Dead fish across the trail: illustrations of money laundering methods

Date01 October 2005
Published date01 October 2005
AuthorAnthony Kennedy
Subject MatterAccounting & finance
Dead Fish across the Trail:
Illustrations of Money Laundering Methods
Anthony Kennedy
`What did he do with the money?' is the fundamental
question which needs to be asked by ®nancial investi-
gators in respect of acquisitive crime. This is because,
®rst, the evidence may be necessary to ground
money laundering charges against the defendant;
and, secondly, the evidence may also be necessary
either to obtain a con®scation order against him or a
civil recovery order against his property.
In United States v Kramer and Others
the trial judge
stated that an essence of money laundering was deceit
and cover-up. He observed that the facts of the case
before him abounded with examples of `dragging
dead ®sh across the trail' to throw bloodhounds o
the scent or `dragging branches behind a horse to
destroy the tracks on the trail'. Financial investigators
must get used to penetrating such deceit and uncover-
ing the reality beneath it. Since previous behaviour is
often the best predictor of future behaviour, this paper
surveys how oenders have attempted to launder their
criminal proceeds. As it is understood how they have
done it in the past, it will be become clearer how they
may attempt to do it in the future.
Rather than communicating the information in this
paper by means of a list of principles, the author has
adopted a story-telling method. Stories are how
people remember; they tend to forget lists of bullet
Knowledge management literature empha-
sises that one of the critical ways knowledge is com-
municated by practitioners in any community of
practice is by `war stories' which act as repositories
for accumulated experience. In the process of telling
and discussing stories the collective memory of the
group is communicated and developed.
Thus if a
®nancial investigator recounts to his colleagues that
he recently had a case where the proceeds of crime
were laundered in a novel way, he is ful®lling an
important function by furthering the learning process
in the community of practice.
This paper groups
together features of alleged money laundering
attempts from US prosecutions and from civil forfei-
ture proceedings in a thematic way. Having access to a
group of collected stories may be particularly useful
for new ®nancial investigators who do not yet have
a group of collected experiences of their own and it
is therefore for that audience that this paper is written.
Criminal proceeds often, but by no means always,
begin in the form of cash. One of the important
elements in any laundering cycle is therefore the
movement of cash to a layering point. This physical
transportation of cash, however, is a moment of vul-
nerability. Cash has been discovered in cars,
gift-wrapped packages,
jewellery shipments,
on private charter ¯ights,
Federal Express packages,
cylindrical canisters of
cable wire,
plastic toys,
house walls and hidden basement safes.
Two illustrations of cash discoveries will be su-
cient. In United States v Mondragon
a car was stopped
for a trac violation. The driver consented to police
searching the car. In the course of the search police dis-
covered a hidden compartment with electronic spring
locks behind the back seat. According to the police
ocer, the installation was of professional quality.
He had seen many such secret compartments and
knew they were routinely used by drug trackers to
transport large quantities of drugs as well as the cash
proceeds from drug transactions. Inside this compart-
ment the ocer found nearly $500,000 in cash, sealed
in ®fteen plastic bags. A drug detection dog gave a
positive alert to the back seat area of the car. When
Mondragon's handbag was searched, an additional
$5,900 in cash was found.
In United States $129,727.00 US Currency
was stopped at Los Angeles International Airport by a
DEA agent. Trujillo told the agent he was a shoe sales-
man and had $40,000 in his suitcase from the sale of
two cars. The agent received permission to open the
suitcase. Inside were bundles of currency, wrapped
®rst in fabric softener sheets and then tightly in plastic
wrap. A number of features created suspicion. These
included Trujillo's late-night cash purchase of a one-
way ticket; travel between New York and Los
Angeles, a drug source city; use of a relatively new
suitcase; dissociation from a travelling companion;
Page 305
Journal of Money Laundering Control Ð Vol. 8 No. 4
Journalof Money Laundering Control
Vol.8, No. 4, 2005, pp. 305± 319
HenryStewart Publications

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