How to Audit the Unique BSA/AML Risks of the

Border Bank

Melissa Triplett, CAMS-Audit

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Table of Contents

Table of Contents 2

Executive Summary 3

Unique Challenges of Banking Along the U.S./Mexico Border 4

Current Environment: Make Auditing Great Again! (M.A.G.A.) 5

Creating a Thorough Audit Program Unique to the Border Bank 6

Cross-Border Transactions 6

Currency Restrictions: Funnel Account Activity and Bulk Cash Activity 6

Human Trafficking/Smuggling 7

Money Service Businesses/Casa de Cambios 8

Nonresident Alien Accounts 9

Audit Best Practices and Recommendations 9

Conclusion 14

References 15

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Executive Summary

Financial institutions along the U.S./Mexico border face a constantly evolving BSA/AML risk landscape. Due to these distinctive challenges, an auditor needs to understand how to audit and test these unique risks. This white paper will talk about those challenges, risks, and special audit considerations that need to be measured when auditing a border bank.

To better quantify the potential BSA/AML risk exposure for a financial institution located within a border town, it is best to understand the activity taking place each and every day across the many ports of entry into the United States from Mexico. There are numerous points of entry from Mexico into the United States that are located along the borders of California, Arizona, New Mexico, and Texas. The San Ysidro port of entry located south of San Diego, CA, is the largest land border crossing in the world and the biggest border crossing in the western hemisphere. This is important to note, due to the geographical cross-border AML risks, which are the foundation for this white paper.

Sources: Bureau of Transportation Statistics, U.S. Customs and Border Protection, OpenStreetMap, Nextzen 2018

The National Money Laundering Risk Assessment published by the U.S. Treasury in 2018 stated: "Mexico remains the dominant conduit for most illegal drugs entering the U.S. Professional money launderers often take possession of the drug proceeds in the U.S. and facilitate the laundering process. Such laundering can involve a combination of structured bank deposits, funnel accounts, and bulk cash smuggling. A typical scheme exemplifying how these money laundering methods work together involves the pooling of proceeds into a single account as the

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result of small cash deposits at bank branches throughout the country, then either wiring the collected funds to Mexico or withdrawing them in currency near the Southwest border for smuggling into Mexico. Another common method is trade-based money laundering, which involves using a cycle of money brokers and exporters of goods to disguise and move drug money. The sale of the goods effectively launders the money and provides drug suppliers with payment in local currency. Merchants who receive payment by check or wire for their goods may be unaware they are participating in a money laundering scheme, but some willingly accept drug cash and are aware they are complicit."1

Using what we have learned from the National Money Laundering Risk Assessment, an auditor can properly ensure that the scope of the audit is comprehensive enough to include all of the above-mentioned risk factors.

It is imperative to understand the unique economic nature of this region, as well. Families on both sides of the border are economically connected. It is commonplace for residents located in the Baja region to cross the border and do their shopping. It is also commonplace for U.S. citizens to live in Baja and commute to the U.S. for work. Keeping these facts in mind will aid in understanding the nature of transactions within this region. When monitoring activity, it is important for both the auditor and the financial institution to know the economic connections in addition to what may possibly be suspicious and/or illicit activity.

It is extremely apparent that border banks along the U.S./Mexico border are facing heightened BSA/AML risks. Rabobank, NA is a recent example of this. The bank was allowing millions of dollars in untraceable cash, most of it from Mexico, to be deposited into its California branches in El Centro, Calexico, and Tecate, which are all located in Imperial County, CA. Imperial County is in close proximity to the Mexico border, with the Calexico branch located a mere two blocks from the U.S./Mexico border. The funds deposited into Rabobank's Imperial County branches were then transferred back out of the country via wire transfer within 24–48 hours after the initial cash deposit. There was no adequate monitoring or reporting of any of these transactions. As a result of the deficiencies in Rabobank's AML monitoring program, Rabobank was penalized almost $370 million dollars.2

Unique Challenges of Banking Along the U.S./Mexico Border

This white paper will discuss the specific challenges listed below that are unique to financial institutions located along the U.S./Mexico border region. These risks are applicable regardless of the asset size of the institution being audited. BSA/AML regulations apply to financial institutions of all size.

