Table 1 : Common money laundering techniques used by Mexican transnational criminal organizations
Bulk cash smuggling Trade-based money laundering Structured money services business money transfers Funnel account activity
Source : Financial Crimes Enforcement Network 17 Visualization by Sam Cousins and Luciano Pollichieni
The Captagon trade is playing a critical role in the geopolitics of the Middle East
Table 2 : Red flag indicators in fentanyl trafficking which may be applicable to Captagon
The beneficiary lists a phone number that is the same as a pharmaceutical or chemical company .
The depository institute smells drugs or detergent on the banknote .
The depositor has received funds from popular dark web marketplaces ( i . e ., Rapture ).
The transaction note field includes the weight of the drugs or the chemical name .
The use of a virtual private network or a Tor network to access a convertible virtual currency exchange .
The customer has a previous history of drug offenses .
The company has a name , address or location discrepancy .
Source : Financial Crimes Enforcement Network 18 Visualization by Sam Cousins and Luciano Pollichieni
What is next ? Assad ’ s Captagon balancing act
The Captagon trade is playing a critical role in the geopolitics of the Middle East . In 2023 , Assad attended his first Arab League summit since the outbreak of the civil war in 2011 , a détente which is in large part influenced by the desire for the Arab States to find ways to curtail Syria ’ s trade in Captagon . Within the summit , Captagon took a high position among the topics , with many Gulf states seemingly believing that Syria could be incentivized to clamp down on the trade beyond the token actions already taken . This has included an offer by Saudi Arabia for $ 4 billion of investment in Syria in exchange for curbing the trade . 19
Despite these developments and statements by the Assad regime , the economic magnitude of the trade means that significant change seems unlikely in the near term , particularly given the dual benefits the trade provides the Syrian regime by way of both revenue and leverage with its neighbors . Furthermore , while the impact of Western countries have thus far been relatively small compared to those in the Middle East , this may become of greater focus for the West as the drug grows in usage globally , particularly if shifting drug trafficking routes drive new markets for the illicit trade in Europe and North America . Further sanctions and wider legislation should be expected , and FIs should consider the potential prevalence of Captagon among other illicit substances when considering drug trafficking money laundering risks , as the market share of this drug in North America and Europe is set to grow and the enormous profits will need to be laundered . On the other hand , Captagon may also prove a diplomatic challenge if the U . S . views political and economic rapprochement between Syria and its neighbors as being detrimental to the intention of the widespread sanctions in place . Ultimately , the Assad regime continues to tread a balancing act through alleged tacit support of the trade while also using it as a bargaining chip to gain diplomatic and economic concessions from its neighbors . While this may serve the regime at the moment , history tells us that once these forces are unleashed , they are hard to put back in the box .
Sam Cousins , senior associate , Sanctions , Ransomware and Risk , ACAMS , SCousins @ acams . org
Luciano Pollichieni , Ph . D ., research fellow , Critica Research and Analysis , pollichieni @ criticaresearch . com
ACAMS Today September – November 2023 105