Sheet1Fuentes - Lavado de Dinero en MonterreyURLFecha CifrasApunteshttp://www.jornada.unam.mx/2011/04/10/politica/005n1pol 4/10/11"El pasado 4 de abril este casino [Casino Revolucin] fue atacado por un comando que lanz una granada y rfagas de metralleta: una persona result herida, ocho sufrieron crisis de histeria y dos vehculos fueron incendiados, uno ardi en su totalidad...Desde hace 15 aos el gobierno de Estados Unidos considera a Monterrey como el principal centro de lavado de dinero. El Estudio Binacional de Bienes Ilcitos Mxico-Estados Unidos seala que entre 19 mil y 29 mil millones de dlares producto de la venta de drogas son introducidos al ao al pas para su blanqueo.Las proporciones del problema sin atender debidamente por el Estado son tan grandes que la misma Asociacin de Permisionarios de Juegos y Sorteos reconoce que la delincuencia organizada tiene operaciones de lavado de dinero en 40 casinos del norte de la Repblica...La Ley Federal de Juegos y Sorteos tiene 63 aos y es considerada obsoleta por la propia Secretara de Gobernacin, que acepta la vulnerabilidad ante "la corrupcin y el lavado de dinero". "Es necesario crear un nuevo marco jurdico para evitar discrecionalidad e ilegalidad", seal Juan Bosco Mart Ascencio, titular de la Unidad de Gobierno de Gobernacin.

La proliferacin de casinos en Monterrey sucede al ritmo que permiten la opacidad y el trfico de influencias en la venta de permisos federales por millones de dlares. Un inversionista estadunidense coment que le ofrecan 10 permisos de casinos por 18 millones de dlares. El estado y los municipios carecen de facultades para regular y controlar los casinos que inmediatamente obtienen amparos federales para su operacin violando leyes locales, algo que urge corregir, segn Sandoval Villarreal: "Es muy lamentable y estamos contra ese trfico de permisos. Son montos muy elevados y no podemos esperar nada bueno de esto. Se va a saturar el mercado y si los empresarios estn invirtiendo esas cantidades las querrn recuperar y finalmente quien viene pagando son los clientes en detrimento de las familias".

Las transacciones financieras en los casinos sin recibo ni comprobantes de por medio generan el lavado de dinero. Algo sintomtico es que la Concanaco no tiene afiliados con este giro: "Hay muchas lagunas legales. La propuesta de reforma de la ley lleva aos estancada. Los permisos los proporciona la autoridad federal. Los estados y los municipios han tenido batallas y todas las han perdido. Con la situacin de inseguridad y que este tipo de negocios estn ligados a la delincuencia, la autoridad en muchas de las ocasiones prefiere no actuar y deja que los casinos funcionen".

Entre los beneficiados de los permisos para 450 casas de apuestas otorgados por Santiago Creel Miranda cuando era titular de Gobernacin se encuentran Emilio Azcrraga y Televisa, Olegario Vzquez Raa, Jos Mara Guardia, Arturo Rojas Carmona, Jess Hctor Gutirrez Corts, Juan Eduardo Mounetou Prez, Carlos Enrique Abraham Mafud, Ral Santiago Fernndez y Pablo Cortina de la Fuente, Fausto Zern Medina y Greg Snchez, pero los negocios no aparecen a su nombre, sino al de empresas, razn social o sociedad annima, lo que propicia mayor opacidad: 'Desde entonces esos permisos se han ido instalando conforme los empresarios han ido queriendo. Cuando uno pregunta de quin son los casinos?, en esos negocios nadie sabe. Son sitios muy grandes con mucho personal y nadie sabe quin es su patrn. Hacienda o Gobernacin deberan sabe.'"1. Casino Revolucion was attacked by a comando with grenades and a sub-machine gun shortly before 4/10/11. One wounded, eight freaked out, two cars burned. 2. According to the "Estudio Binacional de Bienes Ilcitos Mxico-Estados Unidos", between $19 and $29 bil from drugs are laundered in the country each year. 3. The "Asociacin de Permisionarios de Juegos y Sorteos" recognizes that around 40 casinos (there are supposedly about 50) in the north of the country are involved. 4. At 63 yrs old, the current Federal gambling laws in Mexico are inadequate. 5. The whole process through which you recieve permission to build a casino is opaque and corrupt. One American investor said that the federal authorities offered him 10 casino permits for $18 mil. 6. Oftentimes they violate local law but recieve federal protection. 7. Under Santiago Creel Miranda (Secretary of the Interior 12/1/00-6/1/05) 450 gambling houses recieved permision and among the assholes who benefited are: Emilio Azcrraga y Televisa, Olegario Vzquez Raa, Jos Mara Guardia, Arturo Rojas Carmona, Jess Hctor Gutirrez Corts, Juan Eduardo Mounetou Prez, Carlos Enrique Abraham Mafud, Ral Santiago Fernndez and Pablo Cortina de la Fuente, Fausto Zern Medina and Greg Snchez. 8. Regardless, no one knows who the owners are of most of these casinos. http://www2.eluniversal.com.mx/pls/impreso/noticia.html?id_nota=10633&tabla=primera1/7/02""Los narcotraficantes y operadores financieros aprovechan que en Nuevo Len existen miles de sucursales bancarias y casas de bolsa, para disimular sus transacciones", reconoci el gobernador Fernando Canales Clariond.

