- [Narrator] This is Moyara Ruehsen.
She's a professor and the director of
the Financial Crime Intelligence Program
at the Middlebury Institute of International Studies.
- I've been teaching courses on money laundering
for more than 20 years.
- [Narrator] Today, Moyara is going to review
what Hollywood gets right and wrong
in money-laundering scenes.
[suspenseful music]
[siren blaring]
- Money laundering is a necessary step for most criminals,
especially if they have a lot of criminal revenue.
They need to clean it if they don't want
law enforcement to seize it,
and if they don't want the IRS
to come after them for tax evasion.
That's what money laundering is,
is the process of making dirty money clean.
First up, "Wolf of Wall Street."
In this scene, Jordan Belfort hires family members
and other associates to smuggle cash into Switzerland.
[energetic music]
- [Narrator] The next day, Aunt Emma flew to Geneva,
two million in cash in her carry-on,
which in the big picture was a drop in the Swiss bucket.
Because the following month,
over the course of six round trips,
Chantalle's family and friends smuggled in
over 20 million in cash without even a hiccup.
- This happened back in the 1990s, prior to 9/11.
I don't know if any of you remember what airport security
was like before 9/11, but it wasn't at all
anything like what we have today.
Maybe they would've been able to move that cash past TSA
without any questions asked, but technically,
by law, they still would've been required to fill out
documentation for any amount of cash over $10,000.
It's not against the law to move the cash.
You just have to report it.
- And I have some more. - Really?
- Here. - Oh, thank you.
- And here. - Welcome. [laughing]
- And yeah, like four bags of it.
- Are you Swiss Slovakian or Swiss Slovenian?
- What they do get right is once they get the cash
into Switzerland, in the early 1990s,
they probably would've been able to find a Swiss banker
who was willing to accept all of that cash
without any questions asked.
But in 1998, Switzerland toughened
its anti-money laundering laws.
And so that would not have happened after that date.
In fact, here's a little fun fact.
Between 1998 and the end of 2001,
when the new anti-money laundering provisions
of the USA Patriot Act went into effect,
Switzerland had tougher anti-money laundering laws
than the United States.
In fact, Switzerland is quite cooperative
with international law enforcement
when it comes to going after criminals.
Next up, "Ozark".
In this clip, Marty gives us a lesson
on the art of money-laundering.
- [Marty] Okay, money laundering 101.
Say you come across a suitcase
with five million bucks in it.
What would you buy?
A yacht, a mansion, a sports car?
Sorry, the IRS won't let you buy anything of value with it.
- Right off the bat here, we're talking about
how much cash can we actually it into a suitcase?
He mentions $5 million in a suitcase.
That would have to be a really big suitcase,
about 10 briefcases worth of cash,
and that's assuming that it's brand-new $100 bills.
But most cash that comes from drug sales
isn't going to be in the form of $100 bills.
It's gonna be in the form of 20s, 10s, 50s, you name it.
- [Marty] So you better get that money
into the banking system.
But here's the problem.
That dirty money?
It's too clean, looks like it
just came out of the bank vault.
You gotta age it up, crumple it, drag it through the dirt,
run it over with your car.
Anything to make it look like it's been around the block.
Next, you need a cash business.
Something pleasant.
You miss the five million with the cash
from the joyful business.
- What Marty is doing very effectively here
is setting up lots of businesses in which
he can commingle his cash.
So he has the strip club, he has the mortuary,
and he has the casino,
all of which are cash-intensive businesses.
That is exactly what a money launderer might try to do,
because you are disguising all that dirty cash
as revenue from your business.
Your very lucrative business.
- [Marty] That mixture goes from an American bank...
To a bank from any country
that doesn't have to listen to the IRS.
- The bank tanks that money, puts it into his account,
and at that point, he can move it wherever he likes.
He could use it for a variety of reasons, ostensibly,
but what he's really doing is having his bank
wire that money, ultimately, to another bank
in a foreign location, where the drug criminal,
in this case, now has complete access to the funds
and can even withdraw the cash from the ATM machine.
In my professional opinion, this is very realistic.
- [Marty] It's as legitimate as anybody else's.
