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handbook, a compliance officer, and implementation of an anti-moneylaunderingtraining program for staff. These regulations put businesses’compliance on the same footing as banks and other financial institutions inthe United States.Remittances and the Informal Sector in Cuba:Cuban remittances occur predominantly in an informal context.The majority of Cubans choose to send remittances throughinformal mechanisms, particularly through mulas.Mulas are entrepreneurs – men and women, Cuban Americansand foreign nationals (Mexicans and Colombians among others) –who can and do travel with ease and frequency to the island. Theycarry both money and packages of goods to the sender’s relativesin Cuba for relatively inexpensive fees. They are known throughword of mouth, through the references of relatives, acquaintances,and friends who recommend them as “reliable” people to sendpackages of any kind.Mulas go to Cuba predominantly as tourists, as they are informalentrepreneurs without a license to operate as a business. However,they have a well-established network of contacts from Miamiresidents and businesses, to customs officials in Cuba, and to thedistributors of goods.306There is no single type of mula and their numbers may run into thethousands. Some mulas are salaried and employed by a particularentrepreneur who hires them to travel back and forth to Cuba.There are also mulas who are sole proprietors of their informalremittance businesses and who work with family networks in theUnited States and Cuba. Depending on the business size, some ofthese sole proprietorships have an informal financial infrastructurein Cuba, which they utilize to have their distribution operationsactive at any time. Carrying a significant pool of thousands ofdollars, and using a fax machine, these individuals transmitmessages to their Cuban counterparts with the coordinates of whereto deliver money and to whom. In other cases, the individualswho have less capital available travel with greater frequency andarrange the money to be delivered by their relatives. In general,regular mulas tend to travel to Cuba twice a month.