Path To Justice

Chapter Four

Nick Drummond sat at his government-issued, pressed sawdust desk, and looked over at the ugly set of metal file cabinets, brim full with cases and money laundering materials. Most of the other prosecutors, generally quite a bit younger, had their working files in electronic form, stored in their computers. Nick preferred to call himself a tech dinosaur, not a technophobe. He liked the feel of paper, going back and forth through materials the old-fashioned way, making comments on the side of pages. Also, he didn’t have the patience to learn how to use the computer well. Fortunately, he had Rona Delphi, a fantastic paralegal, who handled computer document organization. Rona was worth her weight in gold, and was “the one who must be obeyed” as to case administration. Nick always told the brand new, often too-full of themselves prosecutors, “There’s only one person you have to keep completely happy in this office, Rona.”

Nick had scheduled a Money Laundering Task Force meeting in the conference room. Nick was no longer housed at the downtown San Diego AG’s Office, but was now off-site with the rest of the Money Laundering Task Force in a nondescript warehouse in north-central San Diego. Nick had brought his security blankets with him, Rona and his longtime secretary, Abbie Chivas.

Nick had been chosen to lead the task force because of his many years of prosecuting complex crimes and heading up the California Attorney General’s Money Laundering Program. Now, Nick was frustrated. The Money Laundering Task Force had been up and running for six months. There were some solid leads, but it was becoming apparent that it was extremely difficult to tie Mexican drug cartels to the flood of U.S. dollars going back and forth across the border. The meeting would update the status on the more promising, incipient investigations.

Everyone wandered into the conference room by 11:05. Several dragged along coffee cups with their investigation notebooks. A couple were affixed to their iPhones. Nick had thought about banning phones from the meetings. He decided against it when he had to admit it was useful when one of the techies checked on something, in an internet flash, during the meetings.

“Okay guys, let’s go through the ‘to do’ list generated from the last meeting,” Nick said in his command voice. “Pepe, let’s start with you.”

California Department of Justice Special Agent Pepe Cantana was a get-it-done type of guy. He had grown up on both sides of the border. He had a large family; some still lived in Mexico, while the others lived in the El Centro area of Imperial County, about a 100 mile drive from San Diego. Pepe started with the El Centro PD, then moved on to California DOJ where he was eventually assigned to the liaison division, working with Mexican officials on extradition and child abduction cases. He had numerous law enforcement contacts on both sides of the border.

Pepe reported, “As you know, we have been looking at Hector Morales and his two, so-called legitimate businesses, L&M Freight and Recycle Yard, for five months. The Bank Secrecy Act (BSA) currency reporting documents show three million dollars per month, in cash, being deposited in eight California-based bank accounts along the border with Mexico. These accounts are either in Hector’s name, his wife’s name, or one of the two companies. Different couriers are bringing in cash in backpacks, in amounts of $75k to $100k, for deposit in these accounts. The various banks are filling out the BSA required forms. We have compiled a spread sheet, showing each deposit, and the totals for each month.”

Banks file Currency Transaction Reports (CTRs) for cash deposits or withdrawals over $10,000 with the Internal Revenue Service.

“Have you checked out his businesses?” asked Nick.

“They are incorporated in California and have fictitious business name statements filed with the county clerk. The corporate papers list Lester Sendow as their agent for service of process, with a San Diego address.”

Detective Mario Cipriani of the San Diego County Sheriff’s Office added, “We visually checked out the two business addresses and surveilled our buddy Hector a few times over the last week. There’s no way that either business or both together are generating three million in cash a month. There are a couple of old trucks in the lot behind an empty warehouse that has a sign, L&M Freight. And the recycling business looks like a junkyard, with an old codger in a booth reading a newspaper. On two of the surveillances, Hector visited a few of the banks, and on the third day he went to his recycle business for an hour. He isn’t burning the midnight oil working. He spends most of his time holed up in his five-acre spread in Rancho Santa Fe. He has big name golfers and entertainers as neighbors.” “Sounds promising Mario and Pepe, but we still need to tie all this cash flow to drug trafficking or another felony,” said Nick.