- [Moyara] "The Sopranos".
- 9,900.
- In this clip, Carmela is depositing the money
that she stole from Tony in increments of $9,900.
- Interestingly, at $10,000, we're required by law
to notify the IRS of the transaction.
- Oh, really?
- This clip is a perfect example of structuring.
Structuring is when you're breaking down
a large amount of cash into smaller amounts
below that $10,000 threshold
in order to avoid filling out a currency transaction report.
The crime itself of structuring, technically,
even depositing $9,900 just once in order to
avoid that $10,000 reporting threshold,
politicians and grandmothers alike
have fallen into that trap.
- I want it in something safe, something old economy.
Maybe treasuries.
- If you'll notice from her notebook,
she's only making just the one deposit,
and she's doing it at multiple banks,
which is a smart move on her part
because the banks don't talk to each other,
and so they're not noticing a pattern.
If she were to make all of those deposits
of $9,900 all at the same bank,
it would definitely trigger a suspicious activity report
and she'd probably get caught.
Next up, "Breaking Bad".
- You know you need to launder your money, right?
Do you understand the basics of it,
placement, layering, integration?
- I ain't buying no damn nail salon, so just forget it.
- In this scene, Saul explains beautifully
two out of the three money laundering stages
and why one even needs to launder money in the first place.
- Well, you wanna stay out of jail, don't ya?
You wanna keep your money and your freedom?
'Cause I got three little letters for ya, I-R-S.
If they can get Capone, they can get you.
- I really like this scene.
In fact, I like it so much
that I actually show it in my classes to my students,
because they start off learning the first three
traditional stages of money laundering,
which is placement, where he's putting the dirty drug money
into the proceeds of the nail salon.
Layering he combines with the placement,
but layering is when you move the money around
just to muddy the money trail
and make it very difficult for law enforcement to follow it.
And then integration.
Once the money is clean enough that you can take it
and actually spend it.
- Here's you, right?
Pink, Pinkman, get it?
Okay, here's your cash.
You're out on the town, yeah, you're partying hearty
and knocking boots with the chicky babes,
and aw, who's this?
It's the tax man.
And he's looking at you.
Now, what does he see?
He sees a young fella with a big fancy house,
unlimited cash supply, and no job.
Now, what is the conclusion the tax man makes?
- I'm a drug dealer.
- [buzzing] Wrong, a million times worse.
You're a tax cheat.
What do they do?
They take every penny, and you go in the can
for felony tax evasion.
Ouch!
- The hardest stage for a money launderer is placement.
You need a reason for depositing
all that dirty cash in the first place.
It's not just that you're trying to ward off the IRS.
You also have to demonstrate that this money
was not illegally derived, and that's why you try to buy
these cash-intensive businesses where you can then
commingle the dirty cash.
Hence the nail salon.
- This is the nail salon, right?
I take your dirty money and I slip it
into the salon's nice clean cash flow.
- I also like how he shakes the Q-tips around.
What you're really doing is you're putting
some dirty Q-tips, putting them in there
and shuffling them around so that when
you finally take them all out, it looks clean.
But what you would really be doing,
if you are a sophisticated money launderer,
is you would probably be taking that cash
and then moving it between accounts,
using it for other purposes, and then finally,
after you've moved it around and
made it very difficult for law enforcement
to follow the money trail, only then would you
withdraw the cash and then spend it.
As I said, I really like this clip,
because he's talking about processes
just the way that we would talk about it
in the law enforcement setting.
Very realistic.
Next up, "Narcos".
- [Narrator] And that's what they tried first.
On paper, Pablo had the most profitable taxi company ever.
He only had three cars, but he was pulling in
more than $5 million in a week.
And Gacha had the most successful emerald mine of all time.
He would inject bad stones with oil to make them shiny,
and had his friends in Miami buy the emeralds
with drug money and give them as gifts
to hookers and talent.
Everybody was happy.
- For those of you who are familiar with the series,
it's based on the actual life of Pablo Escobar,
and it's very realistic.
Colombia is known to export emeralds,
and in this case what they're doing is taking
the bad, poor-quality gemstones that aren't worth anything,
polishing them up, making them look nice,
and then selling them as if they are real fancy emeralds.
