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IP: The Money Laundromat part 2 of 2
From: Dave Farber <farber () central cis upenn edu>
Date: Sat, 28 Oct 1995 17:34:56 -0400
for transactions, but it may read off your name, as when it says, "Thank you, Jow Blowup, for allowing me to serve you." The second track contains up to 40 numerical figures, of which the first 19 are reserved for your PAN, which is followed by the expiration date and other information. The third track will hold 107 numerical digits [isn't this redundant?], starting again with your PAN, and perhaps information related to your PAN (personal identification number, or "secret password"), along with other information, all of which potentially gets rewritten every time the track is used. The ATM machine into which you insert your card is itself a computer. The ATM typically has both hard and floppy drives, a PC motherboard that contains the microprocessor, and a power supply -- as well as drawers for deposits, cash and swallowed cards. If the ATM is "on-line" (i.e., connected to a distant central bank computer, which makes all the real decisions), then it also has a modem to communicate over phone lines with the central computer. When you make a request for cash, the ATM machine compares your password to the one you entered. If they are the same, it then takes your request and your PAN, encrypts the information, and sends it on to the central computer. The central computer decrypts the message, looks at your account information, and sends an encrypted message back to the ATM, telling it to dispense money, refuse the transaction, or eat your card. Somewhere between the ATM and the authorizing bank, there is usually a "controller", which services several ATMs. The controller monitors the transaction, and routes the message to the correct authorization processor (bank computer). Some transactions, for example, will involve banks in different ATM networks, and the transaction will have to be transferred to a different network for approval. The controller would also generally monitor the status of the different physical devices in the ATM -- to see that they are operating properly and that the machine is not being burglarized. Consider some of the security problems in this framework. The first duty of the local ATM is to verify you've entered the correct PIN. A typical way of doing this is to recreate your PIN from your card information and ocmpare it to the one you entered. Here is a general example of how PINs are created (there are many variations). The bank first chooses a secret 16-digit "PIN key" (PKEY). This key will be stored in the ATM's hardware. The PKEY is then used as a DES encryption key to encrypt 16 digits of your account number, which the ATM reads off your card. The result of the encryption is a 16-digit hexadecimal number. Hexadecimal numbers use the digits 0 to 9 and also the letters A to F (the latter standing for the decimal numbers 10 to 15). Next, a table is used to turn the 16-digit hexadecimal number back into a 16-digit decimal number. (23) The first four digits of the resulting 16-digit number are the "natural PIN". (If you are allowed to choose your own PIN, a four-digit "offset" number is created, and stored on the third track of your ATM card. This offset will be added to the natural PIN before it is compared to the one you entered at the ATM keyboard.) Since this comparison between the natural and entered PIN is done locally in the ATM hardware, the customer's PIN is not transmitted over phone lines. This makes the process relatively more secure, assuming noone knows the PKEY. But if an evil programmer knows the PKEY, he can create a valid PIN from any customer's account number. (Customer account numbers can be found by the hundreds on discarded transaction slips in the trash bin.) He can easily and quickly loot the ATM of its cash contents. The security problems worsen when the ATM gets a "foreign" card. A foreign card is essentially any card from any bank other than the one that runs the ATM. The local ATM does not know the PKEYs of these other banks, so the PIN that is entered at the ATM must be passed on to a bank that can authorize the transaction. In this process, the account number and PIN will be encrypted with a communication key (COMKEY), and then passed from the ATM to the ATM controller. Next, the account number and PIN willl be decrypted at the controller, and then re-encrypted with a network key (NETKEY) and sent on to the proper bank. Foreign PINs give the evil programmer three additional possibilities for defeating security. The first way is to get hold of the COMKEY. He then taps the line between the ATM and the controller, and siphons off account number/PIN pairs. A second possibility is to get access to the controller, because the account number/PIN pairs may be temporarily in the clear between encryptions. The third possibility is to obtain the NETKEY, and tap the line between the controller and the foreign network. (24) The COMKEY and NETKEY are generally transmitted over phone lines, so the chances of acquiring them are pretty good. These two encryption keys are themselves usually transmitted in an encrypted