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Operation Meltdown

Drug Proceeds

Gold Company U.S.
Drug Traffickers Gold Supplier

Money Broker-U.S.
Smugglec / Courier
Shipment of
Drugs to U.S. Assopiate

Gold for Pesos
U.S. Dollars/Pesos Colombian Gold
Colombian Colombian BMPE Company/Refinery
Drug Cartel BROKER

In or about January 1999, the El Dorado Task Force (LEA's from ICE and IRS) began
investigating certain narcotics traffickers that were laundering cash proceeds by
converting the cash into gold and then smuggling the gold to South and Central America.
According to information developed as a result of the investigation, Colombian narcotics
traffickers had large amounts of cash narcotics proceeds in the New York area that needed
to be repatriated to Colombia for payment for additional narcotics and to capture the
profits of their sales. Thus, these traffickers desired to launder the cash to Colombia, and
ultimately convert the U.S. dollars into pesos in Colombia. Some of these traffickers
achieved this goal by using the services of "money brokers" in the New York area.

One of the methods used by these money brokers to launder the money to Colombia was to
convert the cash into gold. Using this method, the money brokers employed couriers to
pick up cash at designated locations and deliver the cash to designated gold and precious
metal suppliers. The suppliers then provided gold to the couriers in exchange for the cash.
In some cases, the gold suppliers molded the gold into common items, such as tools, belt
buckles, screws and bolts, or other types of hardware, to make the gold less likely to be
detected by Customs inspectors as it was taken out of the country. The gold was then
smuggled to Colombia, either by couriers or in cargo. Once the gold arrived in Colombia,
it was sold to gold refiners for Colombian pesos, which were then delivered to money
brokers and, ultimately, to the narcotics traffickers.
WITH DRAWAL NOTICE

RG: 148
Box: 00001 Folder: 0002 Document: 6
Series: Team 4 Files

Copies: 1 Pages: 2

ACCESS RESTRICTED

The item identified below has been withdrawn from this file:

Folder Title: FinCEN Matters (2 of 2)
Document Date:
Document Type: Talking Points/Briefing Paper
Special Media:
From:
To:

Subject: Treasury response to question re: international fi
nance investigations

In the review of this file this item was removed because access to it is
restricted. Restrictions on records in the National Archives are stated in
general and specific record group restriction statements which are available
for examination.

NND:401
Withdrawn: 10-01-2008 by:

RETRIEVAL #: 401 00001 0002 6
System DocID: 4710
Q&A: FinCen - Patterns of terrorist financing

Q. What patterns of terrorist financing are we seeing—with respect to charities
and hawalas in particular?

(A detailed description of patterns of terrorist financial activity is provided separately).

A. Reconstruction of financial activities linked to the September 11 hijackers, along with
ongoing law enforcement investigations of terrorist financing, indicate that terrorist
financiers are adept at moving funds in ways that that do not trigger automatic reports or
suspicious activity reports in the U.S. or elsewhere; using international funds transfer
systems and associated correspondent banking relationships to hide larger
transactions; routing transactions through non-cooperative jurisdictions to reduce the
risk of exposure to regulatory or law enforcement scrutiny; using ATMs to facilitate
access to cash and reduce personal contact with bank staff; and using non-traditional
money movement systems, such as hawala, in some parts of the world to avoid
traditional banking channels altogether. These patterns are not indicative of terrorist
financial activity per se, and in fact involve methods that have been available to, and
used by, organized crime and drug traffickers for decades. The use of charities to
facilitate the movement of terrorist funds, which has been documented by law
enforcement following the events of September 11, requires further research to
determine the extent to which charitable organizations have been used, wittingly or
unwittingly, as links in the terrorist financing chain. Although hawalas have not been
linked to terrorist financing in the U.S., they are known by law enforcement to have been
used in some parts of the world to move terrorist funds. They are problematic because
they operate outside the regulated financial industry and offer a high degree of secrecy
and lack of record keeping. As required by the Patriot Act, Treasury will provide a
comprehensive report to Congress in October 2002 on the implications of hawalas and
related alternate remittance systems in terrorist financing.
DEPARTMENT OF THE T R E A S U R Y
FINANCIAL CRIMES ENFORCEMENT NETWORK

