This article is part of the book Challenges and Threats to Security in Latin America.

Celina B. Realuyo^[1]

Abstract

Illicit financial flows present a threat to the political, economic, and social development and security of countries around the world, particularly in the Americas. Dirty money serves as the lifeblood for illicit networks that include terrorists, criminals, traffickers, and their facilitators, and provide a window and a vulnerable entry point into these illicit organizations. Money laundering and terrorist financing enable terrorist groups and transnational criminal organizations to conduct their operations and promote their evil agendas which contribute high levels of insecurity and violence across Latin America. Armed groups in the Americas have become increasingly powerful and wealthy, undermining legitimate economies and democratic institutions. Over the past 20 years, governments have increasingly employed “following the money trail” to better understand, detect, disrupt, and counter illicit networks but must continue to keep abreast of evolving threat financing methods to combat criminal and terrorist networks and their illicit financial flows and promote security, prosperity, and good governance throughout the Americas.

Key Words: Illicit Financial Flows, Money Laundering, Terrorist Financing, Transnational Organized Crime, Corruption.

Introduction

Illicit financial flows present a formidable threat to the political, economic, and social development and security of countries around the world, particularly in the Americas. Dirty money serves as the lifeblood for illicit networks that include terrorist groups, insurgencies, criminal organizations, and rogue states. Financing is indispensable to support and sustain the command and control, personnel, arms, communications, logistics and operations of illicit networks. Transnational criminal organizations are involved in the trafficking of drugs, people, arms, contraband, illegal mining, money-laundering, and corruption which all contribute to high levels of violence in the Americas. Drug trafficking continues to be the most lucrative activity of transnational criminal organizations in Latin America and fuels violence, insecurity, instability, and corruption in nations where the drugs are produced, transported, distributed and consumed. It has been a scourge for the Americas for the past 50 years enriching the Colombian and Mexican cartels.

Illicit financial flows related to crimes, such as drug and human trafficking, undermine the global financial system and threaten political, economic, and social stability and security. As we have witnessed in various countries, illicit financial flows also promote bribery and corruption, finance insurgency and, in some cases, terrorist activities. Examples in the Americas include the Mexican cartels, Central American maras like MS-13, FARC dissidents and ELN in Colombia and the PCC in Brazil. These funds also destabilize and deter legitimate enterprise, foreign investment and development. Money-launderers and terrorist financiers exploit loopholes in and differences among national systems for countering money-laundering and the financing of terrorism and move their funds to or through jurisdictions with weaker or ineffective legal and institutional frameworks. This has been a particular challenge in the Americas.

Therefore, the nation states and the international community must work together to reduce illicit financial flows by detecting, monitoring, seizing, repatriating, and preventing them. Those engaged in illicit financial flows contribute to crime, violence, instability, corruption, and inequality. Since illicit financial flows know no borders or nationality, all countries must do their part to address them. This article will define illicit financial flows, distinguish between money laundering and terrorist financing, explain the methods used to move illicit financial flows, describe strategies to follow the money trail to combat terrorism, crime and corruption and recommend measures for governments to fight illicit financial flows in the Americas.

Defining Illicit Financial Flows, Money Laundering and Terrorist Financing

Illicit financial flows (IFFs) are a critical enabler of illicit networks that include terrorists, criminals, proliferators, and their facilitators and provide these groups with wealth and power to conduct their nefarious agendas. According to the World Bank, illicit financial flows (IFFs) refer to money illegally earned, transferred or used that crosses international borders with the following characteristics: (1) the acts themselves are illegal (e.g., corruption, tax evasion); (2)) the funds are the results of illegal acts (e.g., smuggling and trafficking in drugs, people, minerals or wildlife); or (3) the funds are used for illegal purposes (e.g., financing of organized crime or terrorism).^[2]

