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Black Market Peso Exchange

A very recent attempt at the very slick Black Market Peso Exchange method of laundering shows just how a company can be used to launder drug proceeds.

topogigioA local toy company called “Angel Toy Corp.” was indicted in Los Angeles on July 2, 2010 on charges of conspiracy to launder money.

Three defendants from the Angel Toy Corp. illegally structured cash deposits from the illegal sale of controlled substances. One additional subject indicted was a Colombian businessman. The two co-owners and the accountant of the Angel Toy Corp. laundered approximately 8.6 million in drug proceeds over a four year period.

The cash deposits were made on behalf of Colombian and Mexican clients after the cash was dropped off at the toy store or directly deposited into the company’s account. Whenever the cash exceeded $10,000, company employees were instructed to reduce the amounts before placing the money into the account. The cash was then wired to China to purchase Teddy bears and Topo Gigio dolls. The toys were eventually shipped to Colombia and purchased with local currency, which in turn was used to reimburse Colombian drug traffickers.

This is a picture perfect example of the BMPE. Topo Gigio dolls? That must have been the first clue that this was fishy. If you are under 40 you may have no idea of Topo Gigio, the famous mouse from the Ed Sullivan Show. (By the way, no relation to me … Ed that is, not Topo).

These guys should be arrested just for being lame and about 45 years late to the party. Ed Sullivan must be spinning in his grave! I’m sure when good ole Ed said, “We have a really big show” he didn’t realize that Topo was the kingpin dealer to all the other mice!

So the moral of this story is:

A) anything of value can be laundered and; B) methods of laundering money that you don’t think are effective, are exactly why the bad guys will use them.

Further, and more importantly, there is no truth to the rumor that someone from the Mickey Mouse Club has set up Topo Gigio to take a fall.

About the Interviewee

Kevin Sullivan, CAMS, CCI is a retired New York State Police Investigator and Federal Agent who dedicated his career to AML and continues that work through his company, The AML Training Academy and Advisory LLC. Kevin coordinated AML investigations for the state of New York while being detailed to one of the worlds largest AML task forces, the NY High Intensity Financial Crime Area (HIFCA) El Dorado Task Force. He has helped develop and implement global AML guidelines and trained and advised all industries and government agencies requiring AML around the globe. He helped to write various certification programs for the Association of Certified Anti-Money Laundering Specialists’ (ACAMS) and was the co-founder and former chair of their inaugural chapter which was in NY. Follow Kevin or reserve a seat in one of his live webinars. Space is limited!

I work with AML/BSA compliance programs large and small, if you need a customized and quality anti-money laundering program, training, or advise I invite you to contact me to learn how I can help with your compliance needs.

Kevin Sullivan, CAMS, CCI
President of
The AML Training Academy and Advisory LLC

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