Eran los primeros aos de la dcada anterior, cuando Juan Garca brego, cabeza del crtel del Golfo, decidi mudarse de Tamaulipas a Nuevo Len, para sentar sus reales. Con l llegaron sus lugartenientes, entre ellos Ral Valladares del ngel, detenido en 1995. Pero, sobre todo, lo acompaaba Carlos Resndiz Bertoloussi, considerado el cerebro financiero de esa organizacin, ahora testigo protegido del gobierno estadounidense, as como su hermano Humberto, quien cre las empresas Prodeconsa, y Diseo y Construcciones la Herradura.

A mediados de 1997, los banqueros de Monterrey, encabezados por su presidente Francisco Gonzlez Martnez, anunciaron un frente comn y convinieron acciones para un control ms severo en la captacin de dinero, proveniente de inversiones tanto nacionales como internacionales.

El sector empresarial demand combatir a fondo el lavado hormiga de dinero, mediante una profunda reforma al marco regulatorio financiero para un mayor control sobre las transferencias electrnicas que realizan los mexicanos radicados en Estados Unidos, pues se desconoce la procedencia de la mayora de esas operaciones. Tambin el llamado blanqueo hormiga consiste en que los narcos llegan diariamente a las casas de cambio con sus portafolios repletos de dlares, que venden a un peso o cincuenta centavos menos de la cotizacin del da.

De acuerdo con el Departamento de Estado de Estados Unidos, la ciudad de Monterrey se haba convertido, a fines de 1997, en el principal centro de lavado de dinero en Mxico, con 4 mil millones de dlares. A este respecto, la coordinadora de la diputacin local del PRD, Lucilda Prez Salazar, exigi al gobierno federal que la PGR y la Secretara de Hacienda investigaran y, en su caso, confirmaran o desmintieran tal informacin, sin resultado alguno.

Segn la agencia antinarcticos estadounidense DEA, Monterrey es una de las tres ciudades mexicanas las otras dos son Cancn y Hermosillo, que sirven de puente del lavado de dinero entre Colombia y varias ciudades de Estados Unidos. Monterrey es enlace para las ciudades del norte, noreste, centro y sur de la Unin Americana; Hermosillo para la costa oeste, sobre todo California, y Cancn con el sureste, especialmente Florida. Hasta donde se sabe, los municipios con mayor lavado de dinero en el estado de Nuevo Len, son Monterrey, San Pedro y Guadalupe, mediante operaciones en restaurantes, discotecas e inmobiliarias. Segn la Polica Judicial Federal (PJF), la zona residencial de Las Mansiones sera uno de los principales blancos de inversiones de dudosa procedencia, al igual que las casas que obtienen los ganadores del sorteo Tec.

La PGR detect, a mediados del 2001, que el empresario Servando Cano es presunto cmplice de Edelio Lpez Falcn, El Yeyo , uno de los cabecillas del llamado crtel de Monterrey. Las indagaciones llevaron a descubrir que le alquilaba a la citada organizacin una de sus caballeras, a fin de guardar los valiossimos equinos pura sangre."1. According to ex. Gov. Fernando Canales Clariond, organized crime takes advantage of the fact that in N.L. there are thousands of bank branches and exchange houses through which to launder money. 2. In the early 90's Juan Garca brego, the head of the Gulf Cartel, moved from Tamaulipas to N.L. along with his Lt.'s like Ral Valladares del ngel and the financial brains of the organization Carlos Resndiz Bertoloussi, who is now in the US witness protection program, and his brother Humberto who created the companies "Prodeconsa, y Diseo y Construcciones la Herradura." 3. In 1997 the bankers in Monterrey led by Francisco Gonzlez Martnez reccomended stricter regulation on banking transactions. 4. The commercial sector demanded the the gov. thoroughly combat "el lavado hormiga de dinero" using financial regulatory reform for greater control over electronic transfers of Mexicans based in the US. 5. There's also "blanqueo hormiga" where the narcos go to the change house daily with folders full of money and sell them for a peso or .50 pesos less than the current rate. 6. According to the US Dept. of State, at the end of 1997 Monterrey became the principle money laundering center in Mexico with $4 billion. 7. According to the DEA Monterrey is one of three principle Mexican cities, the other two being Cancun and Hermosillo. Monterrey serves the N,NE, center and S of the US, Hermosillo the W coast esp. California and Cancun the SE esp Florida. 8. The cities in N.L. with the most money laundering are Monterrey, San Pedro, and Guadalupe where it often happens through restaurants, clubs and real estate 9. According to the Federal Judicial Police, the neighborhood of "Las Mansiones" is one of the principal targets for investments of doubtful origin. http://www.lostubos.com/%C2%BFy-el-lavado-de-dinero/6/23/11"difcilmente se ven capturas que tengan que ver con la red de complicidades que tienen que ver con el lavado de dinero y el financiacin del crimen.

En el Acuerdo Nacional por la Seguridad, la Justicia y la Legalidad se emitira, segn se mencion ayer por fuentes hacendarias, una estrategia contra el lavado de dinero; una iniciativa de ley para regular operaciones en efectivo; instruir a Gobernacin, Seguridad Pblica y la SHCP para que en conjunto se investiguen averiguaciones previas sobre lavado de dinero y financiamiento al terrorismo.

