Geoffrey visited several branches of his bank in Europe to deposit significant amounts of cash into his company account.

The amounts ranged from USD15 - 40,000. He visited all the branches in a single day, and the branches were all within a short distance of each other. Since this financial institution had automated account-monitoring procedures, the different deposits raised an initial alert for further examination by a human operator.

Geoffrey was a citizen of an African country and according to the customer records at the bank ran a business importing second hand electrical goods from Africa. Fund transfers were made in an irregular basis to accounts in Africa - presumably payments for goods. The credit deposits were apparently proceeds from the sale of the goods in Europe, although the financial institution was concerned at the pattern of deposits. If these credits were legitimate, than why wouldn’t Geoffrey deposit the whole amount at his own branch? The bank decided to report the credit deposits to the national FIU.

To allow some time for an investigation to be developed, the FIU granted the bank the authority to continue to operate Geoffrey’s account normally. After analysing the transaction reports and bank records, the FIU decided to seek further documentary evidence concerning the shipment of goods from Africa. The FIU directed the bank to ask Geoffrey’s accountant to produce them. A short time later, a number of airway bills and invoices which purported to support the alleged shipments were produced for the financial institution and passed on to the FIU.

The FIU served production orders on the account in order to obtain formal records of all transactions through the account over the previous few years. The FIU also contacted the Customs service and requested attention to be focused on future shipment of the electrical goods linked to Geoffrey’s company as they entered Europe from Africa. Customs identified a shipment that was found to contain a large quantity of Cannabis with a street value of over USD300,000.

The African principal organiser - who was not Geoffrey - was identified and subsequently convicted to six years imprisonment for the substantive drug trafficking offence. Further financial and other investigations also identified that the African principal had been involved in eight similar drug importations. He was sentenced to a further ten years imprisonment for these importations to run concurrently. The court further upheld that he had benefited from drug trafficking in excess of USD1,500,000 and made a confiscation order for this amount. Geoffrey fled the country, and a warrant was issued for his arrest for money laundering and other offences.

Indicators :
Large - scale cash transactions
Deposits at a variety of branches and times for no logical reason (possible evidence of ‘smurfing ’ (i.e. structuring transactions to avoid automatic reporting based on value)
Questionable rationale of underlying business - importing used consumer goods from Africa to Europe is unusual