by Dayne Bloxham
When it comes to identifying suspicious transactional activity, knowing what to look for is half the battle.
FinCEN recently highlighted an example of trade-based money laundering that can help front-line and BSA personnel understand this emerging threat.
In this case, large sums of money originating from Mexico were transferred through bank accounts of shell companies in the U.S. The wire transfers resembled pass-through activity because the funds moved through the accounts with only a small percentage taken out for business expenses.
One of the main conspirators was a former shareholder of several banks in Mexico and used those financial institutions to make the illegal activity look like legitimate international trade in cell phones.
Shell companies in Mexico would acquire counterfeit and obsolete cell phones…