“As if we don’t know that Nick,” retorted Pepe, “We’re working on it.”

“We can get federal tax returns on the two companies and individual returns on Hector and his wife from the IRS,” offered Homeland Security Investigations Agent Jerry Slater.

“Good Jerry, let’s do that. We’re going to need a complete financial profile on Hector and his companies,” replied Nick.

Pepe said, “There’s also a business address for L&M Freight in Tijuana. I can use my contacts to get the Baja Norte State Police to check out the address. Depending on what the policia de estado tell us, I can follow up, and go across the border to sit in on any interviews conducted by the policia.”

“Bueno! Vaya con Dios, Pepe.”

“Nick, I won’t do anything if you keep using your mangled Spanish on me. Just because I was born in Mexico, it doesn’t mean I have to be subject to your fifth grade Spanish.”

“Pepe, give an ugly American gringo a break,”

“Ugly,” retorted Pepe, “I can live with.”

Immigration and Customs Enforcement Agent Ana Schwartz suggested, “We could put GPS trackers on the undercarriages of Hector’s high rolling cars, his Benz and Range Rover.”

Assistant U.S. Attorney Josh Sterling spoke up, “With the recent U.S. Supreme Court case, U.S v. Jones, we have to be careful about secreting a tracker on a car without a warrant. We can place a tracker on a vehicle at the border if we have reasonable suspicion of criminal activity.”

“Let’s wait until we establish more cause before we start slapping on trackers right and left.” Nick continued, “Good work on the

Morales case, keep digging! Next?”

Jerry responded, “There’s the Sakia trade-based money laundering case. It’s one of those we could be looking into for years and still not come up with enough proof to make a case.”

Nick said, “We don’t have years. The higher ups are looking for something to talk about as soon as possible. You know how the state AG likes favorable media coverage.”

“Those politicians are all the same, they don’t care about what’s going on in the trenches, just how it makes them look on the six o’clock news,” growled Jerry, with a disgusted look.

“You’re preaching to the choir. But this task force depends on the ‘benevolence’ of those politicians,” said Nick.

Jerry continued, “Mr. and Mrs. Sakia have an import-export food business, called Latin America Productos, which mainly imports beef and other foodstuffs from Mexico and Argentina. They were born in Argentina and still have family ties in Buenos Aires. They have an office in Chula Vista, located halfway between the border and downtown San Diego. The business has been filing income tax returns and everything looked on the ‘up an up’ until the fall of 2012 when the married couple and their agents started declaring large amounts of U.S. cash as they crossed into California from Tijuana.”

In 2012, Mexico passed its Anti-Money Laundering Law (MAMLL), which severely restricts dollar cash deposits into Mexican financial institutions. Under MAMLL, drug cartels and others could no longer deposit U.S. cash into Mexican banks. They had to find other ways to get the cash dollars into the Mexican banking system.

Ana added, “We went through the international financial unit organization, EDMONT, and obtained export documents from Argentina and Mexico. We compared them with our U.S. Customs trade documents for the last ten years. Up until late 2012, the company appeared legitimate, importing foodstuffs into the Los Angeles Port of Entry and then brokering the food to other places in the the U.S. and Canada. The tax returns, both corporate and individual, lined up with expected income and expenses for a legitimate business. This all changed in late 2012, when all, but a few of the imports stopped, and huge amounts of cash began coming across the border.”

Jerry said, “It’s not unusual for legitimate trade businesses to become compromised by the drug cartels and allow their businesses to act as fronts for the laundering of drug dollars.”

“Unfortunately,” lamented AUSA Sterling, “Where there are corrupt businesses that were legitimate, and portions of their business are still legitimate, it’s much more difficult to get a jury to buy off on money laundering.”

“Exactly how are they moving the money?” asked Nick.

