DIFFERENT ANGLE by Kenneth Rijock
Publicity surrounding a low-level organisation of blue-collar workers who "micro-laundered" cash for a Colombian narcotics group, showed that micro-structuring is alive and well in the United States. This is the common practice of "smurfing" (depositing) small amounts of criminal proceeds in multiple accounts. The recipient withdraws the funds via an automatic teller machine (ATM) in another country. The case that was in the news had a small two-person operation placing funds into over 100 accounts, and Colombian drug traffickers withdrew it from a cash machine at a bank that had no limit on withdrawals. One wonders what bright banker would associate his institution with a correspondent bank overseas that allows this practice.
Micro-structuring is extremely time-consuming, is inefficient, and crude, but when you have a number of "employees" with plenty of time on their hands , you can make it work. The weak point is where & when the funds are taken out of the ATMs.
As compliance officers, we cannot defend against a customer who makes hundreds, or even thousands, of deposits, to smurf criminal proceeds into the bank, but we can certainly recommend to senior management that they maintain some measure of control over methods of withdrawal.
The facts and opinions stated in this article are those of the author and not those of World-Check. World-Check does not warrant the accuracy of any facts and opinions stated in this article, does not endorse them, and accepts no responsibility for them.
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