So the drug traffickers in North America
are bringing dirty drug cash, then,
to pay for those high-quality emeralds.
That way, the jewelry store,
who's working in cahoots with the Medellin cartel,
can justify why they're paying $100,000
for an emerald which is really only worth $100.
And that's how they justify wiring the money
back to Colombia.
- First off, let's talk about how he got away
with spending that kind of money in the first place
without triggering any tripwires.
Well, he's not the one purchasing the Picassos
or, in fact, the exotic zoo that he had on his estate.
He's not doing that himself.
He has professional money launderers working on his behalf
who have laundered a lot of his money
and put it into offshore shell companies,
and it's those offshore shell companies
that are making those purchases,
whether it's property, whether it's the Picassos,
whether it's the yacht or the plane.
- He's bringing in so much cash
he doesn't know what to do with it.
There's so many boats, planes, luxury cars,
that one person can buy, so he's thinking,
"I'm gonna save this for a rainy day."
- Just like we see in the clip, in real life,
they actually packaged massive amounts of cash
into plastic containers, buried it underground.
What you don't know, however, is that years later,
when they went to retrieve that buried cash,
so much of it had rotted away.
This is not an uncommon problem to have.
A drug trafficker of his caliber,
many of them have faced this very same problem
of having so much cash they don't know what to do with it.
In fact, there was a money launderer in Mexico
whose home was raided by the police
where they found a very large room full
of stacks of cash in multiple currencies,
hundreds of millions of dollars, stacked up in one room.
It was just too much for one money launderer to handle.
Next up, "The Wire."
- We can come at this a few ways.
The first thing is,
we need the names of all the front companies.
Limited partnerships, LLCs, and all that nonsense.
- LLCs?
- Limited liability corporations.
Start with the nightclub which Barkdsale owns.
Look up Orlando's by address.
You match it, and you see it's owned by who?
- It's on Baltimore Street, right?
Got it, D&B Enterprises.
- Hand that over to Prez, who's gonna get off his ass
and walk on over to the state office buildings
on Preston Street.
- Preston Street?
- Corporate charter office. - Corporate who?
- [Lester] We have the paperwork on every corporation
and LLC license to do business in the state.
- What most launderers will do is set up front companies.
Now, these front companies could be shell companies,
but shell companies are not, by their very nature, illegal.
Most shell companies are actually set up legitimately
for legitimate purposes.
But if they are set up for illegitimate purposes,
to hide criminal activity,
that's when we call them a front company.
He's sending his assistants out to
the corporate registry offices to find more information
and look at the corporate registration documents,
and back in those days, it was a much more painstaking task,
because you had to go and look it up
on the microfiche or the microfilm.
- [Lester] Write down every name you see.
Corporate offices, shareholders, but more importantly,
the resident agent on the filing, who's usually a lawyer.
- You also wanna know who is the lawyer
or company incorporation agent who is
setting up that company in the first place,
because chances are they know who they're working for.
- [Lester] They'll usually use the same lawyer
to do the charter file.
Find that agent's name, run it through the computer,
find out what other corporations
he's done the filing for.
- I really like this clip,
because this is exactly how a smart investigation
will be run, and they all know that
if you really wanna find out who is behind it all,
you do have to follow the money.
- In this country, somebody's name
has got to be on a piece of paper.
A cousin, a girlfriend, a grandmother,
a lieutenant he can trust,
somebody's name is on a piece of paper.
- And if that information isn't
on the incorporation documents,
they can at least find out who the lawyer
or company incorporation agent is
who set up the front company in the first place.
- You follow drugs, you get drug addicts and drug dealers.
But you start to follow the money,
and you don't know where the [beep] it's gonna take you.
- "Shawshank Redemption".
In this clip, Andy explains how he is stealing
and moving money in an untraceable fashion,
by having created a fictional identity
under which he puts all of the accounts.
- I know you're good at it,
but all that paper leaves a trail.
Now, anybody gets curious, FBI, IRS, whatever,
it's gonna lead to somebody.
- Sure it is, but not to me.
