| Two former Bank of China managers and their wives were recently convicted by a Federal jury in Las Vegas for racketeering, money laundering and passport fraud, among other charges. From 1991 through 2004, the defendants defrauded the bank of at least U.S. $485 million. Their scheme included fake passports and visas, sham marriages to U.S. citizens, shell companies in Hong Kong and big bets ($20,000-$80,000) in Las Vegas casinos.
A number of state, federal and international law enforcement agencies, including those from the normally unlikely diplomatic bedfellows of the People’s Republic of China and Hong Kong, cooperated to bring them to justice proving that many governments around the world apparently view chasing down money launders as a top priority. But, despite their elaborate shell game of running the money through different banks in multiple nations and Las Vegas casinos, these schemers were tripped up not by one of the more complicated aspects of their ruse, but rather by simple AML reporting requirements.
This group’s use of high-value transactions is what did them in. Casinos are required to report on their high-roller activity, including the filing of Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs). While these individuals took numerous elaborate steps to disguise their identities, they did not take the same care to obscure the sheer volume of their assets. Sometimes it’s the small stuff that brings down the biggest games.
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