Odd Lots
Odd Lots

Sep 7, 2026 · 1h 1m

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Cash still dominates the hidden economy

Why Money Launderers Love $100 Bills

The episode shows why illicit finance persists across cash, trade, banking, and stablecoins even as governments expand regulation.

3 key takeaways
  1. 1High-denomination notes remain useful because they concentrate enormous value in a portable form.
  2. 2Money laundering extends far beyond banks, using trade, goods, shell companies, and cross-border tax systems.
  3. 3Regulation struggles when governments benefit from money issuance while enforcement agencies lack the capacity to analyze financial intelligence.

Don't miss

Bullough explains how carousel VAT fraud used shell companies and repeated cross-border transactions to generate fraudulent refunds.

The brief

Oliver Bullough joins Tracy and Joe to examine why $100 bills keep circulating as everyday cash use declines, linking the banknote paradox to the global infrastructure of illicit finance.

The discussion moves beyond regulated banks to cash smuggling, trade-based laundering, Chinese wealth transfers, and carousel VAT fraud, where goods and paperwork can move value across borders.

Bullough argues that stablecoins preserve several advantages of trade-based laundering while making value digital, adding a new channel to criminals’ choices among currencies and assets.

The episode’s central tension is political: central banks profit from issuing widely demanded notes, while the harms of cash-enabled crime remain diffuse and difficult to reform.

Suspicious activity reports can help investigators, but only when agencies have the staffing, technology, and analytical capacity to turn enormous volumes of filings into intelligence.

What was said on this episode

17 statements · 4 positive · 5 negative · 1 mixed · 7 neutral

  1. Oliver Bulloughon Global money launderingNeutral6:49

    Global money laundering is estimated at 2%–5% of GDP, or $2–$5 trillion annually.

    “the most widely used estimate is that we're talking about between 2% and 5% of global GDP. And since global GDP is approximately $100 trillion, that means between $2 and $5 trillion being laundered globally.”

    Listen at 6:49

  2. Oliver Bulloughon Anti-money-laundering effortsNegative8:54

    Anti-money-laundering efforts have largely failed to reduce the criminal economy’s share.

    “if the... scale or the share of the global economy that is criminal is the same now as it was in the 1990s. It means that everything we've done to try and tackle money laundering, which has been an awful lot since the late 90s, has essentially failed to do anything except perhaps prevent the criminal economy from getting bigger.”

    Listen at 8:54

  3. Oliver Bulloughon Global AML complianceNeutral10:57

    Global compliance with AML legislation costs approximately $200 billion annually.

    “the estimates from LexisNexis is that global compliance with AML legislation costs something like $200 billion a year”

    Listen at 10:57

  4. Oliver Bulloughon Current anti-money-laundering systemNegative11:40

    The current AML system generates many reports but fails to stop money launderers.

    “But it's not working. The system that we have is incredibly laborious, very bureaucratic. It generates, as you say. millions upon millions of suspicious activity reports every year, but it is signally failing to stop the money launderers who are always at least one step ahead.”

    Listen at 11:40

  5. Oliver Bulloughon Global cash smugglingNeutral13:21

    Global cash smuggling amounts to hundreds of billions of dollars annually.

    “Global cash smuggling is certainly in the hundreds of billions annually. Cash is a hugely significant tool for moving illicit wealth around the world.”

    Listen at 13:21

  6. Oliver Bulloughon Trade-based money launderingNeutral14:24

    Trade-based money laundering moves approximately $1 trillion annually.

    “Global Financial Integrity, that estimates that that's about a trillion dollars a year. It's moved via trade-based money laundering.”

    Listen at 14:24

  7. Oliver Bulloughon European carousel fraudNegative26:56

    Carousel fraud in Europe is currently a €50 billion annual problem.

    “But it just... crossed into the rest of Europe, where now it's a 50 billion euro a year problem, carousel fraud.”

    Listen at 26:56

  8. Oliver Bulloughon U.S. currency in circulationNeutral31:32

    Nearly $2.5 trillion in U.S. currency is currently in circulation.

    “In the US, it's almost 2.5 trillion US dollars in circulation.”

    Listen at 31:32

  9. Oliver Bulloughon Euro and dollar banknotes abroadNeutral33:50

    About half of euro banknotes and roughly 65% of dollar banknotes circulate outside their issuing regions.

    “The European Central Bank reckons about half of euro banknotes are outside the eurozone. The Fed reckons sort of something like 65%, maybe, of dollar banknotes are outside the United States.”

    Listen at 33:50

  10. Oliver Bulloughon SeignioragePositive35:48

    Seigniorage is the profit generated by issuing paper money.

    “the profit that is made from issuing paper money”

    Listen at 35:48

  11. Oliver Bulloughon Large-denomination banknotesNegative38:48

    Large-denomination banknotes enable crime on a geopolitical scale.

    “the products are enabling crime on a geopolitical scale”

    Listen at 38:48

  12. Oliver Bulloughon StablecoinsNeutral44:49

    Stablecoins are the main cryptocurrency used in money laundering.

    “Specifically, we're really talking about stable coins when we talk about crypto being big in money laundering.”

    Listen at 44:49

  13. Oliver Bulloughon Cash and cryptoMixed45:40

    Cash is most useful locally, while crypto efficiently moves illicit value internationally.

    “cash remains the most useful criminal tool at a street level. But it's bulky. not secure. It's kind of annoying and smelly. It's annoying to count and so on. So if you can get away from using that as quickly as possible in order to move it around the world, that's where crypto comes in and is super useful.”

    Listen at 45:40

  14. The U.S. dollar, especially $100 bills, remains dominant in global criminal transactions.

    “the dollar remains the lingua franca of global criminality, the $100 bill, just because it is a much deeper, more liquid market”

    Listen at 48:13

  15. Oliver Bulloughon Debanking from AML and CTF restrictionsNegative51:24

    AML and counterterrorism-financing restrictions have caused widespread debanking, disproportionately affecting Muslims.

    “We haven't talked about debanking, but that is a serious issue, both in politics, but I think more broadly, globally, that affects hundreds of thousands of people, mostly Muslims, but others too, as a really grotesque side effect of anti-money laundering and anti-terrorist financing. restrictions.”

    Listen at 51:24

  16. Oliver Bulloughon Suspicious activity reportingPositive54:08

    AML systems should produce fewer suspicious activity reports that authorities actually analyze.

    “it would be far better to have fewer suspicious activity reports that were actually being read.”

    Listen at 54:08

  17. Tracy Allowayon StablecoinsPositive57:58

    Stablecoins finance U.S. government debt by investing substantial reserves in Treasuries.

    “if you think of stable coins as something that nowadays finances U.S. government debt because a lot of the money goes into U.S. treasuries”

    Listen at 57:58

Statements are attributed to the speaker as said on the episode and reflect their view at the time, not PodLume's. They are not advice.

Books & mentions

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