Although all three countries are signatories to the U.N. Convention Against Illicit Traffic in Narcotic Drugs and Psychotropic Substances 1988, Australia, the United Kingdom, and the United States have adopted approaches to combating money laundering that contain critical differences. Pursuant to the U.N. Convention, Australia passed the Cash Transaction Reports Act of 1988. It had already passed the Proceeds of Crime Act 1987, which made money laundering a criminal offense, and the Mutual Assistance in Criminal Matters Act 1987, which facilitated cooperation with other governments. The 1988 Act is complemented by a number of State laws. Financial institutions must make mandated reports to the Australian Transaction Reports and Analysis Centre (AUSTRAC), which analyzes all the reported data relating to financial movements. Prior to the U.N. Convention, the United Kingdom had already passed laws that require banks and other financial institutions to report suspicious transactions relating to drugs and, in a separate statute, other criminal offenses. The most recent steps involve the passing of the Drug Trafficking Act 1994 and an associated piece of delegated legislation, the Money Laundering Regulations 1993. The main requirements of U.S. law are reporting transactions by financial institutions above a certain size ($10,000). The systems of the three countries have key differences for historical and cultural reasons. In the United States, for example, a number of key prosecutions have been facilitated by "sting" operations. Such arrangements are restricted under British law and virtually impossible in Australia. The three countries regard money laundering with varying degrees of seriousness for both legal and political reasons; this affects the extent to which resources are committed to enforcement. Overall, the United States apparently has been the most effective in consistently breaking up laundering operations; however, the crime has persisted, with ever increasing amounts of money involved. Australia, on the other hand, has developed a system that offers the greatest potential to small and medium-sized countries through the AUSTRAC system, which can be purchased by other countries. 8 notes