A Paper Chase in a Paperless World: Regulating Informal Value Transfer Systems


Informal Value Transfer Systems (“IVTS”) are types of remittance mechanisms that allow funds to change hands and cross borders without necessarily passing through the conventional banking sector. While many IVTS transfers serve legitimate purposes, in a post-9/11 world, IVTS have garnered increased attention as potential sources of funding for terrorism or other criminal activity. This Note examines past approaches to IVTS regulation in the United States and abroad, and outlines the obstacles that have undermined effective regulation. To overcome such obstacles, it argues that the United States and the international community should adopt new regulatory measures, including positive incentives to increase self-regulation and cooperation between IVTS operators and law enforcement. This Note further discusses how the government should enact and enforce such new incentives, arguing that implementation methods–including a focus on procedural justice concerns–may strongly impact cooperation rates with law enforcement.