REGULATORY INITIATIVES
combat transnational crime. Over the past
several years, these joint efforts have identified and disrupted the activities of criminal
organizations engaged in fraudulent trade
schemes, BMPE, money laundering, and
illegal exportation of goods, resulting in
multiple arrests and seizures of millions of
dollars of proceeds and merchandise.
Red flag indicators of trade-based money laundering
Payments to a vendor made by unrelated third parties
Payments to a vendor made via wire transfers from unrelated third parties
Payments to a vendor made via checks, bank drafts, postal money orders
or travelers checks from unrelated third parties
Recent investigative successes
Suspected or known use of shell companies and related accounts
HSI, as part of the Joint Terrorism Task
Force, initiated a case to investigate the
suspicious exportation of electronic goods
from Miami, Florida, to Ciudad del Este in
Paraguay. Cuidad del Este borders Argentina and Brazil, and is part of a region often
referred to as the Tri-Border Area. One of
the largest duty-free zones in the world,
Ciudad del Este is also a South American
smuggling hotspot for counterfeit goods,
illegal weapons and other illicit activities.
In December 2006, Galeria Page, one of the
large shopping centers within Ciudad del
Este, was designated as a Specially Designated Global Terrorist (SDGT) entity by the
Office of Foreign Assets Control, due to its
ties to the terrorist group Hezbollah. Once
an individual