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Trade-Based Money Laundering: The Next Frontier in International Money Laundering Enforcement


Praise for Trade-Based Money Laundering

"Trade-based money laundering (TBML) challenges the entire global AML community. John Cassara clearly recognizes this fact and developed 'The Next Frontier' to aid BOTH the private and public sectors. We all owe John a debt of gratitude for his career leadership and commitment to money laundering prevention."
--John J. Byrne, Esq., CAMS, Executive Vice President, Association of Certified Anti-Money Laundering Specialists (ACAMS)

"This book is a fabulous practical ready reference. It exposes a significant problem, trade-based money laundering. As someone who trains AML professionals, I plan to use Mr. Cassara's book as a valuable learning tool. Well done, John."
--Dennis M. Lormel, Founder and former Chief of the FBI's Terrorist Financing Operations Section

"Although Trade-Based Money Laundering is one of the world's greatest financial threats, it is the least understood method of laundering the proceeds of financial crime. Throughout my legal career I have relied on John Cassara to demystify TBML for me. John's thoughtful book is filled with useful and practical information that will demystify TBML for everyone from bank compliance officers to senior government policy makers. It is almost as good as having John on speed dial!"
--David B. Chenkin, Esq., Certified Anti-Money Laundering Specialist, Managing Partner, Zeichner Ellman & Krause LLP

"If there's an expert in the field of Trade-Based Money Laundering, it's John Cassara. I've known John for more than twenty years. During that time, John has investigated TBML as a law enforcement agent and studied it from every angle. TBML is a hot topic in anti-money laundering/combating the financing of terrorism (AML/CFT), and this book is very timely in that it tackles a complex topic in plain language mixed with John's investigative insights."
--Lester Joseph, Former DOJ prosecutor and current bank compliance officer

"Since entering the field of financial crime, John has been a tremendous influence on me. He is very instrumental in his approach to the topic of money laundering and is very clear on the intricacies and complexities it brings. I had the pleasure of working with him first hand and can say the audience we presented in front of was captivated by the information he delivered."
--Steven Crociata, Director of Compliance Programming and Strategic Accounts, ACFCS Association of Certified Financial Crime Specialists

JOHN A. CASSARA is an expert in anti-money laundering and counter-terror finance, with special expertise in money laundering in the Middle East and the growing threat of alternative remittance systems and forms of trade-based money laundering and value transfer. A 26-year veteran of the federal government intelligence and law enforcement communities, he is an industry advisor for SAS, as well as author and co-author of numerous articles and books.

Foreword ix

Preface xiii

Acknowledgments xvii

About the Author xix

Chapter 1 The Next Frontier 1

Chapter 2 Trade-Based Money Laundering Techniques: Invoice Fraud 13

Chapter 3 Black Market Peso Exchange 33

Chapter 4 Hawala: An Alternative Remittance System 49

Chapter 5 Chinese Flying Money 73

Chapter 6 Misuse of the International Gold Trade 89

Chapter 7 Commercial TBML 111

Chapter 8 More Schemes and Facilitators 125

Chapter 9 Monitoring Trade 145

Chapter 10 Red-Flag Indicators 167

Chapter 11 Conclusions and Recommendations 177

Appendix A Money-Laundering Primer 195

Appendix B Original Trade Transparency Unit (TTU)

Proposal 207

Glossary 217

Index 225