Last year, when a tiny Miami credit union, whose sole task was to serve a local, minority clientele, was hit was a $300,000 FinCEN civil penalty, after being a conduit for 39 foreign MSBs, who moved over two billion dollars through its storefront office, it was assumed that this was the tip of the iceberg. We trusted that the 39 guilty foreign money service businesses, many in the Middle East, would be properly identified, for the benefit of the Florida banking community, and that local arrests for money laundering would follow.
Not quite a year later, not one single credit union officer, director or staff member at North Dade has been indicted, and I have little hope that justice will be served. Credit union officers, like bankers, need to be held strictly accountable for money laundering crime. Around the United States, credit unions saw the North Dade case, and duly noted that, other than a monetary penalty, which was certainly affordable, given the high volume of international money laundering going on there, there were no consequences suffered by the guilty officers and directors. That is what we call zero deterrent, meaning that the case sent the word out: slaps on the wrist only at credit unions, for financial crime.
I personally fear that there may have been political reasons for the failure to charge credit union officers and directors; North Dade, serving a minority clientele, was governed by minorities, including certain local professionals whose indictment would have stirred up a hornet's nest, due to their connections and associations with local political figures, who would have rushed to defend their friends, and possibly made statements that could have polarized the community. Were there no indictments purely to keep the peace, and avoid incendiary charges ? These are difficult questions, I know but if the evidence was there, why were no indictments handed down in this matter ? Who killed this case ?
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