Contrary to the popular parlour game, I can name many famous Belgians: Eddie Merckx, Hercule Poirot, Audrey Hepburn, Susan Grossey [well, I’m famous on this blog – and I’m not quite Belgian but I was born in Brussels] and the Smurfs. And the Smurfs are particularly notorious in AML circles as they have given their name to a type of laundering: instead of paying in a large amount of cash which might be noticed, you split your criminal proceeds into smaller amounts and then get lots of individuals – smurfs – to scurry around and pay it into lots of different accounts. Sadly – not least because it conjures up such a comical image – smurfing has rather gone out of fashion in AML education, and this is a mistake because it is certainly not out of fashion among criminals.
Although crime is ever-evolving, and some of the most successful crimes today are not cash-based (think of embezzlement, and corruption, and fraud – all involving the misappropriation of money already in the system), there are still plenty of cash crimes out there. Indeed, some very large criminal deals (sales of arms, or human trafficking) are often conducted in cash because of its unmatchable anonymity. And so we ignore placement activities at our peril. I was reminded of this by an American news story I picked up yesterday. A couple in Arizona have been sent to prison for more than ten years for drug trafficking and money laundering, and their laundering involved the extensive use of smurfs: “In order to evade IRS filing requirements for transactions involving more than $10,000 in cash, and conceal from the government large cash transactions by narcotics dealers, Jose and Beatriz Valenzuela arranged for conspirators to deposit the proceeds of the scam into bank accounts they controlled, with each transaction being less than $10,000. Antonio Hill Jr., Erico Hill, James Lewis Jr., Kenneth Davis, Ernest Rawlings Jr. and Errol Comma have all pleaded guilty to their roles in the conspiracy and are awaiting sentencing.” That’s a six-pack of smurfs right there. Smurftastic!