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Money Laundering 101: Ten Ways to Place Dirty Money


FAIRFAX, Virg., July 26, 2002 Anti-laundering expert Don Temple outlined the 10 most common techniques used to launder money.



The following list represents several of the methods used by money launderers to accomplish the first stage of money laundering, the placement stage.
 
Did You Know That Money Launderers...
   
1. Often exchange small denomination bills for one hundred dollar bills. This reduces the bulk of the currency several fold and makes it easier to conceal and transport.
   
2. Purchase monetary instruments such as money order, travelers checks, bank drafts, cashiers checks, treasurers checks, and official bank checks with currency in amounts below the $3,000 record-keeping thereby reducing the bulk of currency.
   
3. Purchase the monetary instruments mentioned above in increments just below the $10,000 Currency Transaction Report threshold. This will result in the financial institution identifying the purchaser and maintaining a log of these transactions; however, money launderers recognize that the log is not filed with the government.
   
4. Bulk ship currency to a jurisdiction with bank secrecy laws. Although a Currency and Monetary Instrument Report must be filed with the U. S. Customs Service anytime currency and/or monetary instruments are exported from the U. S. or imported into the U. S. money launderers do not file the report. Section 371 of the USA PATRIOT Act makes bulk shipping cash into or out of the United States a crime.
   
5. Recognize that financial institutions report repeated deposits of just under $10,000. Therefore many money launderers will open several accounts in the names of family members and possibly friends at several financial institutions and deposit small amounts of currency in each account. The deposited amount in these situations may be less than $1,000 on a daily basis or $2,000 to $3,000 twice or possibly three times a week. These deposited amounts remain below the thresholds of any known internally developed monitoring system and would probably only be detected using comprehensive technology along with a compliance team.
   
6. May purchase a currency generating business to launder funds. Money launderers have used businesses such as restaurants and service/gasoline stations. These businesses serve as both a method to place and layer dirty money simultaneously.
   
7. Use electronic transfers to move dirty money. A money launderer may fund an electronic transfer with up to $3,000 in currency without providing identification. These funds can be rapidly transferred anyplace in the world. In many cases the money launderer may request that a representative of a money service business (MSB) execute several wire transfers during the course of a day all below the $3,000 record-keeping threshold. The money launderer will normally offer the MSB employee a bribe for the accommodation.
   
8. May elect to execute electronic transfers below the $3,000 record-keeping threshold at several financial institutions. Doing this will keep these transfers under the radar screen since they are small increments and they are being distributed to multiple places.
   
 9. Purchase a big-ticket item such as a car and use currency to pay down loans at an accelerated rate. The dealership is required to file a currency report if the money launderer uses currency and/or monetary instruments with a face value of $10,000 or less and the total value of the currency and the monetary instruments aggregates to over $10,000. Financing the automobile and making accelerated payments on the loan will evade the filing of a currency report.
   
10. Attempt to disassociate themselves from the proceeds of a fraud quickly. Money launders may deposit the fraudulent proceeds into an account and almost immediately withdraw those funds in the form of currency at various branches of an institution or via ATMs.
 
DON TEMPLE works with financial institutions to develop business requirements and provide assessment services in the areas of compliance planning, programs, and training, at Mantras, a provider of behavior detection software solutions for the financial services industry. Prior to joining Mantras, he spent 26 years with the IRS where he served as a Special Agent and headed a fraud investigation task force.
 

2002 SmartPros Ltd. All Rights Reserved.

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