Ana answered, “The couple and their agents are declaring around $200,000 per northbound border crossing on Currency Monetary Instrument Reports(CMIRs). The forms state that the money originates from their business, World Food Imports, located on Avenida Revolucion, Tijuana. For the last few months, they have been transporting $2.5 million a month, and then depositing the same into 10 accounts in four banks, located just across the border. The cash is declared on CTR forms, and immediately wired to the same Mexican bank account.”

It’s not illegal, in itself, to bring $200K or any large amount of cash across the border as long as the cash is declared at the border on the CMIR form.

Jerry said, “We’re also getting in Suspicious Activity Reports

(SARs) from some of the banks.”

SARs are required to be filed by U.S.-based financial institutions when a transaction, or series of transactions, deviate from the norm of legitimate financial practices to the extent it raises a suspicion of criminal activity. Banks are trained by the government as to what transactions constitute “suspicious activities”. A section of the form allows an institution to specify exactly what aspects of the transactions are deemed suspicious.

Jerry continued, “One SAR sets forth Anthony Sakia’s explanation as to why he was bringing so much cash from Mexico and then wire transferring it back to Mexico. He told the bank official, ‘Our company trades food in Mexico, and the Mexican purchasers pay for the food in cash pesos, which we then exchange into U.S. Dollars at Mexican exchange houses (casas de cambio). We then have to bring the cash dollars across the border because Mexican regulations don’t allow the deposit of cash dollars into Mexican banks. We then deposit the cash dollars into our accounts in California, and wire the dollars to our food suppliers. The suppliers want to be paid in U.S. dollars because of the historic fluctuations in the dollar-peso exchange rates.’”

“Wow!” exclaimed Pepe, “You have to have majored in economics to try to figure all that out.”

“All right, this case could be an incredible resource drain where we end up with no prosecution,” said Nick. “We need to do the following investigative steps, then re-evaluate. We must refute the Sakias’ only defense, a legitimate import-export trade business. Go through all relevant federal databases, the internet, and state filings as to their business and to them as a married couple and as individuals. Also check on their key employees. Make sure to query the U. S. Customs TEC database for all border crossings by the couple, family members and key employees over the last ten years. This could show a pattern, or a contrast, in their border crossings over the years. Let’s surveil the Sakias from when they wake up until they go to bed. Pepe, I want you to use your contacts in Mexico to check out the Sakias’ business located on Avenida Revolucion. Finally, have the banks, under our supervision, segregate some of the future cash deposits and conceal the deposits in the vault. Then see if a drug sniffing dog can make positive alerts on the cash. Make sure the dog has the right credentials and that a positive alert signifies that the cash has come into recent contact with a controlled substance. The dog must be beyond ‘reproach’ because the courts are clamping down on allowing this type of evidence in trial. Once we get this information together, we can run it by an import business expert to see if the couple’s business practices are within an acceptable norm. Of course, we have to find an expert first, but I have some ideas on that.”

“Gee Nick, anything else? We should be able to get that done by the end of the day,” the sarcasm dripping from Jerry’s voice.

“I know it’s a lot of work, but to make these cases, we have to do it. We need to know if we can get enough information to support search warrants on the couple’s business office and their home.”

“One more thing, back on the Morales case. We should also segregate some of their new cash deposits and run it by our sensory-enhanced canine friends.”

“Nick, I knew I should have left the meeting after we finished talking about my case,” said Pepe.

“That will teach you to wait around for the extra donut before leaving. That’s why I bring them for you guys.”

“Are we exhausted yet?” asked Nick. “Only one more thing to discuss. Ana, your Saladez investigation which has ties to the Sakia money laundering operation.”

