layered anonymity because of exceptionally lax identification requirements. Furthermore, they worked with unregulated money service businesses that operated using equally lax identification requirements. In doing so, Liberty Reserve charged fees for services rendered to clients, including currency exchanges and money transfers. Liberty Reserve became an ideal method for laundering and transferring monies internationally, with over US$6 billion were allegedly laundered through its channels. On 28 May 2013, prosecutors in the US Southern District of New York brought charges against seven individuals under the USA PATRIOT Act for money laundering and running an unlicensed financial transaction company. The provisions used to target those at Liberty Reserve were not specifically targeting cybercrime.10 The investigation involved operations in at least seventeen countries. This case is indicative both of the ease with which financial cybercrimes can be committed thanks to the connectivity of cyberspace, as well as the potentially very great financial gains that might be had from such crimes. B. Developing Developing Legal Frameworks Despite a wide range of efforts to create a favorable legal environment to tackle cybercrime, challenges persist to assuring adequate legal frameworks. These challenges include, among others, difficulties in: 1  Drafting new and clear11 cybercrime legislation after the recognition of an abuse of new technology and identification of criminal law gaps; 2  Developing procedures for e-evidence; 3  Ensuring the criminalization of new and developing types of internet crimes; 4  Introducing new investigative instruments in response to offenders’ growing use of ICTs to prepare and execute their offences; 5  Promoting technologically neutral laws12; and 6  Balancing security and rights.13 Box 1.1: Computer-facilitated Fraud Involving Illegally-obtained Online Game Items14 Through mobile phones with a built-in SIM card, and thus access to gamers’ IDs, Defendants would use stored credit to repeatedly and fraudulently purchase game products from the Page 30 | Chapter 1 | § C. Challenges to Fighting Cybercrime Table of Contents