AML’s Road Trip

AML's Road Trip

“Location, location, location” has been a real estate mantra for as long as anyone can remember, but can location also hold the same significant value in anti-money laundering (AML) investigations? How relevant is your location to what you are doing? You may just find that geospatial data hold clues and evidence that merge very well with suspicious transactional behaviors.

Surveillance is an age-old proven and indispensable investigative technique. Whether for evidence or intelligence, following someone around or covertly watching someone is nearly always considered a universally accepted investigative tactic. Questions concerning where you were, and the alibis to prove you were somewhere else, are as old as crime itself. This, like so many other “old school” practices, has been revolutionized by the tech world.

The element the tech revolution brings to surveillance is no longer having to spend long hours, or even days, in cars or covert locations to obtain the same leads, information or evidence about someone’s whereabouts and activities. Whether by Global Positioning System (GPS), cell/smartphones, IP addresses, toll passes, license plate readers (LPRs), video surveillance systems, electronic ID cards, debit/credit card swipes, etc., knowing where someone is, or has been, is easier to determine than ever before. The remaining question is what, if any, relevance does that data have to an AML investigation.

Although money can move in both real space or cyberspace, people still move only in real space

Geographic considerations are already well embedded in standard Bank Secrecy Act/anti-money laundering (BSA/AML) alerts or analytics. Transactions outside of a geographic footprint or multiple branch activities are common red flags for potential suspicious activities. Travel to or from various “source” or sanctioned countries and areas can also be included in evaluations of suspicions. However, there are some more in-depth geographic profile considerations needing comparable analysis with the financial profiles when money laundering or other illicit activities are suspected. Oftentimes, following the money needs to become both figurative as well as literal.

Bob Dylan wrote and sang: “everyone has to be somewhere.” In AML investigations, we need to decide if that somewhere is indicative of something. Although money can move in both real space or cyberspace, people still move only in real space. The examples of “outside geographic footprint” or “multiple branches” obviously put location into investigative considerations; however, in absence of those indicators, exploring what—if any—other role locations play may yield unexpected leads or clues. This is especially true if properly compared and analyzed against financial data and its potential connection to illicit activities.

In one actual case, a “pin” map was used to better illustrate to jurors the nonsensical travel pattern the suspect used as he deposited cash at multiple institutions. This pattern had greater relevance in that it also contradicted statements and assertions the suspect had made to agents about his unusual banking habits. A tangled web he weaved without considering the potential of this impeachment by geospatial analysis. Geospatial analysis like this can enhance an investigation, but it rarely will be a stand-alone element.

Regardless of the criminal activity, putting geospatial considerations on the checklist of investigative steps may produce unexpected leads and possibly unconsidered evidence. Outlining multiple branch or “funnel” activities will be the very foundation of suspicious because of the added geospatial elements. In another case, a judge openly commented that nearly all of the other financial activities of the defendant might have a defensible explanation except for the multiple times this defendant visited multiple post offices on the same day to buy money orders. The judge could not imagine any legitimate reason to spend any more time at a post office than absolutely necessary. There was no reasonable doubt that repeatedly traveling to as many as five on the same day likely had nefarious motivations. No “pin” map was needed here. Unnecessary visits to places like post offices, DMVs and dentists, to name a few, is travel more often avoided than embraced.

A combined analytical evaluation of the two patterns (transaction and travel) can become an investigative lead

Our travel patterns normally are very linear. We tend to go from point A to B by the shortest or most convenient route available. Legitimate money movement normally follows similar linear patterns. Money is moved from point A to point B through the shortest or most convenient process to complete the intended commerce. BSA/AML monitoring programs rely on this for establishing baselines. Paycheck to paycheck, as well as to and from work, creates the norms from where variations can be identified, analyzed, evaluated or questioned. Overly complex transactional patterns, like overly complex travel patterns, can raise questions or suspicions. A combined analytical evaluation of the two patterns (transaction and travel) can become an investigative lead. Much of that location data is already available by simply taking a closer look at the available transactional data.

Debit or credit card swipes can be followed to flights, restaurants, bars, coffee shops, motels, hotels, convenience stores and that gas station on the “bad side of town.” They can also create other leads by identifying payments to toll passes or rapid transit passes. Repeated trips to specific locations can be indicative of potential personal interests, hobbies, hangouts or even the locations of illicit activities.

Scoundrels, especially those profitable enough to attract BSA/AML attention, will seriously consider locations that are conducive, as well as convenient, for their illicit activities, but yet less explainable for legitimate undertakings. Considerations may primarily include avoiding detection by law enforcement but there are also safety considerations from their illicit competitors and even their own customers that are just as important. Convenient access to stash houses and storage facilities are commonly used by those seeking places to secrete their contraband away from direct connections to their personal lives. Even lowly adulterers will seek out hotels or motels in locations where their respective spouses will least likely discover their dalliances; yet a closer evaluation of these locations will indicate that they are also too close to home to be rationally needed, or explainable, as necessary travel accommodations.

In another case, the illicit customer, and fellow conspirator, of a drug trafficker was able surreptitiously to attach a crude GPS device on his supplier’s vehicle. Although law enforcement would need a warrant for such tracking, there are no constitutional considerations between conspirators here. This “customer” was then able to discover a storage facility the supplier frequented. However, the device was not precise enough to determine the exact storage unit this supplier used. Late one night, this customer, with the aid of a couple associates, broke into several units in and around where they believed this supplier’s unit might be. They were clumsy and loud enough that someone called the police. These haphazard burglars found the right unit, along with the money and the drugs stashed inside at about the same time the police arrived. Of course, the supplier denied that he actually owned or “possessed” the illicit evidence this break-in exposed. Nevertheless, this incident added the context and reason for the suspicious financial activities that had been reported by this supplier’s financial institution.

The geospatial leads and information are far from confined case-specific investigations. It can also uncover trends, hot spots, or activities developing or concentrated to specific areas. The Washington Baltimore High Intensity Drug Trafficking Area has received accolades for developing its “O.D. Mapping” program that can, in real time, identify hot spots of overdose calls and activities. First responders can then be more rapidly and better deployed to areas of increased concerns and, hopefully, render aid in time to save lives. The question for BSA/AML is if identifiable corresponding financial activities for the dealers or “pushers” profiting from this destructive activity can be identified in the transactional data associated with these events. These dealers have to be somewhere and they have likely done something financial when they both obtained and dispersed their drugs. If BSA/AML helps better identify that activity, it can in fact become part of the “first responders” in this fight. The possibility of such “mapping” for AML or financial crimes certainly may be one of the destination points in the future of AML efforts.

Let’s hit the ground running.

Steve Gurdak, CAMS, supervisor, Washington Baltimore HIDTA, Northern Virginia
Financial Initiative (NVFI) Annandale, VA, USA,

Disclaimer: The views expressed are solely those of the author and are not meant to represent the opinions of the W/B HIDTA.

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