“In this one, we’ve a direct association with drug trafficking,” said Ana. “Two couriers, each with close to $80,000 in cash, were arrested at the border for not declaring the cash over the $10,000 threshold. Upon being questioned, they told customs officials that they received the cash from Numero Uno, a casa de cambio in Calexico, Mexico. Numero Uno is owned by Jorge Saladez, who has a U.S. record for marijuana and cocaine distribution. The couriers had written instructions on them to deposit the cash in a U.S. border bank on behalf of Anthony Sakia and then obtain cashier’s checks in the same amounts, payable to a Mexican bank account. The busts of the two couriers, eight months ago, must have inspired the Sakias to transport the cash in large amounts themselves, or through their own couriers. Also, we determined that the cashier’s checks were going to be payable to a Mexican bank account with Banco Real. The Mexican account holder is a high ranking Mexican government official, Armando Ruiz Castillo.”

Mario said, “I don’t want to sound like a dumb shit, but if these cases are about Mexican drug cartels running drug dollars through U.S. banks, why cross into Mexico with all the drug dollars to just courier them back across? Wouldn’t it make more sense to just deposit the cash in U.S. banks upon collecting the cash for drugs in the U.S., without bringing it back and forth across the border?”

Nick replied, “Good point. Nobody said drug dealers are the sharpest tools in the shed. This question has been kicked around and there are a couple of possible explanations. First, the cartel’s drug distribution and cash collection networks are usually set up to bring the cash back into Mexico. Because Mexico now prohibits the deposit of significant amounts of cash dollars directly into Mexican financial institutions, but allows dollars to be wired to Mexican banks or deposited via checks, the cartels have to get the cash dollars into U.S. banks so they can be transferred by wire or checks to Mexican banks.

“Some people in law enforcement believe the drug lords like to see and ‘feel’ the drug money in their own greedy, little hands before they launder it. Often, it’s only when the drug cash initially crosses the border into Mexico, that the money laundering side of the cartel kicks in. The money laundering operation is responsible for getting the money into Mexican banks. Once the cash dollars take their circuitous route back and forth across the border to reach their Mexican bank destination, the launderers can take additional steps to try to legitimize the money through off shore accounts or other front companies.

“Wake up, Pepe! That’s all for today. We’ll meet in two weeks, same place, same time.”

Path To Justice

Chapter Four

Nick Drummond sat at his government-issued, pressed sawdust desk, and looked over at the ugly set of metal file cabinets, brim full with cases and money laundering materials. Most of the other prosecutors, generally quite a bit younger, had their working files in electronic form, stored in their computers. Nick preferred to call himself a tech dinosaur, not a technophobe. He liked the feel of paper, going back and forth through materials the old-fashioned way, making comments on the side of pages. Also, he didn’t have the patience to learn how to use the computer well. Fortunately, he had Rona Delphi, a fantastic paralegal, who handled computer document organization. Rona was worth her weight in gold, and was “the one who must be obeyed” as to case administration. Nick always told the brand new, often too-full of themselves prosecutors, “There’s only one person you have to keep completely happy in this office, Rona.”

Nick had scheduled a Money Laundering Task Force meeting in the conference room. Nick was no longer housed at the downtown San Diego AG’s Office, but was now off-site with the rest of the Money Laundering Task Force in a nondescript warehouse in north-central San Diego. Nick had brought his security blankets with him, Rona and his longtime secretary, Abbie Chivas.

Nick had been chosen to lead the task force because of his many years of prosecuting complex crimes and heading up the California Attorney General’s Money Laundering Program. Now, Nick was frustrated. The Money Laundering Task Force had been up and running for six months. There were some solid leads, but it was becoming apparent that it was extremely difficult to tie Mexican drug cartels to the flood of U.S. dollars going back and forth across the border. The meeting would update the status on the more promising, incipient investigations.

Everyone wandered into the conference room by 11:05. Several dragged along coffee cups with their investigation notebooks. A couple were affixed to their iPhones. Nick had thought about banning phones from the meetings. He decided against it when he had to admit it was useful when one of the techies checked on something, in an internet flash, during the meetings.

“Okay guys, let’s go through the ‘to do’ list generated from the last meeting,” Nick said in his command voice. “Pepe, let’s start with you.”