AUB 7 2002

MEMORANDUM FOR EDWARD HNGMAN
ASSISTANT SECRETARY (MANAGEMENT)

THROUGH: JIMMY GURULE*
UNDERSECRET

FROM: James F.
Director

SUBJECT: Proposed Reorganization of FinCEN

Created in 1990, the Financial Crimes Enforcement Network (FinCEN) has served as the
national central clearinghouse for broad-based intelligence and information sharing
relative to money laundering, terrorist financing, and other financial crimes. Starting as
an assembly of highly skilled financial analysts and information technology experts,
FinCEN's role in those areas was significantly expanded by virtue of several
Congressional and Departmental determinations and mandates. Included among them
was the designation of FinCEN as administrator of the Bank Secrecy Act (BSA) in 1994,
as well as FinCEN's elevation to bureau status following the enactment of the USA
PATRIOT ACT in 2001.

FinCEN continues to support the law enforcement, intelligence, regulatory, and
international efforts against financial crime; and to provide U,S; policymakers with
strategic analyses of domestic and worldwide money laundering developments, trends,
and patterns, It works toward those ends through information collection, analysis and
sharing as well as technological assistance and innovative, cost-effective implementation
of the BSA and other Treasury authorities.

Also, during the past three years and in parallel to the increased responsibilities,
FinCEN's human resources have increased significantly. At present, 216 permanent
employees are on board and we anticipate a total of approximately 240 by December
2002, Our workforce is supplemented by approximately eleven dctailees from other
agencies as well as approximately one hundred eighteen contract employees supporting
our mission.

Because of these increased responsibilities coupled with the corresponding resource
requirements, it has become necessary for FinCEN to organizationally restructure in
order to effectively and efficiently continue to fulfill its mission.
Financial Crimes Enforcement Network
Special Assistant to
the Director -
EEO / Diversity
Liaison to the Director Stephanie Holder
Treasury Department SES (703) 905-3741
Germaine Perambo James Sloan
(202)622-1429 (703) 905-3591 Chief Counsel
SES *
Judith Starr
(703) 905-3534
* Reports to Treasury G,C.

Deputy Director Deputy Director
operations Administration
SES SES —I International
Mike Rosenberg Bill Baity Coordination Group
(703) 905-3840 (703) 905-3593 L ncG]
(ICG)
Mary Sue Hafner
Office of Regulatory (703)905-3881
- AD OIV - AD OOM
Programs (ORP)
SES Mike Orndorff (703) 905-3528 Nicholas Procaccini (703) 905-3840
Dave Vogt - ADOSA I- ADOCM
(202)354-6416 Dave Gilles (703) 905-3574 Jane Fisher (703) 905-3708
- AD OOI L AD OH
Judy Knez (703) 905-3549 Ernile Beshai (703) 905-3597

Approved: 8 September 2003
, Sloan Date
Office of Investigative Support International Case Statistics

Time Incoming Requests Outgoing Totals
Increment (Foreign/DOJ- Referrals
OIA)

2000 (Jan-Jun) 102 17 119
2000 (Jul-Dec) 150 26 176
2000 TOTAL 252 43 295

2001 (Jan-Jun) 148 33 181
2001 (Jul-Dec) 233 - 148 381
2001 TOTAL 381 181 562

2002 (Jan-Jun) 248 - 256 504
2002 (Jul-Dec) 239 51 . 290
2002 TOTAL 487 307 794

2003 (Jan- June) 342 116 458
2003 (July-Nov) 220 80 300

Increased caseload from 2000 to 2002:

Incoming requests 193 %
Outgoing referrals 714%
Total cases 270%
Office of Investigative Support International Case Statistics

