Excerpt from the SAR Activity Review
Illegal Casa de Cambio Launders More than $5 Million
In January 1999, the Financial Crimes Division (FCD) of the Texas Office of
Attorney General (OAG), initiated an investigation into money laundering allegations
based on information received from a Suspicious Activity Report (SAR)
filed by a Texas bank. This investigation centered on the operation of an illegal
casa de cambio in Dallas and Kaufman Counties, Texas. The subjects of the
investigation operated an illegal currency exchange business in violation of the
Texas Financial Code, a third degree felony.
Currency exchange and transmission businesses such as casas de cambio 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. Money orders
in U.S. dollars that are sent to other countries can be difficult to redeem. Many
currency exchange and transmission businesses are not licensed to conduct wire
transmissions, as is required in many states.
Texas OAG, FCD, researched Bank Secrecy Act (BSA) reports and located a total
of 115 Currency Transaction Reports (CTRs), 14 Reports of International Transportation
of Currency or Monetary Instruments (CMIRs), two Currency Transaction
Reports by Casino (CTRCs) and 11 SARs. The documents helped the
investigator by providing specific banking transactions and account information.
That information was added to search warrants to establish probable cause and
presented to a state grand jury.
The investigation concluded that money orders were received from various
senders across the U.S. at the home addresses or post office boxes of the subject.
The subject then deposited the money orders into one or more local bank accounts.
The banks were then instructed to wire transfer the funds to another out-of-
state bank. Information gathered through the use of search warrants determined
that from August 1998 through March 1999, banking activity by the casa
de cambio included deposits of $5,593,185 and wire transmissions of $5,122,460.