Homeland Security Investigations Trade Transparency Unit Trade-Based Money Laundering

1. Forging a New Legacy Homeland Security Investigations Trade Transparency Unit Trade-Based Money Laundering

2. Homeland Security Investigations (HSI) • ICE and HSI • In 2003, U.S. Immigration and Customs Enforcement was established as • the primary investigative arm of DHS. By 2010, ICE had further organized into • three integrated law enforcement components: • HOMELAND SECURITY INVESTIGATIONS (HSI) • Office of Domestic Operations • Office of International Affairs • Office of Intelligence • ENFORCEMENT AND REMOVAL OPERATIONS (ERO) • OFFICE OF PROFESSIONAL RESPONSIBILITY

3. 207 domestic ICE offices including 26 SAC Offices

4. 71 International ICE offices in 49 Countries

5. U.S. Immigration and Customs Enforcement (ICE) Homeland Security Investigations (HSI) Trade-Based Money Laundering and the Trade Transparency Unit • Trade-based money laundering is a form of money laundering that utilizes international trade and financial systems to move value with the intent to disguise the true origin of the proceeds. • Globalization is an impetus for the rapid increase in TBML • With the international community enacting stricter financial regulations and new cash control systems, TBML schemes are becoming increasingly more popular with Transnational Criminal Organizations (TCOs). • Most criminal investigators/analysts do not fully understand the complexities of international trade systems, financial analysis, and industry nuances, leading to difficulty in putting the pieces together.

6. U.S. Immigration and Customs Enforcement (ICE) Homeland Security Investigations (HSI) Trade-Based Money Laundering Methods • Methodsinclude traditional customs fraud violations such as: • Over & under-valuation • Over & under-shipment • False invoicing • Double invoicing • Black Market Peso Exchange (BMPE) • “If an item can be priced it can be mispriced”

7. U.S. Immigration and Customs Enforcement (ICE) Homeland Security Investigations (HSI) TBML – Why It Works • Increased global trade brings increased opportunities for criminal organizations to move value disguised as trade to more regions. • Many countries’ Financial Intelligence Units lack access to trade data or the expertise in identifying anomalies in trade transactions. • Most countries do not have any access to foreign trade data to compare imports and exports. • The unknown true value of commodities and inherent complexities in international trade transactions can make it difficult for financial institutions to become suspicious and file a SAR/STR. • Missed the red flags

8. U.S. Immigration and Customs Enforcement (ICE) Homeland Security Investigations (HSI) Foreign Trade Zones

9. U.S. Immigration and Customs Enforcement (ICE) Homeland Security Investigations (HSI)

10. U.S. Immigration and Customs Enforcement (ICE) Homeland Security Investigations (HSI)

11. U.S. Immigration and Customs Enforcement (ICE) Homeland Security Investigations (HSI) Strategic, Operational, & Tactical Intelligence

12. U.S. Immigration and Customs Enforcement (ICE) Homeland Security Investigations (HSI) TBML – Trends and Moving Forward • Cash control regulations make certain countries susceptible to TBML • Gold, diamonds, and gemstones • TTU Expansion • Education and awareness

13. U.S. Immigration and Customs Enforcement (ICE) Homeland Security Investigations (HSI) TTU Brazil - Operation Black Ops

14. Protecting the Borders Against Illicit Trade, Travel, and Finance