form, BUT THE KEYS USED TO ENCRYPT THEM ARE SOMETIMES SENT IN THE CLEAR. Thus, while banks are generally somewhat careful with their own customers, they are often quite helpful in giving rip-off artists access to the customers of other banks. The evil programmer simply reads off the encryption keys and uses them to decrypt the COMKEY and NETKEY, which are in turn used to decrypt account numbers and PINs. The way to solve these security problems is to use smart cards and public key cryptography. That way, banks could transmit their public keys in the open without worrying about evil wire-tapping programmers. Customer messages encrpyted with a bank's public key could only be decrypted with the bank's private (secret) key. Digital cash issued by the bank could be signed with the bank's private key, and anyone would be able to check that the cash is authentic by using the bank's public key. In addition, the bank would not be able to repudiate cash signed in this way, because only the bank had access to its own secret key. Communications between ARM machines and bank computers could also take polace with randomly-generated encryption keys that can be determined by each of the two parties, but which could not be discovered by someone who listens in on both sides of the traffic. (25) ARE SMART CARDS THE MARK OF THE BEAST? Besides optical and magnetic stripe cards, there are two types of "chip" cards. Chip cards are basically any cards with electronic circuits embedded in the plastic. One type of chip card, called a memory (or "wired logic) card, doesn't have a microprocessor and isn't any smarter than the cards we discussed previously. Prepaid phone cards are of this type. They may have about 1K of memory, and can execute a set of instructions, but can't be reprogrammed. Then there are the truly smart cards, which have a microprocessor and several kilobytes of rewriteable memory. Smart cards allow for greatly increased security, since access to their data is controlled by the internal microprocessor. And there can be built-in encryption algorithms. This versatility has made smart cards controversial. The negative reputation arises from certain cases where smart cards were imposed by force, as well as from smart-card storage of biometric data. The use of smart cards became a prerequisite for Marines to receive paychecks at Parris Island. Fingerprint-based smart card ID systems were implemented by the Los Angeles Department of Public Social Services and the U.S. Immigration and Naturalization Service. The "childhood immunization bill" introduced by Sen. Ted Kennedy (D-Mass.) would have used smart cards to track vaccinations of all children under six years of age, together with at least one parent, across geographical areas. Access control at the U.S. Department of Energy Hanford Site requires smart card badges that store the cardholder's hand geometry. Security access through retinal scan patterns stored in smart card memory have been tested at the Sandia National Laboratory. Visa recently announced plans for creating an "electronic purse". The purse would be a reloadable spending card. You would charge the card up at an ATM machine, where it would suck some cash value out of your account and store it in memory. You would then use the card instead of cash to make small purchases. Visa is attracted by the estimate that consumer cash transactions in the U.S. are about five times the size of bank-assisted transactions (those that use checks, credit cards and debit cards). Visa has been joined in this endeavor by a consortium that invludes VeriFone, the leading supplier of point-of-sale transaction systems, and Gemplus, the leading manufacturer of smart cards. There may be increased security in the use of an electronic purse, but it is not clear how replenishing one's card balance at an ATM is any more convenient for the user than getting cash at an ATM. Since Visa is not advertising the privacy aspects of electronic purse payments, one must assume this feature was omitted in the planning. Hence a cynic could conclude that the "electronic purse" is little more than a Rube Goldberg device which, by substituting for cash, will create a better set of PROMIS-type transaction records. These and other examples suggest possible uses of smart cards for more general surveillance and social control. The truly paranoid envision the use of a single smart card for every financial transaction, medical visit, and telephone call. This information would be sent directly to a common PROMIS-like database, which would constitute a record of all your activities. In addition, they suggest, "your card could be programmed to transmit its identification code whenever you use it. So you (or your card, anyway) could be instantly located anywhere on earth via the satellite-based Global Positioning System." (26) But smart cards don't have to be used this way. Recall that mainframe computers once seemed destined to turn the average citizen into Organization Man, a creature to be folded, spindled and mutilated in lieu of IBM's punched cards. The advent of the personal computer, however, showed that the same technology could be a tool of individual freedom and creativity. There