Time Incoming Requests Outgoing Totals
Increment (Foreign/DOJ-OIA) Referrals

2000 (Jan-Jun) 102 17 119
2000 (Jul-Dec) 150 26 176
2000 TOTAL 252 43 295
2001 (Jan-Jun) 148 33 181
2001 (Jul-Dec) 233 148 381
2001 TOTAL 381 181 562
Terrorist
Financing 2001 12 111 123 123

2002 (Jan-Jun) 248 256 504
2002 (Jul-Dec) 239 51 290
2002 TOTAL 487 307 794
Terrorist
Financing 2002 38 226 264 264

2003 (Jan- June) 342 116 458
2003 (July-Nov) 220 80 300
Terrorist
Financing
Jan to 35 10 45 45
Nov 2003
TOTAL
TERRORIST
FINANCING 432

Increased caseload from 2000 to 2002:

Incoming requests 193%
Outgoing referrals 714%
Total cases 270%

Statistics are as of November 4, 2003
Analytical System for Investigative Support
Doing the Hard Things... That Matter

The Financial Crimes Enforcement Network was established to combat Money Laundering
crimes. Typically, these types of investigations are conducted over a substantial period of time (years in
most cases) and are associated with voluminous amounts of documentation obtained from various sources.
By their very nature, these investigations are extremely difficult to manage and are even harder to be
presented in a manner that is understandable and successful for prosecution.

ASIS Description: The Analytical System for Investigative Support (ASIS) has as its core an investigative
support "shell" database designed and developed in Microsoft Access. Current versions of the database
support both Access 97 and Access 2000. ASIS provides a means to capture, store, and maintain large
amounts of data that is relevant to a specific money laundering or financial crime investigation or project.
The system includes four basic tables (Subject, Address, Number, and Activity), with associated forms,
queries, and reports. The user that is knowledgeable in "Access" can easily modify or create any queries,
reports and/or forms. The system has been designed and developed as a PC application that is easy to use
and offers maximum flexibility. ASIS eliminates the conflicts that are associated with the user's need for
both flexibility and for a defined structure. It also allows data to be exchanged or ported from one location
to another without redundant data input, which saves an enormous amount of time, resources, and/or data
entry error. The data is input into the database one time; and can be used many times, by different people.
with various analytical tools, in support of that specific investigation. ASIS was designed and developed
at FinCEN with enhancements provided by various federal law enforcement personnel.

The Analytical Systems for Investigative Support (ASIS 2000*00}
Control Center and Subject Information
11/24/02 7:3SAM: aozeaataag •' O«Dt or trie T r e a s u r y Now Delni ; Page
11/23/02 SAT 22:09 FAI 2026221829 . US TREASURY DEPARTMENT 01008
Secnon for Options Forttoho ^

jon! Financial Crimes Enforcement Network (FinCEN)

Organization's Mission Statement:

The mission of FinCEN is to support law enforcement investigative efforts and foster
interagency and global cooperation against domestic and international financial crimes
and to provide U.S. policymakers with strategic analyses of domestic and worldwide
money laundering developments, trends, and patterns. FinCEN works toward those ends
througb information collection, analysis, and sharing, is well as technological assistance
and innovative, cost-effective implementation of the Bank Secrecy Act (BSA) and other
Treasury authorities.

Overview of Oryanteation's Maior Goals & Objectives:

FinCEN's activities support Treasury's strategic goal to "Combat Money Laundering and
Other Financial Crimes" as well as Treasury's top priorities—the fight against terrorist
financing and money laundering. The bureau's strategic objectives include:

- Support the Financial Aspects of Investigation* by providing quality and timely
investigative support, as well as networking to its customers in the fight against
money laundering, terrorist financing, and other financial crimes.

- Identify financial Crime Trends and Patterns for law enforcement, regulators,
and financial institutions by applying strategic analysis techniques to an array of data
collected pursuant to the BSA, obtained through commercially available sources, or
received by law enforcement.