Ya existe una iniciativa de Ley para la Prevencin e Identificacin de Operaciones con Recursos de Procedencia Ilcita. Y la Iniciativa de Decreto por el que se reforman y adicionan diversos ordenamientos legales en materia penal y financiera, adems de la Ley Federal de Extincin de Dominio.

En entrevista, miembros de la Coparmex piden abundar ms en las investigaciones, el diputado Hctor Gutirrez de la Garza recuerda que el tema del lavado de dinero fue prcticamente abandonado a lo largo del sexenio y el alcalde de Monterrey, Fernando Larrazabal, indica que se han dado golpes a la financiacin del crimen, como el emprendido en contra del contrabando y los piratas en la calle Reforma de Monterrey."1. In the National Agreement for Security, Justice and Legality there will be a strategy against money laundering; a legal initiative to regulate cash transactions; training to the gov., public security, and the SHCP so that they can work together to investigate money laundering. 2. There is already a law in place for the prevention and identification of operations with resources of illicit origin. 3. In an interview, members of Coparmex asked for more investigations into money laundering. The deputy Hctor Gutirrez de la Garza reminded everyone that money laundering was practically abandoned during the past six years. https://research1.stratfor.com:8443/dosearchsite.action?queryString=lavado10 101. P. 3 L. 12 According to a study by the U.S. and Mexican gov's between $19 and $29 billion in illicit funds are brought to Mexico annually (R*: find this study). 2. P. 3 L. 14 According to a study by the Woodrow Wilson International Center in 2008 the operating resources of the Mexican cartels may have reached $30 billion (R*: find this study). 3. P. 4 L. 15 Another report by this same organization says that the number varies between $25 and $35 billion, of which 80% is used to pay for new drug shipments so Mexican cartels earn about $5 to $7.2 billion in profit (R*: find this study). 4. P. 4 L. 23-31 A study by the International Programs and Drug Policy Research Center concludes that these organizations earn on average around $7.1 billion a year (R*: Find this study). 5. P. 4 The president of the "Comision Nacional Bancaria y de Valores", Guillermo Babatz, says that Mexican Banks accumulate $14 billion every year of unknown origin (R*: find this article in Reforma 11/10/10). 6. P. 4 L. 29 The ONU estimates that for cocaine 70% of profits generated through sales are retained by intermediary traffickers who deliver the product to consumers. 7. P. 5 The value of retail sales of Cocaine, Heroine and amphetamines is around $55 billion. 8. P. 5 L. 12,13 American street gangs also play a role and in the US one can transfer amounts of less than $10,000 to dolarized countries such as Ecuador, Panama, and El Salvador. 9. Recently Wachovia admitted it hadn't done enough to identify the handling of illicit funds that totaled $378.4 million coming from Mexican exchange houses between 2004 and 2007 (R*: find this court case). 10. P. 5 L. 17 The majority of illegal money that enters Mexico arrives through the border in small quantities through operations coordinated by the cartels or third parties. Money also comes in through airports and we have also identified courrier services and trucks and only one fourth goes into the financial system. 11. P. 7 The rising importance of over-the-border cash transfers led the US to establish, in Dec. 2009, an office that specializes in stopping such operatings called the Bulk Cash Shipment Center as well as penalizing those who transfer amounts greater than $10,000 done with the intent of avoiding registering with authorities. 12. P. 7 Since 2005 the U.S. has confiscated$277.8 million and detained 555 suspects and in 2009 they confiscated $124.7 million. 13. P. 7 L. 35-42 In 2004 Mexico established the "Unidad de Inteligencia Financiera" within the Treasury Department. In 2009 they received 53,000 reports of unusual activities, 43% more than the year before, 119 reports of worrying operations, 23% more, and 35,800 inquiries, 37% more. 14. P. 8 During the three and a half years that Calderon has ruled $411.9, which represents 11 times as much as the previous president in his first three years and 35 times that of Ernesto Zedillo, has been confiscated. 15. P. 8 The head of the Treasury Department said that during his time they have investigated around $36 billion in suspected laundered funds. 16. P. 8 L. 43-46 Despite this the number of people convicted for such crimes has fallen while criminal investigations rose 600%, and the cases going to court increased 120% orders for arrest decreased 19% and sentences decreased 9%. 17. P. 8 On 8/26/10 Calderon created the "Estrategia Nacional para la Prevencion y el Combate al Lavado de Dinero" that revolves around three axises: effectively stopping money laundering operations, strengthen legal mechanisms to combat it and strengthen the intelligence operations and measure and publish state operations. 18. P. 9 They made a list of three objectives to combat money laundering. 19. P. 11 The majority of laundered money in Mexico is in the form of American cash from drug proceeds though other illicit activities generate income too while cash isn't the only instrument used to store value. 20. P. 11 Organized crime introduces its profits into the financial system by currency exchanges, buying real estate, luxury vehicles and front companies. 21. P. 12 Recently the US and Mexico conducted the Bi-National Criminal Proceeds Study in order to find out how illegal money is collected, transported and sent to Mexico (R: Found the Bi-National Criminal Proceeds Study). 22. P. 12 According to the document cited, the money is sent to the border where it then is transported in small quantities across using people or containers by the criminal groups themselves or a hired third party. 