Illicit financial flows came under greater scrutiny with the disclosures of the Panama Papers in 2016, the Paradise Papers in 2017 and the FINCEN Files in 2020. They revealed how dirty money and front companies were distorting and undermining the international financial system and diverting funds away from development, particularly in the Americas. Illicit financial flows, whether they be from tax evasion or criminal activities, result in a loss of what are often desperately needed resources to fund public initiatives or critical investments. Collectively, for developing countries, this often represents hundreds of millions of dollars in lost or foregone tax revenues that could have otherwise been collected and used for promoting sustainable economic growth, creating jobs, reducing inequality, poverty, and addressing climate change. With billions of dollars estimated to be illicitly leaving developing countries every year, this drain of public resources undermines the efforts of countries to mobilize more domestic resources in order to meet the internationally agreed Sustainable Development Goals by the target date of 2030.^[3]

Money laundering is one of the most prominent manifestations of illicit financial flows. It is the process of disguising the proceeds of crime and integrating it into the legitimate financial system. According to the Vienna Convention and the Palermo Convention provisions on money laundering, it may encompass three distinct, alternative actus reas: (1) the conversion or transfer, knowing that such property is the proceeds of crime, (2) the concealment or disguise of the true nature, source, location, disposition, movement or ownership of or rights with respect to property, knowing that such property is the proceeds of crime, and (3) the acquisition, possession or use of property, knowing, at the time of the receipt, that such property is the proceeds of crime.^[4] Money laundering involves three stages: (1) placement (the initial entry of illicit money into the financial system), (2) layering (the process of separating the funds from their source, often using anonymous shell companies), and (3) integration (the money is returned to the criminal from legitimate-looking source such as real estate).

Terrorist financing involves the solicitation, collection, or provision of funds with the intention that they may be used to support terrorist acts or organizations, according to the International Monetary Fund. The funding may come from both legal and illicit sources. More precisely, according to the International Convention for the Suppression of the Financing of Terrorism, a person commits the crime of financing of terrorism “if that person by any means, directly or indirectly, unlawfully and wilfully, provides or collects funds with the intention that they should be used or in the knowledge that they are to be used, in full or in part, in order to carry out” a terrorist offense within the scope of the Convention. The primary goal of individuals or entities involved in the financing of terrorism is therefore not necessarily to conceal the sources of the money but to conceal both the financing and the nature of the financed activity.^[5]

Various Methods of Money Laundering and Terrorist Financing

While terrorist financing and money laundering have different objectives, they share similar tactics that abuse international financial systems and involve illicit financial flows. Through money laundering, criminals try to disguise the proceeds, sources, or nature of their illicit activities. Terrorist financing uses funds to sponsor or facilitate terrorist activity that could include clean and dirty money. Methods of money laundering and terrorist financing are similar and include: the banking system, cash couriers, bulk cash smuggling, money services businesses, store of value cards, trade-based money laundering, mobile or internet payments, cryptocurrencies, non-profit organizations, real estate, and front companies.

Cash Couriers/Bulk Cash Smuggling: Cash is king! Despite newer methods to move and hide money, paper currency is still regarded as the dominant and preferred mode of payment illicit networks including criminals, traffickers, and terrorists. Bulk cash smuggling is a money laundering and terrorism financing facilitation technique that is designed to bypass financial transparency reporting requirements.^[6] It usually occurs in U.S. Dollars and Euros that are widely accepted as international currency and can always be converted. The currency is often smuggled into or out of countries concealed in personal effects, in shipping containers, or transported in bulk across the border via vehicle, vessel or aircraft. Physically, cash can be large, heavy, and difficult to conceal as one million U.S. dollars in $100 dollar bills weighs about 22 pounds/10 kilos.^[7]

This is a favorite method of the Mexican cartels who move money frequently between the U.S. and Mexico derived from drug and human smuggling operations. According to the U.S. Department of Homeland Security, Mexican national Roberto Gallegos-Lechuga pleaded guilty to conspiracy to commit international money laundering in July 2021 with his links to the Sinaloa Cartel for using money services businesses and currency brokers to recruit money couriers to transport bulk cash from various locations throughout Southern California and other parts of the U.S., then deliver it to stash houses in Mexico. Once in Mexico, the currency was exchanged at a favorable rate from U.S. Dollars to Mexican Pesos. The cartel also used fictitious entities to deposit repatriated U.S. currency in U.S. banks.^[8] Cash continues to be the preferred payment method for drug transactions and operating expenses.