And certainly not to the warden.
- All right, who?
- Randall Stevens.
- Who?
- A silent silent partner.
He's the guilty one, Your Honor,
the man with the bank accounts.
It's where the filtering process starts.
They trace anything, it's just gonna lead to him.
- But who is he?
- He's a phantom, an apparition.
A second cousin of Harvey the Rabbit.
I conjured him out of thin air.
He doesn't exist, except on paper.
- [Moyara] Andy is using a synthetic identity
in order to conduct the money laundering activity
that he's engaging in.
- You can't just make a person up!
- Well, sure you can, if you know how the system works,
where the cracks are.
It's amazing what you can accomplish by mail.
- Synthetic identities are something
that law enforcement is extremely concerned about,
because it is unfortunately not that difficult to create.
All you need to do is apply for a line of credit.
You'll be rejected, because they won't be able
to recognize any of the information that you're providing.
Then, simply by getting rejected in that loan application,
you have actually created a record.
And so now you exist.
- Mr. Stevens has a birth certificate,
driver's license, social security number.
- You're [beep]ing me.
- They ever trace any of those accounts,
they're gonna wind up tracing a figment of my imagination.
- Andy is being extremely clever here
by creating this false identity,
and thereby avoiding any attention from law enforcement.
- Well I'll be damned.
- To me, this clip is very realistic,
but pulling off all this sophisticated fraud
while he's actually in prison?
That would be a tough thing to do
without the help of a lawyer on the outside.
Once again, "Breaking Bad."
- Are you telling me you make $7,125,000 a year?
- Seven and a half even, before expenses.
- There's no car wash in the world
that could do this kind of business.
I mean, this is nine months' work here, minimum.
- She's right, you would need a lot of front businesses
besides just one car wash to clean $7 million a year.
If she were to deposit more than what would be reasonable
for a really well-performing car wash,
the bank would also notice,
because they would know what typical cash flow would be
for that size business, and they would be required by law
to fill out a suspicious activity report
with the Treasury Department.
- Seven million, that, that could take years.
- So set some aside, save it for a rainy day.
- Save it?
Save it where?
I can't go to the bank with it,
and I sure can't leave it here.
Oy.
Wait a minute.
Is this all 50s?
Who pays for a car wash with a 50?
- She also makes another great point
about the denomination of the bills.
They're all $50 bills.
Very strange, and I suspect that a lot of his cash
is probably not typically received
in the form of $50 bills, but in this scene it is,
and that's very weird.
Would you only be receiving $50 bills
from your customers at a car wash?
Most of us rarely use $50 bills.
Most people don't realize that our banks
are required by law to be spying
on our transactions from time to time,
and differentiate typical activity from suspicious activity.
So a bank has lots of cash-intensive businesses
as customers, and they know what a cash-intensive business
would typically do when they make deposits.
They would be depositing five, 10s, 20s, 50s, 100s.
If you're only depositing $50 bills,
that just by itself is a little odd,
and if you're depositing large amounts, even odder still.
They would most certainly file what's called
a suspicious activity report with the Treasury.
In fact, if a bank isn't regularly
reporting suspicious activity,
they'll get in trouble with the regulators and get fined.
- I didn't ask you to do this.
I was under the impression that you had this under control.
- I just didn't expect this amount of money.
The 50s are gonna be a problem.
- So she's actually right, in that they would need
multiple car washes or multiple cash-intensive businesses
in order to commingle that money without being detected.
A better example would be the chicken chain,
Pollos Hermanos, for any of you who are "Breaking Bad" fans.
That would be, perhaps, an easier way
to commingle and launder larger amounts of cash.
I'm guessing that a lot of you have, in your neighborhood,
at least one or more businesses
that do very little business,
and yet those businesses manage to survive
year after year after year.
You have to wonder, are they a front
for some kind of money laundering operation?
And again, "The Wire."
In this clip, Prop Joe is explaining
how they're gonna send money to the Caribbean
disguised as charitable contributions.
- [Joe] You see the pastor here?
He's one of about three I'd like to give money to,
to help with his good works and all that.
- Good works?