23. P. 13 Map of money laundering routes. 24. P. 14 Organizations connected to the Sinaloa Cartel have managed to control hydrochloride production for cocaine in Bolivia and Peru. 25. P. 14 According to the article cited Mexican gangs control 70% of the Colombian cocaine supply. 26. P. 14 The transactions end in Ecuador with its dollar denominated currency. Ecuador has also been classified by the FATF as a jurisdiction that doesn't cooperate. 27. P. 15 The alliance between the Mexicans and Colombians has made it easier for both sides. 28. P. 15 Today it is possible to transfer less thann $10,000 directly to the US using multiple accounts located in countries with dolar based currencies like Ecuador, Panama where a free-trade zone exists, and El Salvador where the fastest growing financial system, with the least transparency, is. 29. P. 17 A large amount goes through airports where controls aren't adequate to search every passenger. 30. P. 17 Vans and trucks used to cross the border can carry more but they are used less and less. 31.P. 17 A small amount is converted into other forms of payment before crossing while. 32. P. 17 Debit cards and "hormigas" - people paid about $500 to carry $5,000 to $10,000 are also used. 33. P. 37, 38, 53 Mexico has implemented some new laws. Among them is a law that banks are required to delimit purchases up to $4,000 monthly for depositors and $1,500 monthly for those who aren't. Foreigners can exchange up to $1,500 to pesos a month. All transactions above $500 must be reported to the financial authority. "Moral" depositors will be allowed $7,000 monthly in tourist and border areas. Another option for tourists and "moral" depositors is to use the "Corresponsales Bancarios Cambiarios" that allows hotels and businesses to let their clients use it as a bank. The hotels can only purchase dolars for foreign tourist guests up to $1,500 and the guest fills out a form. "Money Laundering and Bulk Cash Smuggling." Confluence > Search: "Lavado". https://research1.stratfor.com:8443/download/attachments/622661/Money+Laundering+and+Bulk+Cash+Smuggling.+Farah.pdf?version=1&modificationDate=12911363720005 101. P. 9 Money is taken to a central counting house one one of several major U.S. cities including Atlanta, Boston, Chicago, and LA. It usually arrives from the street in the form of smaller bills where it is then converted to $100 or $50 bills. After that it is vacuum sealed into plastic bags into smuggling compartments on clean vehicles. 2. P. 9 Vehicles are rotated so as not to raise suspicion, shipmentsusually range from $150,000 to $500,000 so that potential disruption doesn't disrupt operations. Now they have a constantly rotating group of drivers. It used to be aggregated and packaged on the US side but due to heavier law enforcement scrutiny most drivers continue on into Mexico. 3. P. 10 At the border a halcon watches a specific border entry point and some cartels even employ sophisticated logistics centers in order to coordinate arrivals. Traffic going south is under less scrutiny, only one in 10 cars is supposed to be searched and in reality it's even less, and they usually search one lane at a time so a halcon simply alerts the driver. 4. P. 10 If they end up in one of these lanes they can gun through the border point or simply get out of the car and walk into Mexico with the crowd. 5. P. 11 Exchange houses are no longer the place of choice due to heavier restrictions on their use. 6. P. 12 Now bulk cash transfers are more common due to post 9/11 banking restrictions and the dollarization of Mexico after NAFTA. 7. P. 12 Under the PRI corruption was top down but now in the multi-party system many officials in each party must be bribed. 8. P. 13 There are 3,603 seperate notary publics in Mexico. Most aren't searchable or computerized so land purchases are common. 9. P. 14 Now the cartels also provide financing for farmers. 10. P. 20 Mexican DTO's will use front companies to buy shipments of cheap Chinese plastic products at an inflated price and then refilter that money into the system. 11. P. 21 Russian mafias buy up properties, usually hotels and casinos because these are cash intensive, and they help the Mexican DTO's launder money. http://www.oem.com.mx/elmexicano/notas/n1555843.htm3/14/101. Technically casinos aren't legal in Mexico. 2. Recently the "Grupo de Accin Financiera Internacional" (GAF) conducted a study that was shortly followed by one published in "El Sol de Mexico", which described gambling operations as an effective means to launder money (R*: find these two studies). 3. An investigator from INACIPE lists several ways that money is laundered. 4. Firstly, DTO's use cash squivalents issued by the casino such as chips or machine credits. 5. Casinos can also give "credit chips" for players that play on loan and "dead chips" that are only used by gambling tourists. 6. Chips are the most commonly used medium because of their versatility and extent to which casinos use them for most things. Oftentimes they buy chips with cash and then exchange it for a check from the casino or a bank credit transfer. 7. Usually reimbursement is done through check, money order or transfer that charges the casino's account. This method becomes more obscure by using casino chains where the chips bought with illicit funds are then transfered to another jurisdiction where the same casino chain operates. That credit is then exchanged for a check in the new jurisdiction. 8. Another common method is to buy chips from legitimate players for a higher price. 