FinCEN Reporting Requirement To Cross-Border
Wire Transfer Will Increase Bulk Cash Smuggling?
DIFFERENT POINT OF VIEW by Monte Friesner
Financial Crime Consultant for WANTED SA
Thursday October 07, 2010
"FinCEN to Require Banks & MSBs to Report International Wire Transfers!" This was a previous article that I posted on WANTED SA and I know that after the 90-day comment period; the regulation will most likely become law.
You can be certain that money launderers for Colombian and Mexican narcotics kingpins read all new information appearing on the FinCEN website at least once a day and you can; therefore, expect them to respond swiftly to the new requirement that all international wires will be reported to regulators.
What will their knee-jerk reaction most likely be? We all may be surprised, but I believe that they will resort to the time-tested techniques of bulk cash smuggling, which is highly effective, and which has a low probability of discovery and interdiction.
More expensive power yachts will be purchased to ship the illegal cash into Colombia from the USA and Europe. This of course will increase the profits on yacht builders and maybe some will actually build yachts for that specific purpose. Implanting cash into Lead Keels is also a very old but effective method and of course undetected.
If I was still in the money laundering business, and I learnt about the new FinCEN regulation, I would immediately expand my bulk cash smuggling operations out of the Continental US. Why?
Because I do not want US law enforcement agencies to see my outbound wire transfer information for if I am a typical laundryman for Narco Traffickers; I have been using wires extensively to move dirty money. I do not want law enforcement to see those transfers, so I will discontinue the use of wire transfers, and concentrate on bulk cash smuggling.
I fear that the loss of the wire transfer exit avenue, except on a very small and infrequent scale, will drive laundrymen back to the crude (but effective) method of using surface, air and sea assets to smuggle bulk cash south in 2011. Let us hope that American and European Law Enforcement Agencies are up to the task of interdicting a large increase in dirty cash, for it is coming soon to US borders, both on the ground and aloft.
The facts and opinions stated in this article are those of the author and not those of WANTED SA. WANTED SA does not warrant the accuracy of any facts and opinions stated in this article; does not endorse them, and accepts no responsibility for them.