Trade-Based Money Laundering: Trade-based money laundering is the movement of illicit funds through commercial transactions and organizations that are and/or appear to be legitimate. This involves practices such as over or under-reporting of the amounts of invoiced goods or services (e.g., shipping more items than documented to allow the recipient to profit from resale), repeating invoices (e.g., delivering one set of items but receiving payment for two sets), falsification of receipts (e.g., the goods shipped are described as a less expensive item when they’re really something more costly), and sales of commodities for prices that are above or below market. The transactions can be simple (two parties colluding to use a commercial transaction to deflate the value of an exchange to benefit from the difference between the resulting understatement in cost and the value of the goods on the open market) or complex (involving multiple parties in numerous nations, knowingly or unknowingly involved in the fraudulent aspects of the transactions).

These practices take advantage of commercial trade to hide their intended purpose and to mix illegally obtained funds into the legitimate financial system. A well-known version of this mode is the “black market peso exchange” (BMPE) very popular in the Americas. BMPE is regarded at the most commonly used money laundering method among Colombian transnational criminal organizations and plays a major role in the movement of funds for Mexican cartels and Lebanese Hezbollah as well.^[9] Intelligence and law enforcement agencies are cognizant of many of these methods, but given the total volume of international trade, legal and otherwise, it is impossible to screen and detect fraud in every transaction.

Cryptocurrencies: A cryptocurrency is a medium of exchange that is digital, encrypted, decentralized and unregulated in contrast to the U.S. Dollar or the Euro. Cryptocurrencies offer online payment methods that are quick, secure, easier to use and pseudonymous. Even governments themselves are exploring the possible issuance of central bank digital currencies or digital cash. The Venezuelan government issued its own cryptocurrency, the “petro,” in 2018 purportedly backed by the country’s oil and mineral reserves, and El Salvador became the first country to adopt Bitcoin as legal tender in September 2021. During the COVID-19 pandemic, criminal organizations in the Americas became more active and reliant on cyberspace and on cryptocurrencies.

Bitcoin is perhaps the best-known cryptocurrency, and the growing of a number of exchanges make it easier than ever to use, especially when such platforms are based in offshore jurisdictions. While not completely private, your unique address is publicly available— and any transactions from it can be tracked. Following the digital money trail is helping to detect, disrupt and detain high-profile criminals and their networks. In April 2019, Mexican police arrested Ignacio Santoyo, a notorious human trafficker linked to a prostitution racket involving some 2000 women across The Americas. Mexican authorities tracked him down after he bought enough Bitcoin to trigger an alert under the new law in Mexico that requires the reporting of suspicious virtual currency activity. Moreover, when making his transactions via a registered platform, Santoyo left personal details including his phone number and address that facilitated his capture. Human traffickers are complementing their activities online in terms of recruitment, marketing, and financial transactions. A July 2020 report by Polaris, a nonprofit organization addressing human trafficking, found that virtual currency was the second-most commonly accepted payment method on 40 platforms in the online commercial sex market.

During the COVID-19 pandemic, the Financial Action Task Force warned of an increased misuse of online financial services and virtual assets to move and conceal illicit funds. Cyberspace and cryptocurrency are emerging as a new frontier for organized crime groups battling for control of vast criminal markets for drugs, arms, sex, and people especially in the Americas. The U.S. Department of Justice has found virtual currency increasingly used to buy and sell illegal drugs on Dark Web marketplaces and by drug cartels to launder their profits, contributing to the opioid epidemic in the U.S.