● Cross-border transactions ● Currency restrictions: funnel account activity and bulk cash activity ● Human trafficking/smuggling ● Money service businesses/Casa de Cambios ● Nonresident alien accounts

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Having a firm understanding of these unique risks will assist the auditor in developing a proper audit plan so that the findings and recommendations are relevant to the review.

Current Environment: Make Auditing Great Again! (M.A.G.A.)

It is safe to say that we are currently living in a very volatile political climate. President Trump has threatened to close the U.S./Mexico border on numerous occasions. This is concerning due to the sheer volume of commerce that comes through the border on any given day. On November 25, 2018 the San Ysidro border was shut down for five hours, which lead to a loss of $5.3 million dollars in revenue for U.S. merchants located along the border. Recent headlines are often flooded with concerns over a border wall, immigration issues, and tariffs being imposed on Mexico. The current administration has many strong opinions on activities occurring within the U.S./Mexico border region.

In 2016, at the beginning of the Trump administration era, Sabeen Bazka of AML Right Source posed this question: "Will Trump's plan to construct a barrier between the U.S. and Mexico in an effort to curb immigration engender new money laundering concerns? These are just a few facets you may want to explore in a preemptive effort to mitigate future risk and bolster your AML strategy and program."3

Bazka also mentions that, "money laundering vulnerabilities may increase in the arena of Mexican immigration. Trump has been insistent on constructing a wall on the southern U.S. border to curtail immigration that would be funded by Mexico, intending to prevent illegal Mexican immigrants in the U.S. to remit money via wire transfers to their families in Mexico. These remittances account for approximately $24 billion influx into Mexico's economy, with the funding of the wall serving as a threat to that end."

Bazka concludes, "It is critical for your financial institution to remain apprised of the changing AML landscape in the face of a very different administration, which may consist of both financial deregulation and simultaneously more stringent AML measures than those currently in place. As the most recent AML legislation impacting financial institutions, the United States of America Patriot Act (USAPA), has primarily remained unchanged since 2001, it is highly likely that Trump may introduce numerous changes that will force you to rethink your preexisting AML strategy in order to avert the facilitation of money laundering through your financial institution."

Although published three years ago, this is still a very real concern for financial institutions along the U.S./Mexico border. Immigration continues to be a hot topic within the Trump administration era, and Ms. Bazka's comments are still extremely relevant to this day. Keeping abreast of the dynamic political environment while performing the audit for the financial institution guarantees compliance within this dynamic BSA/AML landscape and will indeed Make Auditing Great Again.

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Creating a Thorough Audit Program Unique to the Border Bank

Cross-Border Transactions

"Money launderers seeking to introduce illegally-generated funds into the United States financial system through bulk cash deposits, couriers, and funnel accounts will not be tolerated by the federal government." –Ryan L. Korner IRS-CI4

In a recent press release from the U.S. Department of Justice, we learned that a money laundering organization operating in both Tijuana, Mexico as well as in San Diego, employed money laundering techniques such as funnel accounts, bulk cash deposits by paid third parties, unlicensed money transmitting businesses, shell companies, and various layers of transactions providing no legitimate business purpose, had all been integrated into the US financial system prior to ultimately being transferred back into Mexican financial institutions.5

Financial institutions should have clearly defined procedures and controls in place for the identification of all cross-border related activities. Further, banks need to ensure the timely monitoring and reporting of such transactions. These should all be clearly identified in the banks' BSA/AML risk assessment and within the banks' BSA policy and/or BSA department desktop procedures.

Currency Restrictions: Funnel Account Activity and Bulk Cash Activity

On June 16, 2010, Mexico enacted new anti-money laundering provisions to attack the flow of illicit cash from the U.S. to Mexico. This new law imposed currency restrictions, which limited the deposit of U.S. currency into Mexican banks. This made it extremely difficult for the cartels to place large amounts of U.S. dollars into Mexican financial institutions. Specifically:

Individuals limited to USD$4,000 per month

Businesses in border or tourist areas limited to USD$14,000 per month

Shortly after Mexico enacted its new anti-money laundering provisions restricting U.S. currency, FinCEN published advisory FIN-2010-A007.6 This advisory was issued to assist financial institutions in understanding how the U.S. financial system could potentially be impacted by the recent changes to the Mexican regulations. As an auditor, it is important to test that the bank is able to properly detect whether any illicit behavior tied to the currency restrictions is occurring within the financial institution. It is necessary to have an understanding of the typologies surrounding this type of activity, so the auditor knows what to look for when conducting the audit.

