Countering Illicit Finance Essay Paper

Countering Illicit Finance

A number of mechanisms have been devised by various agencies to counter illicit finance. The United States Immigration and Customs Enforcement (ICE) have in particular waged a significant battle on money laundering with a view to combating transnational criminal organizations

(TCO). This paper seeks to enumerate the successful and unsuccessful practices in countering illicit finance noting why the practices have either been successful or unsuccessful.

The proceeds from illicit finances and money laundering activities are used to fund criminal activities. The ICE works in partnership with the United States Customs and Border Protection (CBP) to dismantle transnational criminal activities. Homeland Security Intelligence (HSI) has come up with a raft of measures to counter illicit finance. It particularly examines the manner in which individuals and criminal organizations earn, move, store, and launder their illicit proceeds. The HIS engages in financial investigations, does reporting as per the Banks Secrecy Act

, and also intensifies anti-money laundering compliance among financial institutions. The efforts that have been made by HSI have forced criminal organizations that depended on illicit finances to seek other alternatives like the money service business (MSB), pre-paid access devices, and bulk cash smuggling. HSI enforces and investigates money laundering and bulk cash smuggling violations. In 2011 alone, the HSI special agents initiated at least 4000 financial investigations which culminated into the arrest of 1770 people and indictment of over 1000 criminals. Of these over 1040 were convicted and seizures worth $359 realized

To address issues pertaining to bulk cash smuggling, the HSI has set up the National Bulk Cash Smuggling Center (BCSC) in cooperation with El Paso Intelligence Center

. The center acts as an investigative support and operations facility. The center assesses bulk cash smuggling threat and eventually develops a strategic plan to address the problem. The center also engages in analysis of the movement of bulk cash in a systematic manner while the HSI develops enforcement operations that are designed to combat various methodologies employed by trafficking bodies. The targeted approach enables BCSC to efficiently and effectively utilize its interdiction and investigative resources. The BCSC activities have resulted into 132 seizures totaling to $65.8 million. A total of 319 criminal arrests have been made. Ninety six people have been indicted in the federal court while 68 convictions have been made at the state courts

. The BCSC trains and rolls out outreach programs to over 21,000 state, federal, and international partners. The BCSC in conjunction with HSI have coordinated with its field officers in destinations like St. Louis, Missouri, and Colorado to mention but a few in support of a controlled delivery of illicit bulk cash.

The Homeland Security Intelligence also uses Operation Firewall to disrupt movement of bulk cash destined for borders, and internationally via commercial and private passenger vehicles, commercial airline shipments, and pedestrians. Operations Firewall urgently uses surge operations that target the movement of bulk cash destined for and crossing the U.S. borders with Mexico and Canada

. Operation firewall and surge operations are an example of joint interdiction efforts that brings foreign law enforcement bodies on board. The operation firewall has achieved a lot in terms of disrupting movement of bulk cash since more than 6700 seizures totaling in more than $621 millions have so far been made. Courtesy of operation firewall, international seizures have also been made.

The ICE’s cornerstone outreach initiative has done much with regard to countenance of illicit finances. The cornerstone outreach initiative has partnered with the private sector to systematically and strategically identify and eliminate vulnerabilities in the financial systems that criminals can take advantage of . Through this initiative, HSI builds domestic and international partnerships by sharing law enforcement trends and methods with businesses that manage systems that international criminals seek to exploit. The Homeland Security Intelligence shares whatever it learns through its investigations with the private sector to assist in identifying and preventing criminals from capitalizing on weaknesses in financial systems. In essence, the Homeland Security’s special agents are subject matter experts in money laundering methods like fraud, money service business, casinos, and alternate remitters

Some international criminal organizations accrue proceeds from illicit activities under disguise that they are engaged in legitimate trade

. Criminal gangs do exploit global trade networks using confusing documentation associated with legitimate business transactions. Such criminals ideally make use of Trade-Based Money Laundering (TBML). This is a scheme that Colombian drug cartels have capitalized on. Homeland Security Intelligence has in this regard instituted Trade Transparency Unit (TTU) to counter TCOs resolve to launder illicit proceeds through manipulation of international trade and financial systems. The TTU partners with foreign nations to exchange trade data

