Those who wrestle with addiction are rarely open about their disease and therefore spend immense effort and energy hiding their drug use
AFC CHALLENGES
Hand-to-hand deals, like those old folding maps, are quicky fading into the past. P2P has put a digital footprint on them now and the evidence has gone from impeachable memories to virtual corroboration. LE use and recognition of this digital change is falling behind with the upgrades and updates required. From drug dealing to the explosion of fraud into the AML / BSA arena, the private AML community seems to recognize the need for these regular updates to keep pace with technology. This, however, has expanded into LE communities where AML / BSA considerations were normally reserved for“ big dollar” cases. The BSA, through the Financial Crimes Enforcement Network( FinCEN), had even established dollar thresholds for reporting. LE experiences made investigators strangers to the idea of having actionable financial intelligence as far down as street-level drug deals.
The sad reality is that drug trafficking is an addiction-driven industry. It is merciless and it leaves a giant trail of destruction. Addiction does not discriminate and although we may never cure the problem, we can and should make it much more difficult for traffickers to operate with impunity, profiting from the pain of others. Have you ever made furtive efforts to obfuscate your money through a P2P application just to feel“ normal”? Those who wrestle with addiction are rarely open about their disease and therefore spend immense effort and energy hiding their drug use. However, there are some anomalies that banks should look for when dealing with those possibly afflicted with addiction, such as if a customer starts making round-numbered frequent cash deposits or frequent transfers to peer-to-peer applications. Therefore, it may be possible for the AML community to provide“ early detection” and even intervene through client outreach ― before it is too late. AML teams can and should familiarize themselves with typologies related to criminal activity. There are several resources available through ACAMS. 1 In addition, the authors of this article are happy to provide training.
According to FinCEN’ s April 2025 financial trend analysis report titled“ Fentanyl-Related Finance: 2024 Threat Pattern & Trend Information,” 2 FinCEN identified 1,246 BSA reports
“ between January and December 2024” that involved transactions related to fentanyl and the related supply chain. FinCEN identified 80 % of the BSA reports were related to electronic funds transfers, including P2P transfers. In fact, according to FinCEN, of the approximately $ 1.4 billion identified related to fentanyl, 54 % of the money movement identified was cash activity and 52 % of money movement was identified as P2P. That information alone should force both the AML and LE community to reevaluate the approach to identifying, disrupting and dismantling these drug trafficking organizations.
The scheme is simple when one understands how P2Ps operate. In most( certainly not all) cases, the drug customer and drug seller both have P2P platforms. The drug customer is likely depositing funds into their traditional bank account, commonly referred to as a“ demand deposit account”( DDA). Once their funds are in their account, they can use their P2P app to facilitate their drug purchase. There are no efforts to obfuscate the source of their funds. However, the drug supplier will require some explanation for
Those who wrestle with addiction are rarely open about their disease and therefore spend immense effort and energy hiding their drug use
20 acamstoday. org