TRADECRAFT 101 PART SEVENTEEN: WHAT GOES UP DOESN'T NECESSARILY COME DOWN IN MONEY LAUNDERING TRAVEL OPERATIONS

 

We note that a number of British Virgin Islanders have been denied entry into the United States of late; their ESTA applications are being turned down, because, according to American records, they were still present there, from their previous visits. Apparently, their departure home, by ferry, from nearby USVI was never placed of record, using the UK passports they employed to enter the US. They must have used BVI identity cards to come home. This reminds us of one of the laundryman's bag of tricks you need to be aware of: switching identity documents in midstream.

Many money launderers work tirelessly to confuse any potential law enforcement investigation of their travels, for obvious reasons. They actively create broken travel trails, so that investigators later attempting to put the puzzle pieces together hit a dead end, time after time. One of the the tricks is to leave on a laundering trip, using one form of national identity, and return on one from another jurisdiction, which may have a slightly different spelling of one's name, date of birth or other varying information. The economic passport (Citizenship by Investment or CBI passport) is often employed by financial criminals who cannot present the passport from their native country, which is high-risk, sanctioned, or otherwise not a good idea to have on record when engaged in criminal activity.

Even if you hail from a low-risk country, to reduce the risk of eventual arrest and incarceration for what you are engaged in on that trip, it is prudent for laundrymen to find ways to present different proof of identity when arriving at customs and immigration, or even when departing, to make travel tracing extremely difficult, or even impossible. Thuis of course means planning ahead, and perhaps breaking a few laws in the process, but laundrymen weigh this against the potential 20-year penalty in the US for money laundering, and acquire multiple identities, often under aliases, complete with bogus  local drivers' licenses, and yes even utility bills, to fool compliance officers opening accounts abroad for new clients.

Back when Americans could transit the Caribbean with a birth certificate, yours truly used a US passport to leave the Continental US, and my birth certificate to return. That way, my passport did not have dozens of arrival stamps from Customs at MIA, and US birth certificate holders were waved through, without being entered on any computer. That has now changed, but when moving around abroad, I still employed different forms of identity. when I was eventually indicted, there was a paragraph alleging that I once spent several weeks living in Anguilla, BWI, while in truth and in fact, I had exited the island the same day I entered it, without leaving any paper trail whatsoever. No wonder most laundrymen evade arrest for years.

BTW present day; if you are an American compliance officer handling CIP duties for foreign bank clients at account opening, know this. If the client comes from a country where he can use ESTA to enter the US, and you have an opportunity to look at his passport, presented to you so you can photocopy the primary pages, make sure he does NOT have a new US visa, because that means he was not qualified under ESTA, and had to gain entry the old fashioned way. He may have a criminal record somewhere, as criminal history is disqualifying for ESTA approval. Check him out.