ACAMS Today Magazine (March-May 2011) Vol. 10 No. 2 | Page 13

EXPERT SPOTLIGHT on how businesses tend to structure these proceeds, what type of businesses typically are involved, and how to appropriately report suspect customers/businesses and also how to best document these situations in SARS. The better the SAR is written by the compliance officer, the more useful it becomes to the investigator. border, this may be attributable to this change in regulations. AT: Can you disclose general information about the latest cases you are working on? DO: Our group tends to be focused on the Mexican drug cartels and the financial components associated with their drug trafficking. These groups are very savvy, and utilize a wide variety of methods to move their money — from basic bulk cash transportation of cash across the border to utilization of the Black Market Peso Exchange (BMPE). With the change in Mexican banking regulations I mentioned above, our group is trying to identify what alternatives these cartels are now using based upon the fact that it has become more difficult for them to enter into the Mexican Financial System. I think the U.S. compliance officers are going to have their hands full this year. AT: What type of training should law enforcement professionals be receiving to work successfully with FIs or what type of training should FIs be receiving to work effectively with law enforcement? Do not be afraid to ask questions and interact with the agents and officers AT: In your 10 years in the law enforcement field what are some of the most important lessons you have learned? DO: I mentioned previously the Black Market Peso Exchange. I think it would be wise for businesses to get an understanding of what it is and how it gets implemented. Whether you are in the business of selling computers, shoes, clothing, or widgets, any business could be subject to a Black Market Peso type scheme. I think it would be beneficial for compliance officers to receive training DO: One of the most important things I have learned is “trusting your instincts.” If something does not look right and your gut is telling you that something just does not fit, most likely it deserves to be given a second look. Trust those initial assessments, if you have been in the business long enough, whether for me in the drug trafficking arena or working within the financial system, trust your instincts and those of your people who are on the front lines for your business. Interviewed by Karla Monterrosa-Yancey, CAMS, editor, ACAMS, [email protected] ACAMS.ORG | MARCH–MAY 2011 | ACAMS TODAY 13