1) Funnel account activity. A funnel account is defined as: "An individual or business account in one geographic area that receives multiple cash deposits, often in amounts below the cash reporting threshold, and from which the funds are withdrawn in a different geographic area with little time elapsing between the deposits and withdrawals."

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FinCEN released guidance (FIN-2014-A005)7 specific to funnel accounts and trade-based money laundering. FinCEN issued this guidance due to the rise of funnel accounts as part of trade-based money laundering caused by the U.S. currency restrictions in Mexico. When the Mexican regulations limiting U.S. currency deposits first went into effect in 2010, financial institutions needed to implement proper transaction monitoring strategies in order to catch this illicit activity. In 20118 and 2012,9 FinCEN released two additional advisories due to the rise in funnel account activity. Funnel accounts were being used to move illicit proceeds without being traced. In addition to using funnel accounts to move illicit proceeds, criminal organizations were also using funnel accounts to finance goods as part of trade-based money laundering activity. By using funnel accounts that appear to be linked to the sale of goods, the criminal organizations are able to legitimize their source of funds.

2) Bulk cash activity is another type of activity to monitor that has intensified in relation to the currency restrictions imposed by Mexico.

Bulk Cash Activity can be related to illegal narcotics, Black Market Peso Exchange trade-based money laundering, or other illicit activity. In a recent case that took place at a Bank of America branch in San Ysidro, CA, over $89,000 was seized from an account due to bulk cash smuggling. An employee of a Mexico-based business, National Auto Parts Mexico, was crossing the border multiple times a day with cash hidden all over his person. He was not declaring the cash in order to evade filing requirements of a CMIR (Report of International Transportation of Currency or Monetary Instruments), nor was he allowing the financial institution the ability to properly file CTRs due to the structuring of transactions. The tellers at the financial institution noted that Mr. Raul Hernandez (employee of National Auto Parts Mexico) regularly produced bundles of cash from his socks, his waistband, and elsewhere on his person when making cash deposits to the business account. The tellers also stated that Mr. Hernandez made multiple cash deposits into the account over the course of a business day. Mr. Hernandez informed the tellers that he purposely concealed the cash when crossing the border to avoid having to file a CMIR and going to secondary inspection.

Between January 2012 and January 2013, only one CMIR was filed with the U.S. Department of the Treasury. In reality, between January 26, 2012 and January 28, 2013, there were 962 separate cash deposits made into the account, none of which exceeded $10,000.00.10 This case is a perfect example of bulk cash activity occurring in financial institutions located in close proximity to the U.S./Mexico border. Numerous banks are being cited for lack of oversight when it comes to AML compliance. HSBC specifically was cited for deficiencies within its AML compliance program due to no monitoring of bulk cash transactions with Mexico. Between 2006 and 2009, HSBC allowed $15 billion in bulk cash deposits. The bank was ultimately fined $875 million dollars by the U.S. Treasury.11

Human Trafficking/Smuggling

Sadly, the horrific crime of human trafficking and smuggling continues to be on the rise. As referenced earlier, the San Ysidro port of entry (located just south of San Diego) is the busiest

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land border crossing in the world. Human trafficking is the second biggest financial crime, second to drug smuggling in this region. In San Diego County alone, the underground sex economy represents an estimated $810 million in annual revenue.12 Human trafficking is defined as, "The act of recruiting, harboring, transporting, providing or obtaining a person for forced labor or commercial sex acts through the use of force, fraud or coercion." Human smuggling is defined as: "Acts or attempts to bring unauthorized aliens to or into the United States, transport them within the U.S., harbor unlawful aliens, encourage entry of illegal aliens, or conspire to commit these violations, knowingly or in reckless disregard of illegal status."13

In a joint three-year study published in 2016 by the University of San Diego and Point Loma Nazarene University,14 it was found that facilitators of human trafficking profit $670,625 annually in the San Diego region alone. A "facilitator" refers to the person/s using force, fraud, or coercion for commercial sexual exploitation; "collaborators" are those who benefit financially, and all those involved in the commercial sexual exploitation of children/people.