- Oh, he down with all kind of missionary work
going on down in the islands.
You know, building a church for some folk,
a schoolhouse for some other folks,
all kinda good [beep] like that.
And what else ya'll building?
- A hospital.
- A hospital, yeah.
Except they been building that mess for about 10 years now
and nothing actually get finished.
- This clip is pretty realistic.
We do know that charities are abused
by criminals for money laundering purposes.
You have charitable donations,
which is really dirty drug cash,
coming in disguised as charitable donations.
You deposit that into the bank account of the charity.
No one's gonna ask any questions,
because it's not unusual for charities
to receive cash donations.
Now the bank is wiring money offshore,
maybe to Haiti or somewhere else in the Caribbean,
where they are supposedly using the money
to do charitable deeds.
But as we heard, they're not really
doing those charitable deeds.
- We got accounts with some of the banks down there.
Donations come in as cash, cashier's checks come out.
- Tiny-ass Caribbean island don't truck with no subpoenas.
No court orders, none of that.
- You pay 10 on a dollar.
Anything beyond that depends on your generosity,
to save those who're gonna be saved.
- It's harder to launder your money
through a Caribbean bank today,
because most countries in the Caribbean
have really strengthened their anti-money laundering laws,
certainly in the last 10 to 15 years.
But charities are still being abused by money launderers.
Eventually, somebody might audit the charity
and ask to see whether or not those charitable activities
were actually carried out.
Unfortunately, this clip is realistic.
Next up, "Jack Ryan."
In this clip, Jack Ryan notices some suspicious activity
in the accounts of a Russian client
and asks his boss to send him over there.
- You wanna go to Moscow?
- I think we have to.
They're unnamed, uncategorized,
scattered all over the world.
They're hidden accounts, Rob.
These are just the ones I've managed to find.
- How did you find them?
- You pay me to look.
- Not to look that hard.
Joke.
You think they're ripping us off?
- I don't know what to think.
- Jesus H. Christ.
You're the compliance officer it's your call, but-
- First thing I notice is that the boss
is referring to him as "the compliance officer."
Would he actually make a trip all the way Moscow
to inquire about those accounts?
Unlikely, he'd probably pick up the phone
to make inquiries first.
But I do like this clip.
It's near and dear to my heart,
because I'm in the business of training compliance officers.
- Can I ask one thing?
Don't screw up the most lucrative partnership
this company has.
Please?
I'm not kidding.
Viktor Cherevin is completely unpredictable,
and it's Russia.
Insider trading is legal over there.
It's the Wild West.
There's still ideologues, but the new ideology is money.
They're not a country, they're a corporation,
which is why we're there in the first place.
- I know, don't rock the boat.
- It's not a boat.
It's a goddamn luxury yacht and we're all on it together.
So don't [beep]ing sink us.
- Another very realistic thing about this clip
is the tension between the side of the company
that cares about profits and the compliance team
that cares about sticking to the letter of the law.
And there is an ongoing tension between the two.
The side that cares about profits
is always going to want to push the envelope
about the kinds of customers that they take on.
Criminal customers tend to be quite lucrative.
When we see the laptop with all the account information
on the spreadsheet, we're made to think that what Jack Ryan
is actually doing is forensic accounting,
but in fact, that's not what a compliance officer
or a compliance analyst actually does.
The best analogy I've ever heard
is that the forensic accountant,
who might look at Bernie Madoff's books, for example.
They're like the pathologist who does an autopsy
on the homicide victim, whereas a compliance officer
is like the homicide investigator,
who's looking at lots of different pieces of information
to formulate a hypothesis as to what is actually going on.
They're looking for different patterns of behavior
and different characteristics about the customer
that might suggest that there is
suspicious activity taking place.
So to portray Jack Ryan as a forensic accountant,
or that he would even take an overseas trip
to investigate one client, is somewhat unrealistic.
As we can see, laundering large amounts of cash
is never as easy as Hollywood makes it out to be.
And even if you were able to do it well,
your clients are always gonna be criminals.
When they have the opportunity for a plea bargain,
it's usually the money launderer that they turn in first.
So take my advice and earn your money the legitimate way.