TBML SPECIALISTS: WATCH FOR TRAFFIC IN INDUSTRIES WHICH BEST LEND THEMSELVES TO TRADE-BASED MONEY LAUNDERING

Having worked here for fifty years, much of it in compliance, I know from personal experience that Miami is the epicenter of America's import-export activity to Latin America, and more importantly that it has been a focus of trade-based money launderers for decades, as they labor to repatriate the proceeds of North American narcotics sales to the kingpins who dominate the illicit traffic. TBML and bulk cash smuggling are most likely the principal methods of moving all those profits south.

Compliance officers at banks with a significant amount of international trade clients often employ Country Risk when deciding which accounts should be subject to intense Transaction Monitoring for indicia of TBML. I suggest you supplement that focus by paying specific attention to those industries whose products whose values cannot be easily ascertained from afar, ether because their prices fluctuate due to supply and demand, or are of such a nature that covert substitutions, not disclosed in the shipping documents could result in extremely large value shipments, marked as those of lesser value, for foreign sale, getting through undiscovered by compliance.

Hi-tech products come to mind, because such items as computer chips or other small electronic components are rarely, if ever, inspected by any customs agents, allowing many millions of dollars of value to slip overseas, where they can be sold on black or alternative markets. Thus, rate your exporters by type of products they ship, as well as which country they are destined for, if you want to maximize the chances that you will tumble into a TBML operation. When it comes to trade-based money laundering, work smarter, not harder, to uncover those pipelines.