9. They often "smurf" their funds using these techniques too. 10. Another method is to use the accounts and lines of credit that many casinos give to their customers. These accounts are usually less scrutinized than ones at financial institutions. The frequent exchanges between casinos and financial institutions and other casinos obscures the entire process. 11. Many casinos offer private security boxes to VIP/high rollers. 12. Another form is the transfer of funds to the casinos from exchange houses in other jurisdictions http://www.oem.com.mx/laprensa/notas/n1556978.htm3/15/101. "La Confederacin Nacional de Cmaras de Comercio" estimates that around 500 "brincos", "garitos" and illegal casinos operate in the country. 2. Jorge L. Romo of the "Instituto Nacional de Ciencias Penales, de la Procuradura General de la Repblica" wrote a report entitled "El Lavado de Dinero y los Casinos" (R*:Find this report). 3. In addition to all the aforementioned techniques, he elaborates on the usage of safety deposit boxes in casinos. 4. He also mentions various signs of money laundering in a casino such as money deposited from unknown sources and a lot of activity over a short period of time. 5. Another popular method is to place small bets on games with large jack pots. The launderer then recieves a check from the casino for the remaining credits in the machine plus the jack pot (*What?). 6. Some jurisdictions require the casinos to record if the profits were obtained from game prizes to distinguish them from checks originating from the cashing in of large amounts of money in the remaining credits on machines. 7. Because casinos are popular with tourists many offer money exchange centers too so foreigners exchanging large amounts of money isn't out of the ordinary. 8. Oftentimes employees or the casinos themselves will collude with them. 9. They also use debit or credit cards stolen or obtained using a false identity to buy casino chips. 10. Launderers take advantage of that fact that groups of "Junkets", foreign tourists who go on all-expenses-paid trips to gamble, frequently visit Mexican casinos. As a result, big groups of foreigners transfer large amounts of money across the border and into the casinos which provides ample opportunity for launderers. Sometimes the "Junket" operator takes care of transfering all funds electronically to and from the casinos in his own name so the identity of who the money belongs to usually isn't clear. 11. Money laundering laws are mostly inadequate and they vary by jurisdiction. For example, some casinos operate offices and promotional offers to open up accounts outside of the jurisdiction where they're based. So, clients can make deposits to their casino accounts and then they can withdraw those funds during their trip to the casino without having to make electronic transfers from one side of the border to the other. http://www.google.com/url?sa=t&source=web&cd=1&sqi=2&ved=0CCIQFjAA&url=http%3A%2F%2Fwww.imf.org%2Fexternal%2Fpubs%2Fft%2Fscr%2F2009%2Fcr0907.pdf&rct=j&q=Mexico%3A%20Detailed%20Assessment%20Report%20On%20Anti-Money%20Laundering%20and%20Combating%20the%20Financing%20of%20Terrorism&ei=0oAMTp6-JaujsQKczYiYCg&usg=AFQjCNHZ-V8aYmDLgaPGUGGc6RkM6zPmYA&cad=rja 1 09 1. P. 31 There is no legal definition of casinos in Mexico.The law prohibits all games of chance except those explicitly listed. The activities that are typical of casinos, including slot machines are, in principle, prohibited. 2. P. 31 The law only authorizes the issuance of temporary permits for betting game halls (salones de apuestas) when they are part of regional fairs which are rooted in Mexican traditions. These temporary permit holders offer most games expected from a fully fledged casino, including games of cards, dice, and roulette, as well as slot machines, and they can be of a very large magnitude. The most important of these fairs, the San Marcos Fair, is estimated to draw six million local and foreign visitors per year, of which some two million go to play in the casino. No estimate of money generated from these activities is available. Although the total number of temporary casinos could be as high as four per state every year, in practice, no more than five such casinos are normally authorized, and only one was authorized in 2007. 3. P. 31 The Ministry of Interior undertakes a fit and proper review of the applicants every year. Based on its general powers under the Regulations of the Gaming Law, the Ministry has recently imposed a contractual obligation on permit holders to keep an accurate registry of the identity of their customers in order to determine whose bets, in light of the amount of such bets, raise the suspicion that transactions with illicit resources are being conducted. The most recent permits issued obligate permit holders to inform the authorities of any behavior or practice of the users that is likely to constitute a felony related with organized crime or transactions with illicit resources. There is, however, no information with respect to the practical implementation of these new requirements. 4. P. 31 The following are gaming and drawings activities authorized by the Gaming Law and subject to prior authorization from the Ministry of Interior (Secretaria de Gobernacion)10: Chess, checkers and other similar games; domino, dice, bowling and pool games; any kind of ballgames; person, vehicle and animal races and in general, all kinds of sports. Operation of bets in racetracks (greyhound and horses) and squash or front-tennis. Operation of remote betting centers 11. Operation of number drawing halls 12. Horse races and cockfights, with bets in temporary venues. 