is nothing intrinsically evil in storing a great deal of information about ourselves, our finances, and our current and future plans. That is, after all, exactly why some of us carry around portable computers. But in this case the use of the computer is voluntary, and we ourselves control both access to and the content of the information. The same may apply to smart cards. It is smart cards more than any other aspect of banking technology, I believe, that will allow for financial privacy through cryptology, for anonymous and secure digital cash transactions. It's simply a matter of taking control of the technology and using it to enhance personal freedom. ELECTRONIC CASH, the Way It Ought to Be Suppose we had it our way. Suppose we sat down to create digital cash that had all the right properties. What would these be? Think of the attractive properties of currency -- physical cash. (27) 1) Physical cash is a portable medium of exchange. You carry it in your pocket to give to people when you make purchases. The digital equivalent of this process could be provided by smart cards, which would actually improve on the mobility of physical cash: the weight of $1,000,000 in digital money is the same as the weight of $1. 2) You would want the ability to make digital cash payments offline, just like you can with physical cash. A communication link between every store you shop at and your bank's authorization computer shouldn't be required. Moreover, if digital cash is to have all the desireable qualities of physical cash, you should be able to transfer it directly to another smart-card carrying individual. Smart cards that could connect directly to other smart cards would be ideal in this respect, and would represent an improvement over physical cash. Even if everyone observed two smart cards communicating, they would have no way of knowing whether the transaction involved $5 or $50,000. There would be no need to slide money under the table. 3) Digital cash should be independent of physical location -- available everywhere and capable of being transferred through computers and other telecommunications channels. So we want a smart card that can jack into the communications nodes of the global information network. One should be able to pop into a phone booth to make or receive payments. 4) Got change for a dollar for the quarter slots in the pool table? Just as we "make change" or divide physical currency into subunits, so should electronic cash be divisible. Electronic calculators can perform an operation known as division, and so can third-graders. So smart cards ought to be able to handle this also, even if it presents a few difficulties for theoretical cryptology. 5) To be secure against crooks and rip-off artists, digital cash should be designed in such a way that it can't be forged or reused. We wouldn't want people spending the same money twice, or acting as their own miniature Federal Reserve System, creating money from nothing. This cryptological problem is different between on-line and off-line cash systems. In on-line systems, the bank simply checks whether a piece of cash has been spent before. Proposed off-line systems rely on a framework developed by David Chaum. Chaum has been the preeminent cryptological researcher in the field of digital cash. (28) In his framework for off-line systems, one can double-spend the same piece of cash only by losing one's anonymity. This has considerable value, because the bank or person, knowing the identity of the devious double-spender, can send out a collection agent. But I consider this way of enforcing the "no double=spending" rule a serious flaw in Chaum's framework. Catching thieves and rip- off artists is not the comparative advantage of either banks or the average citizen. (Banks are usually only good at providing transaction services, and charging interest and fees.) Would you really want to see, say, the First Subterranean Bank of Anonymous Digital Cash merge with the Wackenhut Corporation? Luckily, however, there are alternative approaches that will prevent double- spending from ever taking place. (29) 6) The most important requirement for individual freedom and privacy is that digital cash transactions should be untraceable, yet at the same time enable you to prove unequivocally whether you made a particular payment. Untraceable transactions would make impossible a PROMIS-type data-sorting og all your financial activities. In Joe Blowup's financial chronology discussed previously, you wouldn't be able to connect Joe Blowup's name to any of his purchases. Similarly, noone would know about the money you wired to Liechtenstein, your purchase of Scientology e-meters and the banned works of Maimonides, or your visits to the Mustang Ranch. Privacy-protected off-line cash systems can be made nearly as efficient as similar systems that don't offer privacy. PARALLEL MONEY SYSTEMS To set up a digital cash service meeting these requirements, you would need to buy the rights to use patents held by David Chaum and RSA, or equivalent rights, and then set up a bank to issue accounts and smart cards in a legal jurisdiction where the service won't run afoul of the local banking and money laundering