California Department of Justice Special Agent Pepe Cantana was a get-it-done type of guy. He had grown up on both sides of the border. He had a large family; some still lived in Mexico, while the others lived in the El Centro area of Imperial County, about a 100 mile drive from San Diego. Pepe started with the El Centro PD, then moved on to California DOJ where he was eventually assigned to the liaison division, working with Mexican officials on extradition and child abduction cases. He had numerous law enforcement contacts on both sides of the border.

Pepe reported, “As you know, we have been looking at Hector Morales and his two, so-called legitimate businesses, L&M Freight and Recycle Yard, for five months. The Bank Secrecy Act (BSA) currency reporting documents show three million dollars per month, in cash, being deposited in eight California-based bank accounts along the border with Mexico. These accounts are either in Hector’s name, his wife’s name, or one of the two companies. Different couriers are bringing in cash in backpacks, in amounts of $75k to $100k, for deposit in these accounts. The various banks are filling out the BSA required forms. We have compiled a spread sheet, showing each deposit, and the totals for each month.”

Banks file Currency Transaction Reports (CTRs) for cash deposits or withdrawals over $10,000 with the Internal Revenue Service.

“Have you checked out his businesses?” asked Nick.

“They are incorporated in California and have fictitious business name statements filed with the county clerk. The corporate papers list Lester Sendow as their agent for service of process, with a San Diego address.”

Detective Mario Cipriani of the San Diego County Sheriff’s Office added, “We visually checked out the two business addresses and surveilled our buddy Hector a few times over the last week. There’s no way that either business or both together are generating three million in cash a month. There are a couple of old trucks in the lot behind an empty warehouse that has a sign, L&M Freight. And the recycling business looks like a junkyard, with an old codger in a booth reading a newspaper. On two of the surveillances, Hector visited a few of the banks, and on the third day he went to his recycle business for an hour. He isn’t burning the midnight oil working. He spends most of his time holed up in his five-acre spread in Rancho Santa Fe. He has big name golfers and entertainers as neighbors.” “Sounds promising Mario and Pepe, but we still need to tie all this cash flow to drug trafficking or another felony,” said Nick.

“As if we don’t know that Nick,” retorted Pepe, “We’re working on it.”

“We can get federal tax returns on the two companies and individual returns on Hector and his wife from the IRS,” offered Homeland Security Investigations Agent Jerry Slater.

“Good Jerry, let’s do that. We’re going to need a complete financial profile on Hector and his companies,” replied Nick.

Pepe said, “There’s also a business address for L&M Freight in Tijuana. I can use my contacts to get the Baja Norte State Police to check out the address. Depending on what the policia de estado tell us, I can follow up, and go across the border to sit in on any interviews conducted by the policia.”

“Bueno! Vaya con Dios, Pepe.”

“Nick, I won’t do anything if you keep using your mangled Spanish on me. Just because I was born in Mexico, it doesn’t mean I have to be subject to your fifth grade Spanish.”

“Pepe, give an ugly American gringo a break,”

“Ugly,” retorted Pepe, “I can live with.”

Immigration and Customs Enforcement Agent Ana Schwartz suggested, “We could put GPS trackers on the undercarriages of Hector’s high rolling cars, his Benz and Range Rover.”

Assistant U.S. Attorney Josh Sterling spoke up, “With the recent U.S. Supreme Court case, U.S v. Jones, we have to be careful about secreting a tracker on a car without a warrant. We can place a tracker on a vehicle at the border if we have reasonable suspicion of criminal activity.”

“Let’s wait until we establish more cause before we start slapping on trackers right and left.” Nick continued, “Good work on the

Morales case, keep digging! Next?”

Jerry responded, “There’s the Sakia trade-based money laundering case. It’s one of those we could be looking into for years and still not come up with enough proof to make a case.”

Nick said, “We don’t have years. The higher ups are looking for something to talk about as soon as possible. You know how the state AG likes favorable media coverage.”