5. P. 32 Of significant concern for the authorities is the existence of unauthorized betting game halls across the country, consisting of conspicuous establishments with large numbers of slot machines. The government regularly takes enforcement actions to shut them down, only to see them resurface under a different name. Many are even successful in challenging the Ministrys actions in court by claiming that they operate games of skill and not of chance, thereby making the Gaming Law inapplicable to them. 6. P. 32 The degree of sophistication of these businesses varies, but some of them have several locals across the country and provide customers with electronic cards which store the customers cash holdings and may be used to place bets at machines in other affiliated establishments. These businesses are illegal and vulnerable to misuse by money launderers, in the authorities own view. They are perceived as legitimate businesses by the community and by financial institutions in the municipalities where they operate, and that makes them an ideal front to channel cash from illegal sources. 7. P. 32 For purposes of this assessment, it is important to clarify that these unauthorized gaming halls, which basically offer slot machine games, are not covered by the requirements of FATF R.12 and 16. Therefore, the insufficient capacity of the authorities to enforce the prohibition of slot machines is not relevant to the assessment of compliance with the FATF recommendations. http://www.ice.gov/doclib/cornerstone/pdf/cps-study.pdf - Bi-National Crime Proceeds Study6 101. P. 8 The bulk cash supply chain in Mexican cartels is one in which all orders come from the top down (from the leadership in Mexico all the way to smugglers in the US). Firstly, this indicates the importance of communication throughout the supply chain. Second, it indicates that they have the greatest ability within the network to protect their interests allowing them to shift risk to other organizations in the supply chain. Third, it provides a targeting opportunity to remove the pull signal from the supply chain and force the network to adapt the current model to meet the new threat. 2. P. 8 There are two models used to handle the smuggling of criminal proceeds into Mexico: 1: Insource Model - bulk cash shipments are managed internally by the cartel itself. 2: Outsource Model - they use the service of a money broker or outside contractor. 3. P. 8 The insource model allows the cartels to have full control over their supply chain while the outsource model is used when they want to diversify their bulk cash flow or when there is limited access to resources (i.e., network of Transportation Operators or couriers) available for the movement of the cash. 4. P. 9 Map of U.S. - Mexico bulk cash smuggling routes. 5. P. 9 The vast majority of proceeds are laundered in bulk cash form. 6. P. 10 Most bulk cash siezures occur at airports though this is probably misleading because officers have more time to check luggage there. Additionally, most of the cash siezed at airports is destined for other locations. 7. P. 10 Commercial trucks are believed to transport bulk cash less frequently but when they do it is often in large quantities. 8. P. 10 Another common method is to use a ruta hormiga where they pay someone around $500 to smuggle across $5,000-$10,000 through daily border crossings. Once the money reaches Mexico it is usually brought to a border town and sometimes a hub city. From there it is handed off to a cartel member at a designated location and it then falls under the responsibility of the cell chief. 9. P. 10-11 Certainly less than half and no more than a quarter of all bulk cash is laundered into a financial institution. 10. P. 11 Regulated Mexican financial institutions subject to AML laws include credit institutions (including commercial and development banks); limited scope financial institutions (such as non-bank banks), broker dealers, casas de cambio (currency exchange and money remittance businesses), centros cambiaros (currency exchange businesses), afores (pension management companies), general deposit warehouses, financial leasing companies, savings and loan cooperatives, transmisores de dinero (money remittance business), bonding companies, mutual fund distributors, and mutual fund managers. 11. P. 11 Many banks have been diligent in enforcing AML regulations and a number of them have stopped accepting walk-in cash deposits in cities with a lot of cartel activity (e.g., Jalisco, Michoacan, Guerrero, and Sinaloa). Mexican banks rely on the U.S. OFAC list because there is no Mexican equivalent. 12. P. 11 Another trade based money laundering technique is to sell secondhand clothing to Mexican vendors which is illegal for sanitary reasons. 13. P. 11 Communication is key and throughout the entire process each element has to have reliable communications with the others. 14. P. 12 The cartels are adept at compartamentalizing knowledge of the supply chain in order to limit the impact of law enforcement. javascript:open_window("http://catalog.gpo.gov:80/F/5UE9AYXN4DGIPC4LDYV7JE9XGPK9GHRXPE22JEG2CN9EMAATHJ-49841?func=service&doc_library=GPO01&doc_number=000818532&line_number=0001&func_code=WEB-BRIEF&service_type=MEDIA"); - Search for "money laundering" in the Catalog of U.S. Government Publications. The report's code is GA 1.13:GAO-11-73 10 101. P. 7 U.S. Customs and Border Protection (CBP), a component of the Department of Homeland Security, is in charge of policing American borders. 2. P. 8 In Mar. 2009 the secretary of the DHS asked the CBP to help stem the flow of weapons and bulk cash out of the country thus expanding the CPB's mission. 3. P. 8 The Financial Crimes Enforcement Network (FinCEN), a bureau in the Dept. of the Treasury, is responsible for preventing criminals from abusing the U.S. financial system. 4. P. 12 The CBP has stepped up outbound inspections at all 25 U.S.-Mexico border crossings. 5. P. 13 For outbound operations, CBPs budget was about $109 million in fiscal year 2009 and is an estimated $145 million for fiscal year 2010. 