laws. Of course, in many other countries the money laundering statutes will be quickly amended in an attempt to apply the same reporting requirements to anonymous digital cash transactions. Such laws will probably generate little compliance. (30) Since the transactions in question are unconditionally untraceable, there won't be any evidence of wrongdoing. Anonymous digital cash will arise as a parallel system to the existing one of ordinary money. Therefore, there will be a record of the initial entry into the anonymous system. For example, you might write a $10,000 check drawn on CitiBank to the First Subterranean Bank of Anonymous Digital Cash. This check will be recorded, but no subsequent transactions will be traceable, unless you make transfers back out into the ordinary banking worls. Over time, as more people begin to use the anonymous cash system, some wages will be paid in anonymous digital cash. This will enable all income transactions, as well as expenditures, to take place entirely outside the ordinary monetary system. Since the anonymous cash system will exist parallel to the existing system, a floating exchange rate will be created by market transactions between ordinary money and anonymous money. Think, by analogy, of a currency board. Such a board issues domestic currency through the purchase of foreign "hard" currencies. In the same way, anonymous digital cash will be issued through the purchase of ordinary cash or bank deposits. That is, when you make a deposit at the First Subterranean Bank of Anonymous Digital Cash, First Subterranean will issue you an anonymous digital cash account, and will in turn acquire ownership of the ordinary money. The exchange ratio will not necessarily be one-for-one: anonymous digital cash that does not meet some of the ease-of-use requirements listed previously may exchange for less than one ordinary dollar. On the other hand, digital cash that meets all those requirements will trade at a premium, because anonymous digital cash has enhanced privacy aspects. Money launderers, for example, currently get about 20% of the value of money that is made anonymous. That represents an exchange rate of 1.25 "dirty" dollars for one "clean" dollar. The market will similarly determine the exchange ratio between ordinary and anonymous digital money. In the 1960's, various tax and regulatory burdens and political risk considerations gave rise to a new international money market, the Eurodollar market, which was created specifically to get around these regulatory and political roadblocks. (31) When a junior staff member of the Council of Economic Advisors named Hendrik Houthakker discovered the Eurodollar market's existence, he thought it was an important development, and recommended that some discussion of it be included in the annual *Economic Report of the President*. "No, we don't want to draw attention to it," he was told. When Houthakker himself later became a member of the Council under Nixon, he made sure the Report included a discussion of the Euromarkets. But it was only much later, in the mid-70's, that the *Report* said, in a burst of honesty: "The emergence and growth of the Eurodollar market may be viewed as a classic example of free-market forces at work, overcoming obstacles created by regulations, and responding to market incentives to accomodate various needs." (32) In a similar way, some future report will say that "the emergence and growth of anonymous digital cash may be viewed as a classic example of free-market forces at work, overcoming obstacles created by surveillance technologies and money laundering regulations, and responding to market incentives to accomodate the public's need for financial privacy." FOOTNOTES 1. Quoted in *Money Laundering Bulletin*, January 1995, p. 3. 2. Bryan Burrough, _Vendetta: American Express and the Smearing of Edmond Safra_ (HarperCollins, 1992), pp. x, xi. 3. Sec. 1517 (c) states: "Any financial institution that makes a disclosure of any possible violation of law or regulation or a disclosure pursuant to this subsection or any other authority, and any director, officer, employee, or agent of such institution, shall not be liable to any person under any law or regulation of the United States or any constitution, law, or regulation of any State or political subdivision thereof, for such disclosure or for any failure to notify the person involved in the transaction or any other person of such disclosure." 4. "A completely cashless economy *where all transactions were registered* would create enormous problems for the money launderers" (emphasis added), *Report of the Financial Action Task Force on Money Laundering*, February 7, 1990. 5. Kirk W. Munroe, "Money Laundering: The Latest Darling of the Prosecutor's Nursery", law firm of Richey, Munrow & Rodriguez, P.A., Miami, Florida, 1994. 