2. $ LAUNDERING – HOW ITS DONE WHY WE CANT FIND THE $ www.The-Infiltrator.com

3. MONEY LAUNDERING Participate in a financial transaction for the purpose of: –furthering a Specified Unlawful Act (SUA) or –conceal / disguise the SUA origin of the funds

4. THE MONEY LAUNDERING PROCESS Placement Layering Integration

5. TYPICAL $ LAUNDERING FRONTS Cash generating businesses (domestic & multi- national) -Casa de Cambio (Money Transmitters) - Precious metals business - Precious stones & jewelry businesses - Check cashing businesses - Casinos Other techniques - Smurfing

6. TYPICAL $ LAUNDERING FRONTS (cont.) - Illegal transport out of U.S. Private plane Commercial carrier Containers Within shipped goods –Off-shore lending sources –Import / Export businesses –Global distributors of durable and bulk goods –BLACK MARKET PESO EXCHANGE (BMPE)

7. BLACK MARKET MONEY EXCHANGES (INFORMAL VALUE TRANSFER SYSTEMS) Exist in most currencies and regions – (global) Many use due to cultural traditions or because these services are faster, cheaper, less bureaucratic and more convenient Facilitate an underground banking system producing an unconventional paper trail Colombian based traffickers use the BLACK MARKET PESO EXCHANGE (BMPE)

8. BMPE CLIENTS Drug Traffickers Terrorists Illegal Arms Dealers Corrupt Political Figures Customs Duty Evaders Tax Evaders Embargoed Goods Dealers Inflationary Concerns Targets of Terrorism Family Transfers

9. BMPE ECONOMICS 101 + SUPPLY OF DOLLARS Conduct illegal acts in the U.S. & live abroad - DEMAND FOR DOLLARS Foreign based tax/duty evaders buying legal goods with U.S. dollars

10. Narcotics Traffickers Colombian Businesses Pesos are given to Peso Broker Peso Broker Pesos are paid to trafficker Drugs are smuggled into the U.S. and sold for U.S. dollars Trade goods are shipped to Colombia and sold U.S. dollars are used to purchase goods or pay debts with wires and checks Vendors U.S. dollars are used to purchase goods through cash purchases Colombia's representative (Undercover Agent) Narco dollars are sold through Peso Brokers to Colombian businesses U.S. dollars are deposited into domestic bank accounts

11. RED FLAGS RE BMPE CHECKS Checks contain: –Multiple style of entries Handwritings vary Inks vary Contain type & writing –Contain odd symbols Rabbit/Smurf/Turtle –Tape over amount Customer payments: –From multiple third party accounts –From multiple sources: Money Orders/Travelers Checks/Cashiers Checks –From unrelated jurisdictions –From haven countries

12. ACQUIRING PESOS WITHOUT THE BMPE REINTEGROS Government export incentive –Immediate exchange –Favorable rate –Value added reward Key elements –Export front –Finance company –Document of Exportation –Local banker (corrupted)

13. THE CORPORATIONS VICARIOUS LIABILITY CORPORATION ACTS THROUGH ITS EMPLOYEES ACTS AND OMISSIONS ARE IMPUTED WHEN - Made within the scope of employment - Made, at least in part, with purpose to benefit the corporation - Whether the corporation actually benefited is unimportant - Corporation is responsible for collective knowledge of employees

14. WRITTEN POLICIES & PROCEDURES STATEMENT Define Problem Identifies Applicable Law Affirms Sr. Management Commitment Outlines Compliance Program –Due Diligence & recordkeeping (enhanced 2002) –Training : Track & Record Designates Compliance Officer/Committee Outlines A Disciplinary Policy

15. INSTITUTIONAL MONEY LAUNDERING PLANS Private Client Divisions: –Gold for Dollars –Locally booking off-shore $ in bulk –Rep. Offices & private houses as courier receiving sites –Rep. Offices & private houses as account review sites Institutional Plans: –Sinister Window –Sale of dollar bonds to foreign institutions –Use of buffer professionals (Attorneys or CPAs)

16. www.ChaseAndAssociates.com (727) 785-1273