- Foster International Cooperation by promoting global cooperation through
encouraging and supporting other countries to establish financial intelligence units,
and strengthening the mechanisms to facilitate the exchange of information.

- Administer the BSA Effectively in partnership with the financial services industry,
the financial regulatory agencies, and the law enforcement community in order to
support the prevention and detection of money laundering, terrorist financing, and
other financial crimes.

- Strengthen Management Support by building efficient and effective management
processes and administrative support to accomplish FinCEN's mission.

Overview of Organization's Programs and Activities:
FinCEN supports law enforcement investigative efforts and fosters interagency and
global cooperation agabst domestic and international financial crime. FinCEN also
provides U.S. policymakers with strategic analysis of domestic ind worldwide money
laundering developments, trends, and patterns. FinCEN works toward these ends through
information collection, analysis, and sharing, as well as technological assistance, »nd

M/U/JD02

NCTA000066603
WITH DRAWAL NOTICE

RG: 148
Box: 00001 Folder: 0002 Document: 7
Series: Team 4 Files

Copies: 1 Pages: 9

ACCESS RESTRICTED

The item identified below has been withdrawn from this file:

Folder Title: FinCEN Matters (2 of 2)
Document Date:
Document Type: Summary
Special Media:
From:
To:

Subject: feedback from law enforcement customers of FinCEN
services

In the review of this file this item was removed because access to it is
restricted. Restrictions on records in the National Archives are stated in
general and specific record group restriction statements which are available
for examination.

NND:401
Withdrawn: 10-01-2008 by

RETRIEVAL #: 401 00001 0002 7
System DocID: 4711
SAR Bulletin
Information drawn from the Suspicious Activity Reporting System
January 2002 Issue 4

Aspects of Financial Taken individually, the indicators do not
necessarily equate to terrorist or other
Transactions Indicative criminal financial activity. Combinations of
indicators should raise the level of concern
of Terrorist Funding about potential terrorist financing or other
.cfiV/f1 criminal context. For example, references
This Bulletin is provided to alert to occupation or nationals of countries
financial institutions to financial transac- associated with terrorist activity as reported
tions and methods that could indicate in SARs should not, on their own, be taken
fundraising associated with various to indicate potential terrorist activity. But
criminal activities including terrorism. such indicators when part of the larger
grouping of indicators could add to the
?clous Aci This Bulletin provides synopses of suspicion of potential terrorist activity.
FinCEN's investigative support describ-
ing financial transactions that may be Case # 1
associated with criminal fundraising SAR reporting identified activity
I7OII5 activities. This information was derived involving multiple payments by check from
from Suspicious Activity Reports (SARs) a business account of approximately
and other Bank Secrecy Act (BSA) $420,000 to a securities brokerage in the
information filed by depository institu- U.S. The account was also used to wire
tions. Each case example is followed by transfer a total of $2.1 million into and out
a set of indicators of fundraising activity of business and personal accounts in a
that were extracted from the case. SAR Persian Gulf State. In addition, a Cur-
narratives were used extensively in the rency Transaction Report (CTR) was filed
development of these indicators. on a cash withdrawal of $ 11,000 from the
account by an individual with a foreign
The information provided in this passport. Two individuals with signature
Bulletin is intended to assist financial authority on the account were also
institutions in identifying transactions involved in two other businesses, both of
that may be linked to potential terrorist which are the subject of CTR filings for
financial activity. The indicators of such cash withdrawals totaling $43,000.
activity outlined in this Bulletin are
intended to augment existing systems The indicators and patterns of
and procedures used by financial activity described in the SARs that
institutions to identify suspicious or could be associated with funds collection
unusual activity that may be of interest and movement relating to terrorist
to law enforcement. financing include:

United States Department of the Treasury • Financial Crimes Enforcement Network
FINANCIAI CRIMI-.S ENFORCEMENT NF.TVVORK

Financial Crimes
Enforcement Network
(FinCEN)

2003-2008
Strategic Plan

September 30, 2003