Australia's anti-money-laundering
regulator and specialist financial intelligence unit."
    "Would they help?"
    "I think so. Let me check. In the meanwhile, fax me the details you
already have about the company."

    Fifteen minutes later Jim was back on the line. "The cooperation agreement is between FinCEN and AUSTRAC, so all requests must emanate
from us. I'll place the inquiry once I receive it from you."
    I thanked him and went back to the file. Sling & Dewey was the only
solid lead I had so far. Its name had come up in the audit. Just a name,
nothing else. I was hoping that this narrow window of opportunity would
not be shut in the end.
    The following day Jim called. "It took AUSTRAC only twelve hours to
come up with a response."
    "I'm impressed," I said, thinking how long it would take our own
bureaucracy to react in a similar situation.
    "Let me read you what they say .'We attempt to ensure that financial service providers, such as banks, identify their customers to reduce
the occurrence of false name use - "'
    "Jim, spare me the niceties," I cut in impatiently. "Do they have anything?"
    "Yes, they do," he said coolly, refusing to be pressured. "I'm faxing you
their report."
    I walked down the hall to the office fax machine as it started spewing
the report. It was captioned "FTR Information." Below the Australian
agency's emblem it said, "This report is generated in accordance with
Financial Transaction Reports Act 1988 and pursuant to AUSTRAC's
agreement with FinCEN."
    I quickly perused the preamble and the caveats and then went straight
to the jugular. Sling & Dewey Goods and Services, PLC, had been incorporated in New South Wales, Australia, on May 12, 2ooi. The company
listed two shareholders: Advanced Liquids, Ltd., and Regency Portfolio,
Ltd. The company's directors were H. G. Andrews and Sheila McAllister.
Its registered address was Post Office Box 7166, Bondi Junction, New
South Wales. The purpose of the company: international trade. A short
narrative followed.
    Sling & Dewey Goods and Services, PLC, is believed to be a
shell company. Our enquiry has shown that said postal box has always been owned by a reputable bookstore which has no connection to any of the listed names. We believe the use of the box
was fraudulent. Only Regency Portfolio, Ltd., is registered in
Australia. Advanced Liquids, Ltd., is a foreign company registered in the Seychelles. We were unable to find additional local
registration in Australia. Regency Portfolio, Ltd., is also a shell
company with fake directors. The actual registration of Sling &
Dewey Goods and