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
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