convergence

Threat Finance
donations that were intended by donors for legitimate activities may be diverted by charity
executives for criminal uses.
Cash Couriers/Bulk Cash Smuggling
Cash is king! Despite newer methods to move and hide money, the exchange of paper currency
is still regarded as the dominant and preferred mode of payment across the globe, especially
for transnational criminal organizations like drug cartels. Cash couriers and bulk cash smuggling
are an attractive mode of moving money and facilitating money laundering and terrorist
financing. It usually occurs in U.S. dollars and euros, which are widely accepted as international
currency and can always be converted. There is often no traceable paper trail and no third party
such as a bank official to become suspicious of the transaction, and the terrorist or criminal can
control the movement of that money. However, the costs of couriers and equipment, the risk
of the courier stealing the money, the risk of informants within the network, and losses due to
border searches or government inquiries that could compromise the network or mission are
omnipresent vulnerabilities in the transnational organized crime supply chain. Physically, too,
cash can be large, heavy, and difficult to conceal: 1 million dollar bills weigh just over 1 ton and
$1 million in $100 bills weighs about 22 pounds. 9
In the United States, bulk cash smuggling is a money-laundering and terrorism-financing
facilitation technique that is designed to bypass financial transparency reporting requirements.
10 Often, the currency is smuggled into or out of the United States concealed in personal
effects, secreted in shipping containers, or transported in bulk across the border via vehicle,
vessel, or aircraft. According to the Federal Bureau of Investigation (FBI), some of the 9/11
hijackers allegedly used bulk cash as one method to transfer funds. Furthermore, in response
to the 9/11 events, U.S. Customs initiated an outbound-currency operation, Operation Oasis,
to refocus its efforts to target 23 identified nations involved in money laundering. According
to the Department of Homeland Security’s (DHS) Immigration and Customs Enforcement,
between October 1, 2001, and August 8, 2003, Operation Oasis seized more than $28 million
in bulk cash. However, while some of the cases involved were linked to terrorism, Homeland
Security officials were unable to determine the precise number and the extent to which these
cases involved terrorist financing. Bulk cash smuggling across the porous borders of Iraq has
been used by al Qaeda in Iraq to finance foreign fighters. 11
According to the U.S. National Drug Intelligence Center (NDIC), bulk cash seizures in
the United States alone totaled $798 million from January 2008 through August 2010. These
seizures were mostly related to drug-trafficking cases involving Mexican-based transnational
criminal organizations. Demonstrating the size and significance of the bulk cash operations
related to the illicit drug trade, however, is the negligible effect that these seemingly large seizures
have had on stemming transnational criminal operations. NDIC stated in its National
Drug Assessment Report 2011 that “bulk cash interdiction efforts have not impacted overall
TCO operations to a significant extent.” 12 While U.S. counternarcotics strategies focus on
drug interdiction efforts, they now track proceeds from narcotics trafficking that empower
transnational criminal organizations to control global supply routes and corrupt government
authorities. As a result, U.S. agencies including the Drug Enforcement Administration
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