Wednesday, February 19, 2014


The unofficial exchange rate, between the US Dollar and the Venezuelan Bolivar, has mushroomed past 85-to-1, and is predicted to hit 100-to-1 in the short term. Inasmuch as dollars are becoming impossible to obtain in Venezuela, businessmen who must have that currency to engage in international trade, are resorting to extreme measures to obtain it.

This means that some currency brokers are known to be purchasing narco-dollars from individuals engaged in money laundering for their criminal clients. This cash is then being used to purchase imports, and ends up being deposited in financial institutions outside Venezuela, especially in the United States.

Compliance officers at US banks should alert their front-line staff and tellers to watch for structured cash deposits from customers who operate businesses in Venezuela. Should the narcotics traffickers and money launderers who are vending the dollars subsequently be charged, and arrested in the United States, there is a strong possibility that, to reduce their sentences, that they will cooperate with law enforcement, and therefore give up information regarding who they sold dollars to.

When as bank unwittingly accepts large cash deposits from a foreign customer, and does not made diligent inquiry as to Source of Funds, it can be charged with Willful Blindness, which is a money laundering offense. Please ensure that none of your well-meaning customer relationship officers allow bulk cash deposits from a Venezuelan customer, intending to assist him in paying for his imports, unwittingly committing one or more money laundering offenses.

Should you decline to accept any large cash deposits from Venezuelan clients, given the chaos the country is presently experiencing ? That is a judgment call, but if it were me, I would refuse any such attempted deposits.

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