Homeland Security InvestigationsTrade Transparency Unit

Trade-Based Money Laundering

Forging a New Legacy

Law Enforcement Sensitive 2

Homeland Security Investigations (HSI)

ICE and HSIIn 2003, U.S. Immigration and Customs Enforcement was established asthe primary investigative arm of DHS. By 2010, ICE had further organized into three integrated law enforcement components:

• HOMELAND SECURITY INVESTIGATIONS (HSI)• Office of Domestic Operations• Office of International Affairs• Office of Intelligence

• ENFORCEMENT AND REMOVAL OPERATIONS (ERO)

• OFFICE OF PROFESSIONAL RESPONSIBILITY

Law Enforcement Sensitive207 domestic ICE offices including 26 SAC Offices

Law Enforcement Sensitive71 International ICE offices in 49 Countries

Law Enforcement Sensitive 5

U.S. Immigration and Customs Enforcement (ICE)

• Trade-based money laundering is a form of money laundering that utilizes international trade and financial systems to move value with the intent to disguise the true origin of the proceeds.

• Globalization is an impetus for the rapid increase in TBML

• With the international community enacting stricter financial regulations and new cash control systems, TBML schemes are becoming increasingly more popular with Transnational Criminal Organizations (TCOs).

• Most criminal investigators/analysts do not fully understand the complexities of international trade systems, financial analysis, and industry nuances, leading to difficulty in putting the pieces together.

Trade-Based Money Laundering and the Trade Transparency Unit

Homeland Security Investigations (HSI)

Law Enforcement Sensitive 6

U.S. Immigration and Customs Enforcement (ICE)

Methods include traditional customs fraud violations such as:

Over & under-valuation

Over & under-shipment

False invoicing

Double invoicing

Black Market Peso Exchange (BMPE)

“If an item can be priced it can be mispriced”

Trade-Based Money Laundering Methods

Homeland Security Investigations (HSI)

Law Enforcement Sensitive 7

U.S. Immigration and Customs Enforcement (ICE)

• Increased global trade brings increased opportunities for criminal organizations to move value disguised as trade to more regions.

• Many countries’ Financial Intelligence Units lack access to trade data or the expertise in identifying anomalies in trade transactions.

• Most countries do not have any access to foreign trade data to compare imports and exports.

• The unknown true value of commodities and inherent complexities in international trade transactions can make it difficult for financial institutions to become suspicious and file a SAR/STR.

• Missed the red flags

TBML – Why It Works

Homeland Security Investigations (HSI)

Law Enforcement Sensitive 8

U.S. Immigration and Customs Enforcement (ICE)

Foreign Trade Zones

Homeland Security Investigations (HSI)

Law Enforcement Sensitive 9

U.S. Immigration and Customs Enforcement (ICE)Homeland Security Investigations (HSI)

Law Enforcement Sensitive 10

U.S. Immigration and Customs Enforcement (ICE)Homeland Security Investigations (HSI)

Law Enforcement Sensitive 11

U.S. Immigration and Customs Enforcement (ICE)

Strategic, Operational, & Tactical Intelligence

Homeland Security Investigations (HSI)

Law Enforcement Sensitive 12

U.S. Immigration and Customs Enforcement (ICE)

• Cash control regulations make certain countries susceptible to TBML

• Gold, diamonds, and gemstones

• TTU Expansion

• Education and awareness

TBML – Trends and Moving Forward

Homeland Security Investigations (HSI)

Law Enforcement Sensitive 13

U.S. Immigration and Customs Enforcement (ICE)

TTU Brazil - Operation Black Ops

Homeland Security Investigations (HSI)

Protecting the Borders Against Illicit Trade, Travel, and Finance