It is estimated that in 2016, about 40.3 million people were victims of HT worldwide. According to estimates, the U.S. population living in modern slavery today reaches 403,000 people or a sobering one in every 800 individuals.15

In San Diego alone, there are between 3400–8100 trafficking victims annually.16

Financial institutions can often find it extremely problematic to identify the signs of human trafficking. Funds are typically moved quickly, and the transactions may not appear unusual on the surface. Training and awareness are key in order for AML compliance teams to properly mitigate this risk.

Money Service Businesses/Casa de Cambios

It is evident that providing banking services to Money Service Businesses presents higher BSA/AML risks. Money service businesses located in close proximity to the Mexico border carry a heightened level of risk. During an audit, it is important to review the mitigating factors the bank has employed and ensure that all are in line with the bank's risk appetite.

A money services business (MSB) is defined as any person doing business as a:

Check casher

Currency dealer/exchanger

Issuer of travelers checks, money orders, or stored valued cards

Seller or redeemer of travelers' checks, money orders, or stored value cards

Money transmitter

U.S. Postal Service employee

With exception to money transmitters, to be considered an MSB, the business must conduct a transaction of $1,000 or more in any given day. Money transmitters are recognized as MSBs regardless of the amount of the transaction.

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Casa de Cambios are currency exchange houses located within border communities. These businesses typically serve as facilities for tourists traveling across the border to exchange their U.S. currency for Mexican pesos. Casa de Cambios may be used by criminals to launder funds in connection with exchanging U.S. dollars for currencies of other countries prior to the funds being transmitted.

FinCEN states that, "MSBs play an important role in a transparent financial system, particularly because they often provide financial services to people less likely to use traditional banking services and because of their prominent role in providing remittance services."17

Certain MSBs are required to be registered with FinCEN, and most states require them to maintain a license. Although MSBs are regulated by FinCEN, it is extremely important that the financial institution is mindful of how funds are flowing through its institution. Financial institutions should be utilizing a risk-based approach when monitoring their MSBs.

Nonresident Alien Accounts

Foreign individuals living and working in the United States have legitimate needs to establish a U.S. bank account. The amount of NRA deposits in the U.S. banking system has been estimated to range from hundreds of billions of dollars to about $1 trillion. Even at the low end of the range, the magnitude is substantial, both in terms of the U.S. banking system and the economy.18 Nonresident alien accounts create additional risk for financial institutions, since it can be difficult to verify and authenticate nonresident alien identification and their true source of funds. Monitoring efforts surrounding nonresident alien accounts need to be heightened due to their nature. Critical considerations and regulatory expectations increase the risk surrounding NRAs.

Audit Best Practices and Recommendations

Now that the many different unique BSA/AML risks that border banks are currently facing have been identified, the best practices and recommendations listed below can assist the auditor in how to approach testing these unique challenges throughout the audit. A risk-based approach should be used by the financial institution when determining how to mitigate the risks associated with: cross-border transactions, currency restrictions, bulk cash activity, funnel account activity, human trafficking/smuggling, money service businesses/Casa de Cambios, and nonresident alien accounts.

Cross-Border Transactions

Using the case study referenced earlier, in which money laundering organizations operating on both sides of the U.S./Mexico border used funnel accounts, bulk cash deposits, and shell companies in order to integrate illicit funds into the U.S. financial system, an auditor would want to consider the following.

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The auditor should review the bank's BSA/AML risk assessment to verify that the bank has acknowledged this specific type of risk. Confirm that the bank has identified that it is at a higher risk for illicit activity, due to the sole reason that it is located along the U.S./Mexico border.

The bank has scenarios set up to monitor velocity transactions. The case study referenced funnel accounts. Velocity scenarios would alert this type of activity for the bank to review.

The auditor needs to test for transaction monitoring scenarios that drill down on the specific country of origin and test for scenarios that look for funds transfers purchased with currency.

