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Local Company Investment

As we see from history, investment into legitimate and illegitimate businesses is one of the key money laundering techniques. By adding raw cash into a business (assuming that it is a cash based business, like a laundry), it looks like it was genuinely earned revenue. This was the primary start for laundering, legitimate businesses that generate cash revenue can easily have funds injected into themselves, covering up the source of the funds. Local company establishment is the age old technique of simply starting some type of business which is cash based. I can simply add cash to the drawer of my business, and as long as it is nothing that is extravagant or copious, there will not be any type of investigation or trepidation as to the origin of the money.

This method is most common throughout drug syndicates. Multiple, smaller transactions in the drug trade will result in the accumulation of multiple small bills, which can be an issue when trying to push financial assets into a singular account.

Banks are restricted also with respect to multiple privacy laws. All banks that are in this nation are limited by The Banking Secrecy Act. This allows your bank to exempt you from filling out currency transaction reports (CTRs) if your deposits or withdrawals of currency fall into any of the following categories (see 31 C.F.R. 103.22(b)(2)(1992)):

1) They are made from an existing bank account, and you are an established U.S. depositor who operates a “retail type of business”. This means that you sell consumer goods for which payments are substantially in the form of currency, just as long as you are not an automobile, aircraft, or boat dealer.

2) They are made from an existing bank account, and you are an established U.S. depositor who operates a sports arena, race track, amusement park, restaurant, hotel, check cashing service licensed by state or local governments, vending machine company, theater, regularly scheduled passenger carrier, or public utility.

3) You are a local, state or United States governmental agency or instrumentality.

4) They are made from an existing bank account, and you are an established U.S. depositor who regularly withdraws more than $10,000 to pay your employees in currency.

The most talented launderers find a way to work within these laws so that the monies never even have to cross borders, reducing risk of any type of loss. However, to work within these limits also places a restriction on the methods and processes that a launderer can use.

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