The main problem with the US AML/CFT system remains that the "inability to access accurate BO 
information directly from states, FIs or agents serving corporations or trusts may curtail how effective 
the authorities can be in pursuing criminally persons who misuse U.S. corporations to launder pro- 
ceeds generated domestically as well as abroad or to trace and recover their illicit assets. This includes 
laundering associated with taxes evaded in the United States? and abroad, by U.S. citizens and for- 
eigners respectively, and to cooperate effectively with their foreign counterparts in this regard. 
?The amount laundered from taxes evaded in the United States may be substantial. Serious tax crimes are not 
predicate crimes to ML. The authorities estimated the U.S. net tax gap to be around $450 billion in 2006, exclud- 
ing international tax evasion, and tax crimes for state taxes.” 
The definition according to Art. 3 point (4) (f) of the 4" AMLD is irrelevant for the US, since they're 
not a member to the EEA. The interpretive note to FATF recommendation 3 seems not to be imple- 
  
mented relating to tax crime as predicate offence to ML. 
  
81 See the IMF Country Report No. 15/174 of July 2015 on the United States, footnote 80, pages 4 et seq. 
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