AML CHALLENGES INTERVIEW
Ryan Hill, HSI supervisory special agent
ACAMS Today: Could you tell me about your role and what you do on a daily basis?
Ryan Hill: My group is tasked with looking at non-traditional money laundering investigations— so everything outside of narcotics money laundering. Currently, some of the investigations we are working on are Ponzi schemes, securities fraud, manipulations of securities and commodities. We have also targeted the proceeds of contraband, for example, cigarette contraband trafficking. This is an offense that is not typically prosecuted because it is difficult to get the requirements for it, but we have found that we can do undercover operations where we can get information from the organized network that is operating these rings of contraband cigarettes. For example, these organizations go to low-tax jurisdictions, like Virginia, to buy as many cigarettes as they can at a low cost. They then sell the cigarettes at a higher price in the Black Market, which allows for huge profits even though they employ couriers and runners to travel on the interstate. We have discovered that this type of contraband trafficking has been tied to Hawalas because criminals prefer to use illicit money laundering networks because they operate without any oversight. However, not all Hawalas are used for illicit money. Since illicit money investigations falls under our purview, a lot of our investigations have begun with illicit money movement. This is why many of our investigations have begun with a contraband cigarette trafficking investigation. For example, imagine that a state trooper in West Virginia has pulled over a courier, which then leads to a larger network dealing in K2 synthetic cannabinoid distribution. The K2 is so prolific it has melded into the contraband cigarette trafficking. We have noticed in our undercover investigations that the criminals do not want us to purchase K2 synthetic cannabinoid as much as they want us to sell them contraband cigarettes, so they can trade between contraband cigarettes from low-tax juris-
Ryan Hill, HSI EDTF supervisory special agent
dictions for K2. We are seeing an overlap between K2 and the contraband cigarettes and even though contraband cigarettes do not appear as a public safety, K2 is and the melding of the two is affecting the public safety.
AT: Would you say that it is related to synthetic opioids? RH: It has been related to fentanyl and synthetic opioids.
AT: Could you expand on your work with commodities?
RH: We work closely with the Securities Exchange Commission( SEC) and we have recently started working closely with the U. S. Commodity Futures Trading Commission( CFTC). We worked on a case involving a woman that was a Harvard graduate and she played up her Harvard degree as a selling point to come across as a prolific trader. She even tried to say that she had an evolved trading rationale that would guarantee double-digit returns. She would take victims’ money and prepare false investor statements and this was to the tune of $ 23 million. The SEC was the original provider, but the CFTC was the organization that we worked with to identify her and gather the evidence to obtain her conviction and we were successful.
AT: What has been your favorite case?
RH: There was a Bangladesh organization made up of 15 to 20 individuals that had a very sophisticated way of conducting check fraud. They would create these high quality counterfeit checks and had access to great false IDs. They would then open bank accounts with banks and let them remain dormant for a six-month period. Because of the dormancy, the banks would relax their controls on these accounts. Then on a Friday, they would deposit a $ 15,000 check and would withdraw money from ATMs up to the ATM limits. They realized
42 ACAMS TODAY | SEPTEMBER – NOVEMBER 2017 | ACAMS. ORG | ACAMSTODAY. ORG