6. President's Commission on Organized Crime, *The Cash Connection: Organized Crime, Financial Institutions, and Money Laundering* (U.S. Government Printing Office, October 1984). This definition is certainly more coherent than Michael Sindona's circular statement that "laundering money is to switch the black money or dirty money...to clean money." The U.S. definition of money laundering is found in 18 U.S.C. 1956, which was enacted in 1986, and strengthened in 1988, 1990 and 1992. It sets out three categories of offenses: transaction offenses, transportation offenses and "sting" offenses: *Transaction Offenses*: It is a money laundering transaction crime for any person to conduct, or to attempt to conduct, a financial transaction which, in fact, involves the proceeds of specified unlawful activity, knowing that the property involved in the transaction represents the proceeds of some crime, and, while engaging in the transaction, with either (a) the intent to promote the carrying on of the specified unlawful activity, or (b) the intent to commit certain tax crimes, or with the knowledge that the transaction is designed at least in part (a) to conceal or disguise the nature, location, source, ownership or control of the proceeds, or (b) to avoid a cash reporting requirement. *Transportation Offenses*: It is a money laundering transportation crime for any person to transport, transmit or transfer, or to attempt to transport, transmit or transfer, a monetary instrument or funds into or out of the U.S., and, while engaging in the act, with either (a) the intent to promote the carrying on of specified unlawful activity, or (b) the knowledge that the monetary instrument or funds represent the proceeds of some crime, and the knowledge that the transportation, etc., is designed, at least in part, (i) to conceal or disguise the nature, location, source, ownership or control of the proceeds, or (ii) to avoid a cash reporting requirement. *"Sting" Offenses*: It is a money laundering crime for any person to conduct, or to attempt to conduct, a financial transaction which involves property represented to be the proceeds of specified unlawful activity, or property used to conduct or to facilitate specified unlawful activity, said representation being made by a law enforcement officer or by another person at the direction of, or with the approval of, a federal officer authorized to investigate or to prosecute S.1956 crimes, and, while engaging in the transaction, with the intent to (a) promote the carrying on of specified unlawful activity, or (b) conceal or disguise the nature, location, source, ownership or control of the property believed to be the proceeds of specified unlawful activty, or (c) to avoid a cash reporting requirement. 7. See Samuel J. Rabin, Jr., "A Survey of the Statute and Case Law Pertaining to 26 U.S.C. 60501 (Forms 8300)", in Fletcher N. Baldwin, Jr. and Robert J. Munro, *Money Laundering, Asset Forfeiture and International Financial Crimes* *Oceana Publications, 1994, three volumes). 8. Section 4702 of P.L. 100-690. 9. 31 C.F.R. 103.11(p) (1991). 10. "The means should, in fact, include access by Interpol to the telecommunications system SWIFT," *Draft Explanatory Report on the Convention on Laundering, Search, Seizure and Confication of the Proceeds from Crime*, September 8, 1990. 11. *Money Laundering Bulletin*, March 1995, p. 3. 12. Curiously, however, some of the same set of characters were apparently involved on all sides: in drug-running, money laundering and the theft and modication of the PROMIS system. I will leave it to someone with more lawyers, guns and money than I have to bring that part of the story to light. 13. U.S. Congress, Committee on the Judiciary, *The Inslaw Affair*, House Report 102-857, September 10, 1992. 14. Memorandum to Judge Nicholas Bua from Elliot Richardson, p. 34. The NSA, naturally, does not acknowledge the existence of such a chip, much less provide technical information. But in order to avoid detection of the chip's transmission signal by the organization being spied upon, the chip would be designed so its broadcast would be masked by the general -- or some characteristic -- electronic noise of the computer. This could imply a low probability-of-interception digital spread spectrum (DSS) communication system with a broad bandwidth, perhaps with a transmission frequency in the range of 1-10 gigahertz. As a related example of this technique, a "low level wideband SS signal, can easily be hidden within the same spectrum as a high power television signal where each signal appears to be noise to the other." Quoted from "Spread Spectrum Techniques", in Geoff Lewis, *Newnes Communications Technology Handbook* (Oxford, 1994). The broadcast power requirements of such a chip would not be large, but rather similar to a walkie-talkie's. The information broadcast by the chip could then either be monitored locally and re-transmitted to satellite, or transmitted directly to a geosynchronous signals-collection satellite such as Magnum. The Magnum and other U.S. spy satellites are operated by the Air Force on behalf of the National Reconnaissance Office, while NSA does the signal processing. (I am grateful to John Pike, Director of Space Policy & CyberStrategy Projects, Federation of American Scientists, for advice on the information in this footnote. He is not responsible for any errors or the specific content of any statement.) 