The financial investigation revealed that various family members had bank accounts fed by a stream of wire transfers, but no apparent source of the income. They had purchased four single-family homes in the United States, as well as an avocado farm and a strip mall, laundering their illegal income. To obtain mortgages on these properties, they had written notarized letters stating that they had gifted each other the amounts of the down payments. All of their utility bills were paid by wire transfer or cashier’s checks. They had also laundered smuggling money by purchasing 141 motor vehicles.
In another San Diego case, local branches of the Crips and Bloods gangs formed an alliance to traffic prostitutes. Financial records revealed more red flags of trafficking: account deposits had been structured to avoid Bank Secrecy Act-mandated currency transaction reports and deposits were almost entirely even numbered. Proving themselves perhaps not the smartest of crooks, some of the checks deposited into the accounts “had ‘For a good time’ written in the note field,” Salazar said. Additionally, credit cards that were tied to false business fronts were used to lease luxury cars and pay for extravagant vacations. There were also credit card payments for advertising on online escort service Web sites.
Seeing the signs. Last year, DHS initiated the Blue Campaign—an agency-wide effort to combat human trafficking through enhanced public awareness, victim assistance programs, and law enforcement training and initiatives. Part of this campaign involves outreach not only to the banking and financial services sector but also to the travel, agricultural, construction, entertainment, manufacturing, and hospitality industries that are used by traffickers to transport, market, and exploit victims.
Another recently launched initiative is Project Stamp (Smugglers and Traffickers Assets, Monies, and Proceeds). Under the program, DHS seeks to educate the banking and financial sector about the red flags that indicate possible money laundering by human trafficking and smuggling organizations. DHS has identified the following among the examples of suspicious financial transactions to watch for:
- Large cash deposits going into one account from multiple locations across state lines.
- Cash deposits totaling just under $10,000 (the amount that triggers a Bank Secrecy Act currency transaction report) made at several bank branches.
- No deposits originating from customers for services the business purports to conduct.
- The purchase of money orders to pay bills instead of writing personal checks.
Ann Longmore-Etheridge is an associate editor of Security Management and editor of ASIS Dynamics.