Another factor the auditor should consider is how the bank is addressing potential shell corporations. A shell company is a legal vehicle that typically has no physical presence (other than a mailing address) and generates little to no value. They are commonly used to facilitate illicit activity, which includes money laundering and tax evasion. FinCEN published an advisory citing indicators of possible shell account activity (FIN-2006-G014).19 A typical typology would look like the following: an account that receives multiple deposits from third-party checks, layers those deposits three to four times, and then wire-transfers the money down to Mexico. During testing, the auditor should look at the nature and purpose of the transactions and whether the transactions in the account make sense for the business type. If not, it could be that the transactions are sheer velocity in nature, with no business purpose, and the bank may have shell account activity taking place.

Acting Deputy Assistant Director of the FBI Criminal Investigative Division, Steven M. D'Antuono, said: "The FBI has countless investigations, spanning criminal and national security threats, in which illicit actors, operating both domestically and internationally, use shell and front companies to conceal their nefarious activities and true identities. The strategic use of these entities makes investigations exponentially more difficult and laborious. The ability to easily identify the beneficial owners of these shell companies would allow the FBI and other law enforcement agencies to quickly and efficiently mitigate the threats posed by the illicit movement of the succeeding funds."20

Enhanced due diligence is key. Test to confirm that the bank is performing a deep dive on the documentation gathered at account opening for accounts that engage in cross-border transactions. The bank should employ best practices, such as scanning its database for existing signers. Example: the bank customer has been a signer on multiple accounts, yet many of them have been closed. All of the accounts have different business names, yet the business account documentation all points to the same registered agent. This is not typical of normal business practice, and the bank may be used as a conduit for money laundering due to the accounts that appear to be shell corporations.

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Ensure that the bank has strong know your customer (KYC) and due diligence protocols. Test the bank's policy and procedures to confirm there aren't any loopholes. Verify that the bank is adhering to its policies, and ensure that the policies are commensurate with the bank's risk appetite. If a loophole is found during the audit, then the auditor should address the loophole and suggest enhancements.

Currency Restrictions: Funnel Account Activity and Bulk Cash Activity

1. Funnel Account Activity

When testing for funnel account activity, the auditor should check for red flag activity, such as:

Accounts with multiple deposits that are quickly transferred to other accounts

Accounts with high aggregate dollar deposit activity but low account balances

Accounts with deposits from multiple or different individuals or companies

Accounts with multiple deposits from multiple locations outside the banking area

Accounts with multiple deposits from multiple sources (cash, ATM deposits, checks, wire transfers)

Accounts opened in the U.S. by individuals temporarily residing in the U.S. with immigration documents making transfers back to Mexico

Deposits that are immediately withdrawn or wired out of the account

Transaction activity that does not appear to be consistent with the stated business purpose or occupation of the account owner

Accounts with an unusually high number of chargebacks

Multiple cash deposits made in another state followed by rapid cash withdrawals made in the border state; this type of activity is often termed as "operating outside of the geographic footprint"

2. Bulk Cash Activity

Cash transactions are particularly vulnerable to money laundering. When testing for bulk cash activity, verify the following measures the financial institution has implemented for the monitoring of cash transactions, such as:

Test for patterns of potential "smurfing" activity. Smurfing involves the use of multiple individuals and/or multiple transactions for making cash deposits under the reporting threshold.

If the bank has made a risk-based decision not to offer bulk shipments of currency for its customers, then testing should be comprehensive enough to ensure safeguards are in place to mitigate the risk surrounding this type of activity.

Human Trafficking/Smuggling

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As a financial institution, it can be especially tricky to detect the different patterns of activity that the traffickers/facilitators and smugglers use. As an auditor, it is important to test that the financial institution is properly mitigating this very unique risk. Reviewing the bank's BSA/AML risk assessment to learn what mitigating factors the bank has listed for human trafficking/smuggling will assist the auditor in devising specific testing steps.