The above-mentioned money laundering and terrorist financing techniques are just some of the ways illicit networks abuse the international financial system and cyberspace to move and fund their criminal or terrorist activities. “Following the money trail” or exploiting financial intelligence has enhanced the ability of Latin American governments to better understand, identify and combat transnational criminal organizations and terrorist groups in recent years.

Strategies to Fight Money Laundering and Terrorist Financing

Since financing serves as the oxygen for any criminal or terrorist organization, depriving illicit networks of funding constrains their operating environment and ability to plan and execute their evil agendas. This is the objective of counter threat finance strategies that countries employ to combat terrorism and crime. Over the past 20 years, governments have increasingly exploited financial intelligence to “follow the money trail” to combat terrorism, crime and corruption including in the Americas. Tracking how terrorists and criminals raise, move, store, and use money has been instrumental in degrading groups such as Al Qaeda, ISIS, Lebanese Hezbollah, the FARC in Colombia and the Sinaloa Cartel in Mexico. Strategies to counter threat financing, that includes money laundering and terrorist financing, consists of three lines of operation: (1) law enforcement and intelligence operations against terrorist financiers and money launderers; (2) public designations of terrorists and drug traffickers, sanctions, asset freezes and seizures; and (3) domestic and international training and capacity building in the counter-threat finance discipline for the public and private sectors.

Law Enforcement and Intelligence Investigations: “Following the money trail” has greatly enhanced law enforcement and intelligence operations against illicit networks. How, when, where, and from/to whom money has been transferred are reliable data points that counterterrorism and counter-crime officials use to map out and identify armed groups, their facilitators, and their activities. In many cases, financial intelligence and forensics are determining factors in developing and prosecuting cases of transnational organized crime, terrorism, and the material support of terrorism. Unlike confidential informants and witnesses for the prosecution, the money trail presents clear evidence of a financial connection or link between two or more parties.

At the U.S. Treasury Department, the Office of Terrorism and Financial Intelligence is responsible for the intelligence and enforcement functions to protect the U.S. financial system against illicit use and combat rogue nations, terrorist facilitators, weapons of mass destruction proliferators, money launderers, drug kingpins, and other national security threats.^[10] After the September 11, 2001 attacks, the Treasury Department established the Terrorist Finance Tracking Program (TFTP) to identify, track, and pursue terrorists – such as Al-Qaida and ISIS – and their networks.^[11] Since the start of the program, the TFTP has provided thousands of valuable leads to partner agencies and other governments that have aided in the prevention or investigation of many of the most visible and violent terrorist attacks and attempted attacks and links to criminal organizations.

The convergence of terrorism and crime is best illustrated by Lebanese Hezbollah’s cocaine trafficking and fundraising networks in the Americas. Hezbollah is a Shiite Muslim political party and militant group based in Lebanon and is designated as a terrorist group by the United States, Israel, and many other countries. After years of investigation, the Paraguayan and U.S. governments carried out a coordinated action in Ciudad del Este, Paraguay, in the Tri-border area near Argentina and Brazil, on August 24, 2021, against the money laundering network of Kassem Mohamad Hijazi, a Brazilian citizen of Lebanese descent allegedly involved in funding Hezbollah terrorism. According to the U.S. Treasury Department, Hijazi’s laundering network has been operating on a global scale since 2017 with the capability to launder hundreds of millions of dollars.^[12] Hijazi along with other suspected Hezbollah financiers were investigated by the Paraguayan prosecutor Marcelo Pecci, who was assassinated in Cartagena, Colombia on May 10, 2022, while on his honeymoon. There are rumors that Brazil’s PCC and even Hezbollah operatives were behind the killing.^[13] Hijazi was convicted and finally extradited from Paraguay to the U.S. on June 20, 2022.