15. I have in mind an NSA operation. But recently, the CIA approached my own former company (which sells banking software) and proposed that it provide cover for their agents to enter foreign banks. The CIA also separately offered to pay $100,000 for the customer list of a particular bank among the Swiss big four. 16. Barry A.K. Rider, "Fei Ch-ien Laundries -- the Pursuit of Flying Money", in *Money Laundering, Asset Forfeiture and International Finance Crimes*. 17. *Money Laundering Bulletin*, April 1995, p. 2. 18. Ibid, p. 4. 19. Details of the foreign exchange, Eurocurrency and Eurobond markets are covered at length in J. Orlin Grabbe, *International Financial Markets* (Simon and Schuster, 1995, third edition). 20. Eurobonds are *bearer* bonds. So if you have the bond in your pocket, you own it, in the same way you own the dollar in your pocket. The same goes for interest coupons -- they are to be paid to bearer. Most Eurobond-issuing companies pay interest to Euroclear, which distributes the payments to the owners of the bonds stored in its depository vaults. But the companies are afraid that if the bonds are stolen, they will have to pay the same coupons again. Hence they insist coupons be clipped and destroyed as they are paid. When I visited Morgan Guaranty (which operates Euroclear) in Brussels in 1982, there were 20 employees whose full-time job was clipping coupons. 21. John W. Moscow, "The Collapse of BCCI", in *Money Laundering, Asset Forfeiture and International Financial Crimes*. 22. Details of the card size, layout, coding and recording are laid out in ISO standards 7810 to 7813. The first track is sometimes called the International Air Transport Association track, the second the American Bankers Association track, and the third the Mutual Institutions National Transfer System track. 23. This may be as simple as assigning the numbers 0 to 5 to the letters A to F. If this assignment is made, the probability is three-fourths that a digit in the resulting decimal number is one of 0 to 5, while there is only one- fourth probability that a digit is 6 to 9. 24. Computer logs are often kept for each part of a transaction. So the evil programmer doesn't have to tap lines if he can get hold of the logs instead. 25. Public-key encryption is implemented in the Datakey smart card of the National Institute of Standards and Technology. This card uses the Hitachi H8/310 processor. Atmel and Phillips chips also include public-key encryption hardware, and allow algorithms to be implemented by the card's application designer. Smart and other chip card standards are laid out in ISO 7816. More on smart cards can be found in Jose Luis Zoreda and Jose Manuel Oton, *Smart Cards* (Artech House, 1994). The recent ANSI X9F standards include those for using public key systems to secure financial transactions. The communication link would involve two-way authentication using Diffie-Hellman key exchange. 26. From Clark Matthews, "Tomorrow's 'Smart Cards': Technical Marvels That Give Government Fearful Power", reprinted from *The Spotlight*, undated. 27. Some of the following points were broached in a different way by T. Okamoto and K. Ohta, "Universal Electronic Cash", *Advances in Cryptology -- Crypto '91* (Springer-Verlag, 1992.) 28. See David Chaum, "Achieving Electronic Privacy", *Scientific American*, August 1992; "Blind Signatures for Untraceable Payments", in D. Chaum, R.L. Rivest and A.T. Sherman (eds.), *Advances in Cryptology -- Crypto '82* (Plenium, 1983); "Online Cash Checks", in J.J. Quisquater and J. Vandewalle (eds.), *Advances in Cryptology -- Eurocrypt '89* (Springer-Verlag, 1990); "Efficient Offline Electronic Checks", with B. den Boer, E. van Heyst, S. Mjxksnes and A. Steenbeek, in *Advances in Cryptology -- Eurocrypt '89*; "Crytographically Strong Undeniable Signatures, Unconditionally Secure for the Signer" with E. van Heijst and B. Pfitzmann, in J. Feigenbaum (ed.), *Advances in Cryptology -- Crypto '91* (Springer-Verlag, 1992); "Numbers Can Be a Better Form of Cash than Paper", in D. Chaum, *Smart Card 2000* (North Holland, 1991); "Privacy Protected Payments: Unconditional Payer and/or Payee Untraceability", in D. Chaum and I. Schaumuller-Bichl (eds.), *Smart Card 2000* (North Holland, 1989); "Security Without Identification: Transaction Systems to Make Big Brother Obsolete", *Communications of the ACM* 28:10, October 1985; "Smart Cash: A Practical Electronic Payment System", in J. Bos and D. Chaum, *CWI-Report CS-R9035*, August 1990; "Untraceable Electronic Cash", with A. Fiat and M. Naor, in S. Goldwasser (ed.), *Advances in Cryptology -- Crypto '88* (Springer-Verlag, 1989). 29. "[P]rior restraint of double-spending can be achieved by using a tamper- resistant computing device that is capable of merely performing a signature scheme of the Fiat-Shamir type (of one's own choice), such as the Schnorr signature scheme" (Stefan Brands, "Highly Efficient Electronic Cash Systems", Mary 17, 1994.) 30. I highly recommend Henry David Thoreau's essay "Civil Disobedience". 31. These included the interest ceilings set by the Federal Reserve's Regulation Q, Kennedy's Interest Equalization Tax, and the Foreign Credit Restraint Program. See Grabbe, op. cit., chapter 1. 32. *Economic Report of the President*, 1975. .end.
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