Typically, an auditor would want to see monitoring controls that would catch specific financial indicators for human trafficking/smuggling, such as the following:

Consistent use of cash with multiple cash withdrawals and transfers in small amounts that avoid identification and reporting requirements

High volumes of airline and hotel expenses within a single account

Excess transactions involving travel agencies

Customers that may have multiple bank accounts and/or credit cards

Customers that may be using multiple identities with common addresses

High volumes of round dollar deposits via wires, ACH, or cash in amounts ranging from $2,000–$3,000; these could be indicative of payments made straight to the trafficker/facilitator

Extensive payments made to websites that cater to the sex industry

Wires and/or frequent travel to countries known as a human trafficking "hot spot"

Training to identify the signs of human trafficking/smuggling is another key element that will diminish risk for the financial institution. An auditor should test for the following:

Ensure that the BSA Department has received proper training on detecting red flags for human trafficking/smuggling

Branch/customer-facing staff should also be properly trained to identify key behaviors when interacting with customers

Verify that all training is current, relevant, and properly documented A check sheet alone indicating that training took place is not sufficient; review the actual training materials that were used

Money Service Businesses/Casa de Cambios

MSBs are regulated; however, it is prudent that the financial institution have firm controls in place to mitigate the heightened risks associated with these businesses. As an auditor, the challenge in reviewing this industry type comes with many different levels of risk that need to be examined independently. Again, utilizing a risk-based approach when choosing samples will ensure a comprehensive audit.

Best practices in MSB testing include:

Reviewing documents the bank requires for customer due diligence specific to MSBs

Reviewing MSB site inspection forms

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Confirm state licensing and registration with FinCEN (if required)

Verify that the bank has reviewed the MSB's AML program

Determine whether the MSB tests its AML program

Review the volume of cash and checks deposited and that the activity is in line with the business model and the MSBs customer base The auditor will want to ensure that the bank has implemented enhanced surveillance (transaction monitoring) for these high-risk customers

Nonresident Aliens (NRAs)

Verifying and authenticating documentation for nonresident alien accounts in addition to confirming source of funds can be challenging for financial institutions. When performing an audit for a financial institution that banks NRA customers, the audit scope should include a review of the following:

Verify that the bank's customer identification program details the identification requirements for opening an account for a non-U.S. person and that the procedures properly address regulations (FFIEC BSA Exam Manual CIP Overview page 52)21

Review customer due diligence information as well as CIP documentation

Ensure that there are procedures to elevate nonresident alien accounts for ongoing monitoring purposes and that these accounts are appropriately risk-rated

Verify that the bank's transaction monitoring and the reporting of nonresident alien accounts is sufficient, depending on the complexity of the account (source of funds, home country, etc.)

Review transaction details to determine whether actual account activity is consistent with expected activity

Review transaction activity and identify any patterns that may indicate U.S. resident status or that may indicate other questionable or suspicious activity

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Conclusion

BSA audits for financial institutions located along the U.S./Mexico border need to be extremely risk-based, due to their unique nature. Regardless of the asset size of the institution, all financial institutions have to adhere to the same BSA regulations and are examined by the same guidelines via the bank's regulator. The audit scope for banks located within this region need to be extremely detailed and should include the five unique risks identified:

Cross-border transactions

Currency restrictions: funnel account activity and bulk cash activity

Human trafficking/smuggling

Money service businesses/Casa de Cambios

Nonresident alien accounts

When scoping the audit, the bank's BSA/AML risk assessment should be a defining factor. Has the bank implemented effective processes to identify, measure, monitor, and control the specific cross-border risks identified within this white paper? Even if the bank is not actively banking MSBs, does the bank take a proactive approach to reference them on their risk assessment with an indication that it does not bank those customers? Awareness of all potential issues is key to mitigating cross-border AML risk.

Although auditing a border bank comes with its own set of challenges, if the audit is appropriately scoped and focuses on the specific risks of the region (risk-based approach), this will enable the bank's management team, along with the board of directors, to become aware of any potential weaknesses in the bank's BSA/AML program.