Investigators must now leverage financial and digital intelligence as criminal networks move into the cyber domain. One of the first cases of money laundering using cryptocurrency detected took place in April 2018 when the Spanish Civil Guard dismantled a criminal structure involved in cocaine trafficking that bought Bitcoins with illegal proceeds in Euros and sent the “legalized” money to accounts in Colombia to be withdrawn in Colombian pesos. In total, the group used 174 bank accounts to launder $9.3 million in cocaine proceeds from Europe. In a separate case, Brazil’s Department of Narcotics Investigation agents apprehended a criminal running a crypto-mining operation in Porto Alegre and seized 25 cryptocurrency mining machines, which operated around the clock and are each valued at approximately $65,000 in April 2019. Law enforcement and intelligence agencies will have to expand their understanding cryptocurrencies, their attributes and vulnerabilities to potential abuse and anticipate how illicit networks are exploiting cryptocurrencies to finance their criminal activities like drug and human trafficking, engage in cybercrime and launder their proceeds.

Public Designations and Sanctions: Sanctions and public designations constitute another measure to combat and prevent money laundering and terrorist financing. Countries levy sanctions in different ways against governments, individuals, terrorist, and criminal groups. Sanctions are used to punish, shame, isolate and seize the assets of those targeted. The U.S. government has various designation programs to stem the flow of financial resources to a particular terror or criminal group. The first of these efforts is aimed at state sponsors of terrorism. The Secretary of State designates nation states who provide funding to terrorists or terrorist organizations as state sponsors of terrorism; currently, Cuba, Iran, North Korea, and Syria are on this list. Under Executive Order 13224 signed by President Bush after the 9/11 attacks, the U.S. can designate and block the assets of organizations and individuals linked to terrorism. Over the past two decades, designations of terrorist financiers by the Treasury, State, and Justice Departments have been used to disrupt terrorist networks by blocking their assets and deterring would-be terrorist supporters from providing financial resources to terrorist groups. Some terrorist groups designated by the U.S. include Al Qaeda, ISIS, Hezbollah, Hamas, FARC dissidents and ELN (Colombia), and Boko Haram in Nigeria.^[14]

Perhaps more widely known in the Americas is the Drug Kingpin Act that is a U.S. law that targets significant foreign narcotics traffickers, their organizations, and agents with the purpose of denying them access to the U.S. financial system and to prohibit all trade and transactions between the traffickers and U.S. companies and individuals. The infamous leader of the Sinaloa Cartel, “El Chapo” Guzman was arrested, extradited from Mexico, and convicted in a U.S. court in 2019 for drug trafficking and money laundering as a “drug kingpin.” More recently, the U.S. launched a “maximum pressure” campaign that leverages diplomatic, economic and law enforcement measures to isolate Nicolas Maduro and his cronies and impede the regime’s access to the illicit economy and encourage a transition to democracy in Venezuela. The program has targeted regime leaders, the central bank, and key industrial sectors (like gold, oil, and gas) based on terrorism-related and drug-trafficking-related sanctions, under the Foreign Narcotics Kingpin Designation Act and sanctions for anti-democratic actions, human rights violations, and corruption under the 2014 Venezuela Defense of Human Rights and Civil Society Act. As of May 23, 2022, the U.S. Treasury Department had imposed sanctions on roughly 166 Venezuelan or Venezuelan connected individuals and the State Department had revoked the visas of more than 1,000 individuals and their families. The illegitimate Maduro regime sustains itself through narcotics trafficking, illegal oil sales and illicit gold mining and relies on its network of allies, namely Colombia’s ELN and former FARC members, Cuba, Russia, China, Iran, Turkey to circumvent sanctions and keep itself in power.