. It has partnered with Mexico, Panama, Brazil, Colombia, Ecuador, and Paraguay to mention but a few countries with a view to identifying, investigating, and prosecuting international criminal gangs that engage in TBML. The ICE, ITU, and intelligence analysts in the field together with the foreign customs and law enforcement agencies responsible for border control and enforcement of financial crimes make use of TTU’s computer systems called the Data Analysis and Research for Trade Transparency System (DARTTS) to analyze trade and financial data. The TTU’s computer system can identify international trade anomalies and financial irregularities that point to engagement in TBML, custom fraud and smuggling. The system is capable of analyzing large amounts of data within a short period. This helps in maximization of limited time and resources. DAARTS helps in initiating and furthering criminal investigations

. A number of countries have shown interest in developing their TTU. Countries like Colombia and Guatemala that have established their TTU currently receives funding and support from State Department’s Bureau of International Narcotics and Law Enforcement Affairs.

Prepaid access devices are currently used in illicit cash transfers. Money launders make use of open loop prepaid access devices because they can easily be made use of at point of sales terminals. These cards are also use by money launders because they are widely accepted by hotels and car rental agencies. Money launders prefer prepaid access devices to bulk cash because their portability makes it extremely difficult to detect as could be the case with bulk cash. The dangers that prepaid cards posed to the United States economy prompted the enactment of the Credit Card Accountability, Responsibility, and Disclosure Act of 2009 that became law in May 2009

. The law has compelled the U.S. Department of Treasury and Department of Homeland Security to address risks associated with prepaid cards. The Homeland Security Intelligence works in conjunction with other law enforcement agencies and Financial Crime Enforcement Network to address the dangers prepaid devices poses to the entire economy. This has culminated into the publication of Bank Secrecy Act


Department of Homeland Security, (2012). “Written testimony of U.S. Immigration and Customs Enforcement Homeland Security Investigations Investigative Programs

Assistant Director Leigh Winchell for a Senate Committee on Homeland Security and Governmental Affairs, Permanent Subcommittee on Investigations hearing titled “U.S.

Vulnerabilities to Money Laundering, Drugs, and Terrorist Financing: HSBC Case

History”16 Jul. 2012.

Baker, Raymond, Eva, Joly, “Illicit Money: Can it Be Stopped?” 23 Jul. 2009.

World Bank, Stolen Asset Recovery (StAR) Initiative: Challenges, Opportunities, and Action

Plan. New York: World Bank, 2007.

Schneider, Friedrich, Money Laundering and Financial Means of Organized Crime: Some

Preliminary Empirical Findings. Linz: Johannes Kepler University Press, 2008.

Department of Homeland Security “U.S. Vulnerabilities to Money Laundering, Drugs, and Terrorist Financing: HSBC Case History” 16 Jul. 2012.

Department of Homeland Security “U.S. Vulnerabilities”

Department of Homeland Security “U.S. Vulnerabilities”

Department of Homeland Security “U.S. Vulnerabilities”

Department of Homeland Security “U.S. Vulnerabilities”

Department of Homeland Security “U.S. Vulnerabilities”

Department of Homeland Security “U.S. Vulnerabilities”

Raymond, Baker, Eva, Joly. “Illicit Money: Can it Be Stopped?” 2009. 20 Apr. 2013

Raymond, Baker & Eva, Joly. “Illicit Money: Can it Be Stopped?”

World Bank. Stolen Asset Recovery (StAR) Initiative: Challenges, Opportunities, and Action Plan (New York: World Bank, 2007)

Friedrich, Schneider, Money Laundering and Financial Means of Organized Crime: Some Preliminary Empirical Findings

(Linz: Johannes Kepler University Press, 2008).

Department of Homeland Security “U.S. Vulnerabilities”

Department of Homeland Security “U.S. Vulnerabilities”

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