Robert Tie, CFE, CFP
Companies are realizing that good anti-money laundering programs can do more than satisfy regulators — they can boost the bottom line by reducing major business risks. Transnational organized crime is more profitable than ever, and money launderers are devising new methods to hide the true source of illicit gains. Here are the U.S. federal government’s latest anti-money laundering efforts plus ways CFEs can help businesses cope with schemes and payment technology risks.
Even when a crime is innovative and unfamiliar, investigators often can associate it with similar cases they’ve solved. New needle — old haystack.
On Jan. 24, in McAllen, Texas, a federal district court judge sentenced 12 people to prison after they pleaded guilty to violating the U.S. statutory requirement (31 CFR 103.23) to declare cash sums greater than US$10,000 when entering or leaving the country. The defendants had concealed US$3.1 million in air mattresses aboard a Mexico-bound commercial passenger bus inspected at the Hidalgo, Texas, border crossing. New cache — old method. U.S. Customs and Border Patrol, which astutely detected the stash, and U.S. Immigration and Customs Enforcement’s Homeland Security Investigations (ICE/HSI) worked the case jointly.
Sometimes, however, money launderers create an entirely new haystack, making detection and prevention harder. To counter such criminal innovations, HSI has redoubled its efforts, particularly with respect to an emerging technique known as trade-based money laundering (TBML). One week after the Texas trial, the corrupt leaders of a California toy wholesaler were convicted of TBML. Here’s how investigators gathered the evidence that made the case.