“Those politicians are all the same, they don’t care about what’s going on in the trenches, just how it makes them look on the six o’clock news,” growled Jerry, with a disgusted look.

“You’re preaching to the choir. But this task force depends on the ‘benevolence’ of those politicians,” said Nick.

Jerry continued, “Mr. and Mrs. Sakia have an import-export food business, called Latin America Productos, which mainly imports beef and other foodstuffs from Mexico and Argentina. They were born in Argentina and still have family ties in Buenos Aires. They have an office in Chula Vista, located halfway between the border and downtown San Diego. The business has been filing income tax returns and everything looked on the ‘up an up’ until the fall of 2012 when the married couple and their agents started declaring large amounts of U.S. cash as they crossed into California from Tijuana.”

In 2012, Mexico passed its Anti-Money Laundering Law (MAMLL), which severely restricts dollar cash deposits into Mexican financial institutions. Under MAMLL, drug cartels and others could no longer deposit U.S. cash into Mexican banks. They had to find other ways to get the cash dollars into the Mexican banking system.

Ana added, “We went through the international financial unit organization, EDMONT, and obtained export documents from Argentina and Mexico. We compared them with our U.S. Customs trade documents for the last ten years. Up until late 2012, the company appeared legitimate, importing foodstuffs into the Los Angeles Port of Entry and then brokering the food to other places in the the U.S. and Canada. The tax returns, both corporate and individual, lined up with expected income and expenses for a legitimate business. This all changed in late 2012, when all, but a few of the imports stopped, and huge amounts of cash began coming across the border.”

Jerry said, “It’s not unusual for legitimate trade businesses to become compromised by the drug cartels and allow their businesses to act as fronts for the laundering of drug dollars.”

“Unfortunately,” lamented AUSA Sterling, “Where there are corrupt businesses that were legitimate, and portions of their business are still legitimate, it’s much more difficult to get a jury to buy off on money laundering.”

“Exactly how are they moving the money?” asked Nick.

Ana answered, “The couple and their agents are declaring around $200,000 per northbound border crossing on Currency Monetary Instrument Reports(CMIRs). The forms state that the money originates from their business, World Food Imports, located on Avenida Revolucion, Tijuana. For the last few months, they have been transporting $2.5 million a month, and then depositing the same into 10 accounts in four banks, located just across the border. The cash is declared on CTR forms, and immediately wired to the same Mexican bank account.”

It’s not illegal, in itself, to bring $200K or any large amount of cash across the border as long as the cash is declared at the border on the CMIR form.

Jerry said, “We’re also getting in Suspicious Activity Reports

(SARs) from some of the banks.”

SARs are required to be filed by U.S.-based financial institutions when a transaction, or series of transactions, deviate from the norm of legitimate financial practices to the extent it raises a suspicion of criminal activity. Banks are trained by the government as to what transactions constitute “suspicious activities”. A section of the form allows an institution to specify exactly what aspects of the transactions are deemed suspicious.

Jerry continued, “One SAR sets forth Anthony Sakia’s explanation as to why he was bringing so much cash from Mexico and then wire transferring it back to Mexico. He told the bank official, ‘Our company trades food in Mexico, and the Mexican purchasers pay for the food in cash pesos, which we then exchange into U.S. Dollars at Mexican exchange houses (casas de cambio). We then have to bring the cash dollars across the border because Mexican regulations don’t allow the deposit of cash dollars into Mexican banks. We then deposit the cash dollars into our accounts in California, and wire the dollars to our food suppliers. The suppliers want to be paid in U.S. dollars because of the historic fluctuations in the dollar-peso exchange rates.’”

“Wow!” exclaimed Pepe, “You have to have majored in economics to try to figure all that out.”