Building Capacity to Combat Money Laundering and Terrorist Financing: Counter threat finance assistance programs are aimed at building sustainable, dynamic anti-money laundering and counterterrorist finance regimes that adhere to international standards and implement effective programs in the legal, financial regulatory, financial intelligence, law enforcement and prosecutorial fields. Improving the capability of countries to combat and prevent terrorist financing significantly enhances the ability to detect and isolate terrorist financiers and to “follow the money” to where it links global terrorists and their support networks. To successfully combat and prevent money laundering terrorist financing, governments must develop an effective counterterrorist finance regime based on five basic elements described below.^[15]

• Legal Framework to Criminalize Terrorist Financing. Each country should have a legal framework that criminalizes terrorist financing and money laundering. This allows countries to comply with international standards pursuant to UN Security Council Resolution 137326 and the Financial Action Task Force Special Recommendations on Terrorist Financing.
• Financial Regulatory Supervision to Protect the Integrity of the Banking System. Each country should develop a financial regulatory framework that vigilantly supervises the financial services sector. Additionally, the financial services sector must develop and employ strict anti-money laundering and counterterrorism finance compliance measures that ensure that their employees “know their customer” and file suspicious transaction reports that may indicate money laundering and terrorist financing activities.
• Financial Intelligence Unit as the Link Between the Private and Public Sectors. Each country should set up a financial intelligence unit to collect, analyze, and disseminate suspicious transaction reports submitted by the private sector associated with financial transactions. An effective financial intelligence unit leverages well-trained analysts, equipment, information technology platforms, and specialized analytical software to meet its mission to develop and refer relevant evidence of financial crime cases (including terrorist financing cases) to law enforcement authorities.
• Law Enforcement Investigations to Track Down Terrorist Financiers. Each country should develop specialized financial crime units within their law enforcement agencies. These units must possess the deep technical skills necessary to follow financial forensics and develop financial crimes cases that include money laundering and terrorist financing. These financial crime units must follow the money trail of terrorist groups and complement counterterrorism and counter-crime investigations.
• Judicial/Prosecutorial Process to Bring Terrorist Financiers to Justice. Each country should possess a well-developed judicial system capable of bringing money launderers and terrorist financiers to justice. An effective regime would employ well-trained prosecutors who are able to “follow the money trail” and make their case to the judges and magistrates.

The U.S., other nations, and multilateral organizations such as the UN, World Bank, IMF and OAS are engaged in capacity building programs throughout the Americas to enhance countries’ ability to combat illicit financial flows that threaten the financial system and regional security. They conduct financial sector assessments, provide technical assistance in the financial and non-financial sectors, and monitor economic systems to ensure compliance with the international standards on Combating Money Laundering and the Financing of Terrorism and Proliferation.

Conclusions

Financing is the lifeblood of any organization, licit or illicit. “Following the money trail” has proven to be an important financial instrument of national power for governments fight illicit financial flows and to combat money laundering and terrorist financing. Not only is financial intelligence helpful for understanding illicit networks and how they operate but has been valuable in identifying the key financial leaders in threat networks who are difficult to replace. Denying these illicit networks their financing and targeting the financiers of terrorist groups like Al Qaeda, FARC, ELN, ISIS, Hezbollah and transnational criminal organizations like the Mexican cartels and PCC in Brazil have been a critical component of military, intelligence, and law enforcement operations to identify, degrade, and dismantle these transnational terrorist and criminal threat networks.

To finance themselves, illicit actors engage in a broad spectrum of activities to raise, move, store, disguise, and spend money that are difficult to detect and disrupt. They include cash couriers, bulk cash smuggling, trade-based money laundering, cryptocurrencies, front companies, and real estate. To combat and prevent money laundering and terrorist financing, governments have developed complex, interagency, counterterrorism and counter-crime strategies that include law enforcement and intelligence operations that “follow the money trail” to pursue and prosecute terrorist financiers and sanctions and public designations. Countries have built significant capacity to criminalize money laundering and terrorist financing, regulate the financial services sector, establish financial intelligence units, and create specialized law enforcement and prosecutorial units to combat and prevent threat financing.

