Saturday, April 9, 2016


The Miami-Dade County Commission, in a symbolic resolution, has lodged a strong objection to what its feels is undeserved attention from US law enforcement and regulatory agencies, regarding money laundering in Miami. This comes on the heels of the Miami indictment, this week, of 22 individuals for laundering millions of dollars for the Sinaloa cartel, including the principal money launderer for Joaquín "El Chapo" (Shorty) Guzmán.

The Commissioners are objecting to specific US Treasury Department targeting orders, involving 700 import/export firms neat the Miami Airport, and all real estate transactions over one million dollars, that occur in Miami-Dade County. Please allow me to respond, as I believe I have unique qualifications to analyze the issue they have raised, due to my 45 years of experience, working in this city, literally on both side of the money laundering problem.

First, Miami's banks lead the nation in regulatory fines & penalties, for deficiencies in their anti-money laundering and countering the threat of terrorist financing (AML/CFT) programs. Many banks are censured multiple times, and consistently fail to improve their AML programs sufficiently to be removed from regulatory supervision. It appears that they regard those fines as the cost of doing business, for repeated violations indicate a corporate culture that regards profit ahead of instituting banking best practices. This is a national disgrace, and it needs to stop.

Second, we are home to the largest healthcare fraud operation in the United States, where unneeded and bogus health care, medicines and medical appliances are fraudulently prescribed, and sold, costing the American taxpayer billions of dollars in bogus billings. The healthcare scam even has a special Miami twist to it, where Cuban nationals are actually imported, as front men, then returned to Cuba, outside the reach of US law enforcement. Often, criminal proceeds is also wired to Cuba, and placed in Cuban state-owned banks.

Third, Miami's vacation mecca culture conspicuous consumption, often excessive and even garish, has spawned a high-end real estate market that attracts dirty money, and inasmuch as money laundering laws do not yet apply to realtors or brokers, the city has become a magnet for "flight capital," with little push back from a business community, eager to take obscene profits from anyone.

While the "Miami Vice" era of the 1980s, where carloads of dodgy cash were deposited in Brickell Avenue banks, is gone forever, more subtle methods of placing dirty money still are in widespread use in Miami-Dade County. The malevolent Cocaine Cowboys no long assassinate their competition in the city's streets, but they do find ways to move consistently drugs and money through Miami. County Commissioners, we are still a problem for US law enforcement. If you really want to no longer be the subject of unwanted attention, get the business community to actively assist in money laundering suppression, by refusing to accept money, where the Source of Funds cannot be established. Miami businessmen, leave the attractive dirty money alone.

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