“All right, this case could be an incredible resource drain where we end up with no prosecution,” said Nick. “We need to do the following investigative steps, then re-evaluate. We must refute the Sakias’ only defense, a legitimate import-export trade business. Go through all relevant federal databases, the internet, and state filings as to their business and to them as a married couple and as individuals. Also check on their key employees. Make sure to query the U. S. Customs TEC database for all border crossings by the couple, family members and key employees over the last ten years. This could show a pattern, or a contrast, in their border crossings over the years. Let’s surveil the Sakias from when they wake up until they go to bed. Pepe, I want you to use your contacts in Mexico to check out the Sakias’ business located on Avenida Revolucion. Finally, have the banks, under our supervision, segregate some of the future cash deposits and conceal the deposits in the vault. Then see if a drug sniffing dog can make positive alerts on the cash. Make sure the dog has the right credentials and that a positive alert signifies that the cash has come into recent contact with a controlled substance. The dog must be beyond ‘reproach’ because the courts are clamping down on allowing this type of evidence in trial. Once we get this information together, we can run it by an import business expert to see if the couple’s business practices are within an acceptable norm. Of course, we have to find an expert first, but I have some ideas on that.”

“Gee Nick, anything else? We should be able to get that done by the end of the day,” the sarcasm dripping from Jerry’s voice.

“I know it’s a lot of work, but to make these cases, we have to do it. We need to know if we can get enough information to support search warrants on the couple’s business office and their home.”

“One more thing, back on the Morales case. We should also segregate some of their new cash deposits and run it by our sensory-enhanced canine friends.”

“Nick, I knew I should have left the meeting after we finished talking about my case,” said Pepe.

“That will teach you to wait around for the extra donut before leaving. That’s why I bring them for you guys.”

“Are we exhausted yet?” asked Nick. “Only one more thing to discuss. Ana, your Saladez investigation which has ties to the Sakia money laundering operation.”

“In this one, we’ve a direct association with drug trafficking,” said Ana. “Two couriers, each with close to $80,000 in cash, were arrested at the border for not declaring the cash over the $10,000 threshold. Upon being questioned, they told customs officials that they received the cash from Numero Uno, a casa de cambio in Calexico, Mexico. Numero Uno is owned by Jorge Saladez, who has a U.S. record for marijuana and cocaine distribution. The couriers had written instructions on them to deposit the cash in a U.S. border bank on behalf of Anthony Sakia and then obtain cashier’s checks in the same amounts, payable to a Mexican bank account. The busts of the two couriers, eight months ago, must have inspired the Sakias to transport the cash in large amounts themselves, or through their own couriers. Also, we determined that the cashier’s checks were going to be payable to a Mexican bank account with Banco Real. The Mexican account holder is a high ranking Mexican government official, Armando Ruiz Castillo.”

Mario said, “I don’t want to sound like a dumb shit, but if these cases are about Mexican drug cartels running drug dollars through U.S. banks, why cross into Mexico with all the drug dollars to just courier them back across? Wouldn’t it make more sense to just deposit the cash in U.S. banks upon collecting the cash for drugs in the U.S., without bringing it back and forth across the border?”

Nick replied, “Good point. Nobody said drug dealers are the sharpest tools in the shed. This question has been kicked around and there are a couple of possible explanations. First, the cartel’s drug distribution and cash collection networks are usually set up to bring the cash back into Mexico. Because Mexico now prohibits the deposit of significant amounts of cash dollars directly into Mexican financial institutions, but allows dollars to be wired to Mexican banks or deposited via checks, the cartels have to get the cash dollars into U.S. banks so they can be transferred by wire or checks to Mexican banks.

“Some people in law enforcement believe the drug lords like to see and ‘feel’ the drug money in their own greedy, little hands before they launder it. Often, it’s only when the drug cash initially crosses the border into Mexico, that the money laundering side of the cartel kicks in. The money laundering operation is responsible for getting the money into Mexican banks. Once the cash dollars take their circuitous route back and forth across the border to reach their Mexican bank destination, the launderers can take additional steps to try to legitimize the money through off shore accounts or other front companies.

“Wake up, Pepe! That’s all for today. We’ll meet in two weeks, same place, same time.”

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