GLOBAL FINANCIAL CRIME REVIEW
The financial and money laundering aspects of fentanyl
Drug trafficking is a crime motivated by profit . Nevertheless , OCGs need resources to finance their activities . The main expenses for OCGs include the acquisition of precursor chemicals and manufacturing equipment , the processing of precursor chemicals into final drug products and the need for specialized human resources such as bioengineers capable of carrying out the synthesis of these precursor chemicals or to pay bribes for the cartels to carry out their trafficking operations . Regarding money laundering , OCGs use a combination of both traditional money laundering methods which are well-tested and more modern methods . The former category includes the use of cash-intensive businesses ( e . g ., casinos ) and businesses trading high-value commodities ( e . g ., real estate , vehicles and jewelry ), and the use of shell and front companies . The latter category includes the use of third-party money brokers , trade-based money laundering , professional money laundering networks , especially from Asia , and the use of cryptoassets , especially via cryptocurrency ATMs . 23 The “ follow the money ” approach is particularly important in order to fight OCGs involved in the trafficking of opioids , because money flows may provide evidence of criminal activity and the connections between members of OCGs . In this regard , FATF released a report raising awareness about the trade of opioids , including fentanyl and precursor chemicals , as well as the related global financial flows and how the proceeds are laundered from the trafficking of synthetic opioids . FATF ’ s report also provides a list of risk indicators and a series of recommendations . 24
The “ follow the money ” approach is particularly important in order to fight OCGs involved in the trafficking of opioids , because money flows may provide evidence of criminal activity and the connections between members of OCGs
FATF ’ s Recommendations
To conclude , FATF recommends improving risk understanding which can be achieved by establishing robust legal and regulatory frameworks to disrupt the trafficking of opioids . In addition , countries must stay alert to existing and new developing trends and identify cases for risk-based review , which can help develop risk indicators . In this regard , countries should ensure they have coordination procedures with respect to information and intelligence sharing . The second recommendation consists of driving financial investigations . This requires properly training law enforcement ( LE ) investigators on financial investigations related to opioid trafficking , including the trade of precursor chemicals . Countries should also identify obstacles related to the identification , freeze , seizure and confiscation of assets , as well as ensure strong compliance policies and procedures . The third consists of improving international cooperation by leveraging existing mechanisms to effectively combat opioids trafficking . Lastly , FATF recommends promoting private sector engagement and public-private partnerships . In this regard , countries should raise awareness about existing and new emerging risks pertaining to the trafficking of opioids within the private sector and share risk indicators and sensitive information by leveraging existing mechanisms and identifying information-sharing mechanisms to help the private sector to better identify and report actors involved in the trafficking of opioids and precursor chemicals . Based on these recommendations , this article is supplemented by a comprehensive list of reference material , resources and tools that government and LE , as well as professionals from the private sector , can use to better combat the opioid epidemic related to fentanyl .
Jonathan Dupont , FIU Investigator and subject-matter expert on cryptocurrency , human trafficking and crimes against children , Lithuania , jonathandupont @ protonmail . com
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