The Black Market Peso Exchange (BMPE) is a tried and true method of laundering money between the U.S. and South America – it was used effectively by the Colombian narco-traffickers – and who is to say it isn’t being used by South American drug cartel members visiting Las Vegas casinos and joining various card clubs.
This is how it would work if I were running the system here in Las Vegas. I would organize high roller Las Vegas trips from Mexico, all expenses paid. Each one of my guests would have no limit on what they could spend as long as I got 20 percent of the money they so kindly deposited, in narco-dollars, in my mobile safe (never use the same location twice). The rest of the money would be deposited in my guests’ accounts at banks, non-banking monetary institutions and casinos up and down the strip.
The guests could then enjoy their stay, or they could partake in the activity of chip, jackpot or token redemptions, with the help of “friends” working at the casinos – no, no, we are not talking about skimming – that’s illegal (I’ll get to illegal immigrants next week). This activity is structured avoidance of currency transaction reporting requirements.
I would educate my guests in the hallowed ritual of “Minimal Gaming with Large Transactions” as referred to in the Financial Crimes Enforcement Network’s (FinCEN) regulations for gaming institutions under Suspicious Activity Report by Casinos and Card Clubs (SAR-C) filings. From 2004 to June 2011, there were 74,816 such filings totaling $1.77 billion, therefore there is little chance my South American guests would be noticed buying chips, depositing funds into their casino front money accounts and then cashing out after little or no play. Contracts with other than Mexican (OTM) nationals are pending.
After all, the casinos are in the business of cash, not law enforcement, even if they have to file Currency Transaction Report by Casinos (CTRCs) on cash amounts exceeding $10,000. As you can see from the colorful map of the U.S. at the top of this report (courtesy of FinCEN), our Battle Born state has the distinction of being at the top of something (no not illegals working in or most high school graduates) again with over $780 million reported in annual SAR-C filings.
America being the land of many choices and many jobless Americans, I would introduce my guests to more than 438 land-based and riverboat casinos, over 40 racetrack casinos, over 500 card rooms, and over 450 casinos run by Indian tribes across 28 states. I believe in spreading the largess and the old Irish saying, “variety is the spice of life.”
I bet you never noticed how the cartels were hiding their money in plain sight at the recent horse races, where ladies wear crazy hats and sip mint juleps, did you? Well, it just so happens the Federal Government recently seized a dozen race horses in New Mexico that were part of a money laundering operation for one of Mexico’s most powerful drug cartels. Those were some smart horses.
Now to help the Las Vegas economy further, I would create lucrative careers by hiring runners who would be paid handsomely (complete and thorough background checks, fingerprints, lie detectors etc, more funds for the county, police, etc), to deposit less than the ten thousand dollars reporting requirement, in different financial accounts around Vegas and then all over the U.S. (more money for, financial institutions, airlines, hotels, etc).
I strongly believe in contributing to the growth of the job market and helping all those jobless people who sit in front of their TVs chugging beers all day long – it’s a tough life; someone has to do it. In fact, looking at my spreadsheets, I am sure I can create more jobs than the two contenders for the presidency during these trying times for our nation. Maybe I should run for…