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References

1National Money Laundering Risk Assessment 2018. Retrieved from: https://home.treasury.gov/system/files/136/2018NMLRA_12-18.pdf)

2 Department of Justice. (2018, February 7). (Rabobank NA Pleads Guilty, Agrees to Pay Over

$360 Million. Retrieved from https://www.justice.gov/opa/pr/rabobank-na-pleads-guilty-

agrees-pay-over-360-million

3 Baazka, S. ( 2016, December 1). The Trump Era: Potential Shifts in the Anti-Money Laundering

Sphere. Retrieved from: https://amlrightsource.com/posts/trump-aml/

4 Department of Justice. (2019, June 18). Leader of International Money Laundering

Organization Pleads Guilty. Retrieved from: https://www.justice.gov/usao-sdca/pr/leader-

international-money-laundering-organization-pleads-guilty

5 Department of Justice. (2019, June 18). Leader of International Money Laundering

Organization Pleads Guilty. Retrieved from: https://www.justice.gov/usao-sdca/pr/leader-

international-money-laundering-organization-pleads-guilty

6 Financial Crimes Enforcement Network. (2010, June 21). Newly Released Mexican Regulations

Imposing Restrictions on Mexican Banks for Transactions in U.S. Currency. Retrieved from:

https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2010-a007

7 Financial Crimes Enforcement Network. (2014, May 28). Update on U.S. Currency Restrictions

in Mexico: Funnel Accounts and TBML. Retrieved from:

https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2014-a005

8 Financial Crimes Enforcement Network. (2011, April 21). Information on Narcotics and Bulk

Currency Corridors. Retrieved from: https://www.fincen.gov/resources/advisories/fincen-

advisory-fin-2011-a009

9 Financial Crimes Enforcement Network. (2012, July 18). Update on U.S. Currency Restrictions

in Mexico. Retrieved from: https://www.fincen.gov/resources/advisories/fincen-advisory-fin-

2012-a006

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10 Justia Dockets & Filings. (2013, June 7). United States of America v. $89,416.42 in U.S.

Currency Seized from Account Number x-xxx-xxxx-3325 at Bank of America, N.A. Retrieved

from: https://dockets.justia.com/docket/california/casdce/3:2013cv01329/416397

11 U.S. Department of the Treasury. (2012, December 11). Treasury Department Reaches

Landmark Settlement with HSBC. Retrieved from: https://www.treasury.gov/press-

center/press-releases/Pages/tg1799.aspx

12 Abolish Human Trafficking. (2015, October 23). New Study Reveals Complex and Widespread

Sex-Trafficking Ocurring Throughout San Diego County. Retrieved from:

http://www.abolishhumantrafficking.com/new-study-reveals-complex-and-widespread-sex-

trafficking-ocurring-throughout-san-diego-county/

13 Financial Crimes Enforcement Network. (2014, September 11). Guidance on Recognizing

Activity that May be Associated with Human Smuggling and Human Trafficking-Financial Red

Flags, Retrieved from: https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2014-

a008

14 Carpenter, A & Gates, J. (2016, January). The Nature and Extent of Gang Involvement in Sex

Trafficking in San Diego County. Retrieved from: https://www.sandiego.edu/peace/faculty-and-

research/research/human-trafficking-study.php

15 Global Slavery Index. (2018). United States Country Data. Retrieved from:

https://www.globalslaveryindex.org/2018/data/country-data/united-states/

16 Project Concern International. Ending Human Trafficking in San Diego. Retrieved from:

https://www.pciglobal.org/human-trafficking/

17 Financial Crimes Enforcement Network. (2014, November 10). FinCEN Statement on Providing

Banking Services to Money Services Businesses. Retrieved from:

https://www.fincen.gov/news/news-releases/statement

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18 Federal Financial Institutions Examination Council. FFIEC BSA/AML Manual. Expanded

Examination Procedures for Persons and Entities. Nonresident Aliens and Foreign Individuals-

Overview. Retrieved from: https://bsaaml.ffiec.gov/manual/PersonsAndEntities/01

19 Financial Crimes Enforcement Network. (2006, November 9). Potential Money Laundering

Risks Related to Shell Companies. Retrieved from: https://www.fincen.gov/resources/statutes-

regulations/guidance/potential-money-laundering-risks-related-shell-companies

20 International Consortium of Investigative Journalists. (2019, May 24). FBI Says ‘We Must

Learn From The Panama Papers’. Retrieved from: https://www.icij.org/investigations/panama-

papers/fbi-says-we-must-learn-from-the-panama-papers/

21 Federal Financial Institutions Examination Council. FFIEC BSA/AML Manual. Retrieved from:

https://bsaaml.ffiec.gov/manual