In some of the countries there exists specific legislation relating to forfeiture. In countries lacking specific provisions concerning drug cases, provisions of forfeiture may have to be traced to the penal code or the customs and excise legislation, or even to the general criminal law. New law-making is needed to give the State complete authority to forfeit the ill-gotten gains of drug offenses. There are two ways the law of forfeiture may be developed: internally through domestic legislation and law enforcement, and externally through the cooperation of States. Two obstacles prevent full international cooperation between countries: tax havens and secret bank accounts. Owners of ill-gotten gains can easily avoid forfeiture by moving capital between certain countries. An international convention may be needed to investigate sources of large amounts of money before that money can be deposited into foreign accounts. 24 references. (Author abstract modified)