International initiatives such as those undertaken by the United Nations and Financial Action Task Force have raised awareness of the negative effects of illicit financial flows on international financial markets and increased regulation to safeguard the international financial system. Since illicit actors threaten all sectors of society, the private sector must be aware of these threats and engage in combating terrorism and crime. Public-private sector partnerships promote more understanding of financial innovation’s advantages and disadvantages and of how terrorists and criminals might finance themselves. All of these measures contribute to efforts around the Americas to combat and prevent money laundering and terrorist financing but must be reviewed and updated to keep up with evolving financial innovations and methods of threat financing.

Endnotes:

1. The views expressed in this chapter as those of the author and do not necessarily reflect the views of the William J. Perry Center for Hemispheric Defense Studies, National Defense University, or the Department of Defense. ↑
2. The World Bank “Illicit Financial Flows (IFFs) Brief”, worldbank.org (July 7, 2017), https://www.worldbank.org/en/topic/financialsector/brief/illicit-financial-flows-iffs; International Monetary Fund, “The IMF and the Fight Against Illicit and Tax Avoidance related Financial Flows”, imf.org (March 8, 2021), https://www.imf.org/en/About/Factsheets/Sheets/2018/10/07/imf-and-the-fight-against-illicit-financial-flows ↑
3. Global Financial Integrity, “Illicit Financial Flows”, gfintegrity.org, https://gfintegrity.org/issue/illicit-financial-flows/ ↑
4. International Monetary Fund, “Anti-Money Laundering/Combating the Financing of Terrorism – Topics”, imf.org, https://www.imf.org/external/np/leg/amlcft/eng/aml1.htm ↑
5. Ibid. ↑
6. Financial transparency reporting requires Currency and Monetary Instrument Reports, which obligates the filer to declare if he or she is transporting across the border $10,000 or more in cash or monetary instruments. ↑
7. Nickel, “How Much Does a Million Dollars Weigh?” fivecentnickel.com (May 21, 2009), https://fivecentnickel.com/how-much-does-a-million-dollars-weigh/ ↑
8. U.S. Immigration and Customs Enforcement, “Decade-long ICE HSI investigation leads to prison sentence for Sinaloa Cartel associate”, U.S. Immigration and Customs Enforcement (January 11, 2022), https://www.ice.gov/news/releases/decade-long-ice-hsi-investigation-leads-prison-sentence-sinaloa-cartel-associate ↑
9. NDIC, “National Drug Threat Assessment Report 2011”, The United States Department of Justice (2012), 40, http://www.justice.gov/ndic/pubs44/44849/44849p.pdf ↑
10. U.S. Treasury Department, “Terrorist Finance Tracking Program”, treasury.gov https://www.treasury.gov/resource-center/terrorist-illicit-finance/Terrorist-Finance-Tracking/Documents/TFTP%20Fact%20Sheet%20revised%20-%20%288-8-11%29.pdf ↑
11. Ibid. ↑
12. Juan Delgado, “Paraguay, US Capture Leader of International Money Laundering Network”, Dialogo Americas (September 28, 2021), https://dialogo-americas.com/articles/paraguay-us-capture-leader-of-international-money-laundering-network/#.YsUZ-5PMKu4 ↑
13. Catalina Oquendo, “Murder of Paraguay prosecutor Marcelo Pecci shows international crime links”, El Pais (Bogota: June 9, 2022), https://english.elpais.com/international/2022-06-09/murder-of-paraguay-prosecutor-marcelo-pecci-shows-links-between-international-criminals.html ↑
14. U.S. Department of State, “Foreign Terrorist Organizations”, United States Government (2022) https://www.state.gov/foreign-terrorist-organizations/ ↑
15. Celina Realuyo, “Building a Counterterrorist Finance Regime”, in The Global War on Terrorist Finance, US Department of State Bureau of International Information Programs, E-Journal USA: Economic Perspectives, Vol. 9, No. 3 (September 2004), 10–13, https://usa.usembassy.de/etexts/his/ijee0904.pdf ↑