6. P. 14 CBP operates 327 ports of entry in the US and it estimates that in 2009 it inspected 360 million travelers (70%0 of the total). 7. P. 14-15 CBP has a different procedure for people leaving the country as opposed to those coming in. They ask travelers whether they (1) intend to leave the country by asking where they are going, (2) are carrying more than $10,000 in currency, checks, money orders, or any other type of monetary instrument, and (3) are transporting any weapons or ammunition into Mexico or Canada. 8. P. 15 For travelers who carry or individuals who ship, mail, or receive more than $10,000 in currency or other monetary instruments, such as travelers checks or money orders, into or out of the U.S., CBP requires them to fill out a form called the Report of International Transportation of Currency or Monetary Instruments. When travelers fail to file a form, file a form with material omission, or misstatement, or file a false or fraudulent form, they are subject to civil and criminal penalties, including under certain circumstances a fine of not more the $500,000 or imprisonment of not more than 10 years, or both. In addition, the currency or monetary instrument may be subject to seizure and forfeiture. 9. P. 16 Sometimes CBP officers conduct secondary inspections. 10. P. 18 FinCEN is responsible for the administration of the Bank Secrecy Act (BSA) a statute that authorizes FinCEN to require MSBs and other financial institutions as well as nonfinancial trades or businesses and many individuals to maintain records and file reports that have a high degree of usefulness in criminal, tax, regulatory investigations or procedures, or certain types of counterterrorism investigations. 11. P. 18 FinCEN has about 300 staff. 12. P. 20 Recently money launderers have used stored value cards. 13. P. 27 Since the implementation of this new program bulk cash siezures have increased markedly but two crossings represent half of all siezures and 80% were siezed at five crossings on the SW border. 14. P. 28 However several obstacles remain. First, CPB doesn't conduct operations on a full time basis so smugglers can cross when the CBP is off duty. Second, officers have limited equipment for outbound operation. Third, the CBP has to balance between long wait times and stepped up inspections. http://www.yogonet.com/espanol/2011/05/26/mexico-en-un-ataque-comando-asaltan-cuatro-casinos-de-monterrey http://thenarcotimes.blogspot.com/2011/05/dan-aviso-casinos-con-ataques-en-nl.html http://www.youtube.com/watch?v=zz3GN1m-004 http://www.youtube.com/watch?v=Zm0I4wYaIBk&NR=15/26/111. In the center of Monterrey gunmen robbed four casinos at gun point. 2. The chain of attacks occurred at 2 AM when the casinos were packed. 3. The first attack occurred at Hollywood Casino (or Casino Royale according to the second source). Witnesses say gunmen arrived in Murano vans screaming with high calibre weapons, shot in the air and told customers to get down on the ground. Some stayed outside and shot in the air while others entered. Then they took the money from the registration boxes and fled. 4. In Casino Miravelle, which is almost a km. from Casino Royale, a gunman hit two employees and shot into the ceiling damaging chairs, seats, walls and other things. 5. Municipal, State and Federal police arrived around 2:10 AM along with the Mexican army but the attackers got away. The other attacks occurred afterwards at the Royale, Red and Miravelle Palace casinos in the same fashion. 6. The mayor of Monterrey demanded that the government verify their permits because, according to the local press, they operate under legal protection (amparo) and without authorization. 7. In each case the gunmen who looked like gang members arrived and robbed the casino as described in #3 before causing damage to the interior and exterior of the casinos and fleeing without a problem. 8. On 5/20/11 the municipal government closed three casino construction sites for presumed irregularities in permits and licenses and the week before they closed at least ten other businesses for the same reason however the majority obtained legal protection (amparo). 1. http://www.lapoliciaca.com/nota-roja/procuraduria-descarta-ataque-contra-ministerial-en-casino/ 2.http://www.youtube.com/watch?v=vzyqxhf8GvE&feature=related2/15/111. On the night of 2/14/11 a shooting occurred at entrance of the Jubilee Casino. 2. An agent of the Ministerial Police, Patricia Marroqun Ramrez, was leaving at the time however the Attorney General denies that she was the target. Her car was hit but she came out unscathed after hiding under the car's control panel. 3. 45 year old Ricardo Daz Silva was wounded and the attack damaged the building's facades and hit a car and two trucks, one of which was driven by the Ministerial Police. 4. The attack occurred at 23:30 on 2/14/11. 1. http://notaroja-koneocho.blogspot.com/2011/04/nuevo-leon-ataque-casino-en-monterrey.html 2.http://mexico.cnn.com/nacional/2011/04/04/grupo-armado-lanza-una-granada-a-un-casino-en-monterrey-hay-un-herido 3. http://www.youtube.com/watch?v=hkys6-8UddY&feature=related4/4/111. On 4/4/11 at 18:40 Casino Revolucion in Monterrey was attacked. 2. According to witnesses armed men launched an explosive device from a moving vehicle with a grenade launcher. The attack left two cars completely charred and damaged some of the building's structures. 3. One man was wounded by shrapnel. ProQuest Search: La Reforma "Investigan la conexin entre juzgado y casino"6/4/111. Esiquio Martnez Hernndez, secretary of the "Juzgado Noveno de Distrito en Materia Administrativa del Distrito Federal" was arrested several days ago after it was revealed that on 10/10/07 he suspended the closing of a casino in Monterrey and then recieved 500,000 pesos 24 hrs. later in his HSBC account. 