Jed and Natalie Ladin, two South Florida gold importers, have been arrested* by Homeland Security Investigations (HSI), after they sent wire transfers, to two Guatemalan gold exporters, which totalled $17.8m more than the reported value of the gold. The overpayment, when coupled with an undervaluation of the gold, for Customs purposes, resulted in two counts being filed against the defendants:
(1) Money Laundering Conspiracy.
(2) Conspiracy to Smuggle Goods.
For the purposes of reference, the two Guatemalan exporters were Sarino SA and Montoro SA. Whether the defendants were engaged in the repatriation of narcotics profits cannot be learned from the court file to date. The Court denied the US Attorney's request for Pre-Trial Detention, and set a reasonable bond for the defendants.
Compliance officers should be aware that US law enforcement is actively looking for import/export firms involved in trade-based money laundering, and it is in your best interests to be alert for the numerous red flags of this activity. I suggest that you view the resource at International Trade Alert**, which offers a reasonably-priced software solution to ascertaining whether a client is engaged in trade-based money laundering. I am not affiliated with the company, but am familiar with its products, which are extremely useful in the real-time determination as to whether your client is engaging in this from of money laundering.
* US District Court, Southern District of Florida.