Welcome to Your Guide to CICAD!
Hello there! As you prepare for your CAMS exam, you will encounter several international organizations that set the rules for how the world fights money laundering. One of the most important regional players is the Organization of American States (OAS), specifically its body known as CICAD.
Don't worry if that sounds like a mouthful! In these notes, we are going to break down exactly what CICAD is, why it matters to an AML professional, and the specific "Model Regulations" you need to know for the exam. Think of CICAD as the "neighborhood watch" for the Western Hemisphere, helping countries in North, Central, and South America stay on the same page.
What is CICAD?
CICAD stands for the Comisión Interamericana para el Control del Abuso de Drogas (Inter-American Drug Abuse Control Commission). It was established by the OAS General Assembly in 1986.
Why was it created? Initially, the focus was very specific: the Western Hemisphere was facing a massive drug trafficking crisis. The OAS realized that individual countries couldn't fight this alone. They needed a shared forum to discuss policy, share information, and create standard rules.
The Evolution: While it started with a focus on drugs, CICAD quickly realized that you can't stop drug trafficking without stopping the money behind it. This is where it becomes vital for your CAMS studies.
Did You Know?
CICAD serves as the political arm for the Western Hemisphere on these issues. It doesn't just talk; it provides technical assistance to help smaller countries build their own AML systems from the ground up!
The "Model Regulations"
This is the most important part for your exam. CICAD developed something called the Model Regulations Concerning Laundering Offenses Connected to Illicit Drug Trafficking and Other Related Offenses.
What are "Model Regulations"? Imagine you are trying to bake a cake for the first time, but you don't have a recipe. A "Model Regulation" is like a master recipe. CICAD wrote a perfect version of an AML law and said to all member countries: "You don't have to start from scratch. Use this recipe to write your own national laws."
Key Features of the Model Regulations:
1. Defining the Crime: They provide a clear definition of what "money laundering" actually is.
2. Predicate Offenses: Initially, these regulations focused on drug money. However, they were later expanded to include all serious crimes.
3. Asset Forfeiture: They provide rules for how governments can seize and freeze "dirty money" and property used in crimes.
4. Cooperation: They emphasize that countries must help each other by sharing evidence and tracking criminals across borders.
Memory Aid: The "Three C’s" of CICAD
To remember what CICAD's Model Regulations aim for, remember the 3 C's:
- Criminalize (Make money laundering a specific crime).
- Confiscate (Take the profit away from the bad guys).
- Cooperate (Work with neighbor countries).
Why is CICAD Relevant Today?
You might wonder, "If we have the FATF (Financial Action Task Force), why do we need CICAD?"
The answer is regional specialization. While the FATF sets global standards, CICAD focuses on the specific challenges of the Americas—such as the unique nature of transnational cartels and the specific legal traditions of Latin American countries.
A Step-by-Step Evolution:
1. 1986: CICAD is born to fight the "drug war."
2. 1992: The first "Model Regulations" are approved. They were the first international standards to suggest that money laundering should be a crime.
3. The Expansion: Over the years, the regulations have been updated to include terrorist financing and cybercrime, keeping them in line with FATF standards.
Common Pitfalls to Avoid
Mistake #1: Thinking CICAD only cares about drugs.
While "Drug" is in the name, their AML regulations now cover all serious predicate offenses. Don't get tripped up on the exam by thinking they only handle cocaine or heroin money!
Mistake #2: Confusing CICAD with GAFILAT.
GAFILAT is an FSRB (FATF-Style Regional Body) for South and Central America. CICAD is part of the OAS. While they work together, CICAD is the one that developed the Model Regulations used as a legal framework.
Quick Review Box
Organization: OAS (Organization of American States)
Body: CICAD (Inter-American Drug Abuse Control Commission)
Main Tool: Model Regulations
Main Purpose: Providing a legal framework for member states to criminalize laundering and seize assets.
Key Connection: Works to harmonize the laws of the Americas with global standards (like the FATF).
Summary: What You Must Remember for the Exam
If you see a question about CICAD, remember these key points:
- It is the regional body for the Western Hemisphere under the OAS.
- Its Model Regulations were a pioneer in international AML standards.
- It focuses on criminalization, asset forfeiture, and international cooperation.
- It has expanded from strictly "drug offenses" to all serious crimes including the financing of terrorism.
Don't worry if this seems like a lot of organizations to keep track of! Just remember: FATF is the world, and CICAD is the Americas. You've got this!