2. Over the past decade he depositied 9,847,412 pesos in cash from branches of 13 different banks. Of that 12% came from N.L. 3. He made 260 deposits of 8,174,428 pesos in one of his HSBC accounts and 18 bank deposits for a total of 1,228,170 pesos. 4. The suspension corresponds to legal protection (amparo) 1276/2007 issued for the Paradise Casino in Monterrey against an order to close it. 5. Federal deputy Ramn Salas Lpez warned that the casino was operating illegaly and he said he recieved an anonymous call that said the owners of Paradise launder money for a crime organization. 6. Other officials are suspected of helping these casinos. On 3/31/11 Ricardo Hiram Barbosa "juez tercero de distrito en materia administrativa del Cuarto Circuito" based in Monterrey was suspended temporarily. ProQuest Search: La Reforma "Apuestan a casino y ganan la muerte"4/17/051. Three men Jose Cruz Fuentes Gaona, Juan Daniel Favela and Luis Martin Moreno Rodriguez, who were working with some American investors to open up a casino in Monterrey were murdered at Los Arcos Restaurant on 4/14/05. 2. The Mexicans were propsing to two Americans, Alberto Jaureguiy and Cherie Carter-Scott through a Canadian that resided in Monterrey, Luc Pelchat, to create a casino in Monterrey and put 70% down. 3. Then the three Mexicans were shot as they waited to meet up with them. Two of them had pending drug charges with the PGR and the DEA and another was involved in fraud. ProQuest Search: La Reforma "Congelan en NL a juez polmico"6/1/111. Ricardo Hiram Barbosa Alanis the "juez tercero de distrito en materia administrativa del Cuarto Circuito" was suspended six months for corruption. 2. His latest crime was calling off the closure orders for the Sport-Zone Casino in 03/11 which was fined for not renewing it's restaurant-bar license. 3. Depending on how the review goes he may or may not return to work as a judge or even end up in jail. 4. Already controversial the judge has been cited for a number of crimes: in 05/11 he granted legal protection to the ex-mayor of Santa Catarina Dionisio Herrera who had been charged with corruption in 09 and obtaining legal protection for casinos like Poker City Live and Revolucion as well as nightclubs like AM, George, Classic and Havana. ProQuest Search: La Reforma "Pierde Segob ante casinos" and "Detectan en Mxico 120 casinos 'ilegales'"6/19/101. Tourists from the US have increasingly driven demand for new casinos. 2. There are 425 legal gaming facilities in Mexico. Currently 173 casinos, 151 gaming rooms, 2 horse racing tracks, 2 ball courts and 2 dog racing tracks are about to open. 3. A KPMG report titled "Juegos en Lnea: una Apuesta al Azar o una Apuesta Segura" estimates that the gambling industry in Mexico is worth $4.3 billion. 4. Alfonso Prez Lizaur, the president of the "Asociacin de Permisionarios de Juegos y Sorteos" said that 120 illegal casinos, many of which launder money and have ties to drug cartels, exist in Mexico. 5. 9 out of every 10 illegal casinos are in Sonora, Coahuila, Chihuahua, Nuevo Len, Tamaulipas, Monterrey, Torren, Reynosa and Ciudad Jurez. 6. 8 out of the 25 authorized companies have Jorge Hank Rhon, the e- mayor of Tijuana, as an investor. 7. 82 out of the 213 remote betting centers count him as an investor. 8. 79 out 0f 201 gaming rooms(salas de sorteos numeros) have economic ties to him. ProQuest Search: La Reforma "Perfila la SCT a ex Alcalde polmico en NL"1/30/101. Zeferino Salgado, the ex-mayor of San Nicolas, NL and a PAN official is being questioned for corruption and even accepting a helicopter from the "zar of the casinos" Juan Jos Rojas. ProQuest Search: La Reforma "PLAZA PBLICA / Casinos ilegales y evasores"9/24/091. A list of 39 illegal casinos was submitted in the hall of deputies. 2. 9 of those were located in NL. Emerging Markets Information Service Search: Milenio Monterrey "Mauricio denuncia que ha recibido amenazas " and "San nicols y guadalupe rechazan tener problemas con magistrado "6/16/111. Mauricio Fernndez, the mayor of San Pedro, a suburb of Monterrey, said she received threats from judge Hiram Barbosa and lawyers of Casino Alegre, which is owned by Atracciones y Emociones Vallarta. 2. He claims that the casino recieved legal protection from Barbosa as well as state magistrate Jos Alfonso Sols Navarro even though it is less than 120 meters from a school which violates Mexican law. 3. Nevertheless, the town councillor (edil) of San Nicols Carlos de la Fuente, and the mayor of Guadalupe Ivonne lvarez, two other suburbs of Monterrey, deny having any problems with Alfonso Solis. 4. An official from Carlos de la Fuente said that there are only two casinos, which were granted permits in 2005 and 2009 in his jurisdiction and that both operate lawfully. He also said that the city doesn't plan on allowing more. 5. The mayor of Guadalupe says that she has had no problems with Alfonso Solis but also that no casinos belonging to Atracciones y Emociones Vallarta operate there. Emerging Markets Information Service Search: Milenio Monterrey "Secretara de gobernacin es sorda y ciega: larrazbal "6/16/111. In Monterrey there are 12 casinos: 3 from the previous administration and 9 from the new one, that operate without any permission from the city-council due to complacency among federal authorities and judges. 2. The mayor Fernando Larrazabal blames the Secretara de Gobernacin because it is "blind and deaf" and takes authority away from the municipality while blindly granting permits to these casinos. Emerging Markets Information Service Search: Milenio Monterrey "Monterrey, la capital del juego"6/15/111. According to the most recent count there are 50 casinos in NL, 31 of which operate outside of the law. 2. Carlos Fonseca, an expert on the subject, says that Monterrey has around 800 machines bringing in $120,000 daily.