NEW NONSTOP FLIGHTS FROM TAX HAVENS INTO MIAMI MAY FACILITATE LAUNDERING FROM IRAN AND VENEZUELA

                                                           Maiden flight DXB-MIA
 

If you are an avid reader of aviation news, you know that last Thursday the first scheduled nonstop Emirates flight from Dubai UAE landed at Miami International Airport. Flights will be arriving and departing four times each week. While the 15-16 hours flying time is a bit long for many tourists, the new service will directly connect Miami and Dubai.

 Additionally, American Airlines has announced that, beginning in December, it will be offering twice-weekly flights to Miami from the Commonwealth of Dominica. Previously, travelers to or from Dominica were required to access the United States from airports elsewhere in the East Caribbean.

While as a longtime resident of Miami (50+ years)*, I have seen MIA go from an airport with few international nonstop destinations outside the Caribbean and Latin America, to becoming a centre of global aviation, two of the new connections pose a problem for American law enforcement and regulatory agencies that are trying to stem the tide of criminal proceeds from abroad entering the American financial structure to be laundered, and thereafter invested here.

Dubai is a well-known destination for Iranian capital, particularly in US Dollars, seeking to enter the US banking system for a wide variety of reasons, all of which are strictly prohibited by American sanctions imposed by OFAC, and the President of the United States, in his executive capacity. This covert activity is facilitated by the large number of Iranian expats residing in the UAE, as well as other nationals with no fear of breaking US regulations and laws.

The Commonwealth of Dominica, one of the five East Caribbean States that offers Citizenship by Investment (CBI) passport sales programmes, and which accepts US Dollars in payment, has a dysfinctional and ineffective CBI programme, rampant corruption at the highest level, and is a clear and present danger to US financial institutions, due to their exposure to American Anti-money Laundering laws.

While cash and cashier's cheques payable to the bearer are prohibited from entering America without being disclosed in writing upon arrival, financial instruments payable to third parties or entities can be easily, and legally, carried on the person of individuals entering American Ports of Entry, such as MIA, and subsequently quietly and effectively placed in cooperating US bank accounts. Giving money launderers, as well as corrupt PEPs ,a nonstop means of entering the USA, from known tax havens, makes the job of American law enforcement harder. 

We understand that, in a global economy, facilitating international travel is a must, but we hope and trust that US Customs and Border Enforcement ramps up their on-arrival investigation techniques, so as to insure that those who would place dirty money into America are identified and interdicted, and that US bank compliance officers, particularly in Florida, be alert for any new deposit patterns that may indicate a possible money laundering pipeline operating through these new aviation routes. 

Compliance officers must at all times remember that money launderers are constantly on alert for new techniques and travel routes, and they quickly adjust and modify their methods to take advantage of what they regard as new opportunities to successfully  place and integrate their clients' criminal profits. Their success is at your expense, ladies and gentlemen of compliance.

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*In the old days, if you wanted to fly nonstop to Paris, your only choice was an Aeromexico flight Mexico City to Paris' Orly (ORY), which made a stop at Miami; Times have certainly changed.