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The Bank Secrecy Act should be mobilized----to follow the paper trail and determine how Deborah Coughlin facilitated the dispersal of NYC Metropolitan GOP Club monies and how exactly monies changed hands.

Republican donors need to know the scope and dimension of alleged collusion in sub rosa deals and who, allegedly, might be personally profiting.

<><> L/E needs to examine Deborah Coughlin and the NYC Metropolitan GOP Club's bank accounts.

<><> Joint bank accounts might be used to facilitate the transfer of funds from one account to another, and/or wire-transferred offshore;

<><> To cover their tracks, fake invoices might be created to show that money deposited into accounts was being used for legitimate purposes.

<><> Financial schemes scheme might be advanced by issuing phony statements of payments from financial sources that actually covered the transfer of funds for insiders' personal use and/or for redistribution schemes.

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NOTE WELL Under the Bank Secrecy Act, banks are required to establish, implement and maintain programs designed to detect and report suspicious activity indicative of money laundering and other financial crimes. “The Bank Secrecy Act was enacted to protect the public from harm by identifying and detecting money laundering from criminal enterprises, terrorism, tax evasion or other unlawful activities,” the special agent in charge for Internal Revenue Service Criminal Investigation, explained.

Shady banking transactions could be prosecuted under the (1) Bank Secrecy ACT, (2) RICO, and, (3) the Hobbs Act.

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<><> L/E should get ahold of: (1) copies of checks, (2) wire transfers, (3) account statements, (4) invoices, (5) bills, (6) delivery tickets, (7) correspondence including snail mail, e-mail, mobile devices, cell phones, (8) contracts, (9) loan agreements, (10) other account books or official records.

L/E should also explore (a) monies paid to brokers, sub- brokers, (b) family members, (c) mortgage brokers, (d) financial managers, and, (e) real estate agents, brokers, and developers.

<><> L/E should scrutinize bank accounts for suspicious activites: (A) large deposits, (B) funds transferred from one account into another, (C) frequent requests for withdrawals.

<><> Bank records might also show diversions to secret LLC accounts, to money launder and to operate personal ventures;

Tax fraud may also be a factor, facilitated by withdrawals, gift cards purchases, credit card purchases and intra-bank transfers from legal bank accounts into personal accounts, or redistribution schemes.

<><> A huge tipoff is whether bank withdrawals support and luxurious lifestyle including payments for real estate, investment and stock holdings, jewelry, luxury vehicles, resort travel....... and gifts from luxury outlets.