 Miami in the US. It is an honor for me to be joining this presentation from GFI that I will introduce in a brief moment. GFI or Global Financial Integrity is a Washington DC based think tank focused on illicit financial flows, corruption, illicit trade and money laundering for those of you who don't know, GFI uses high caliber analysis, fact-based advocacy and strategic advisory work to address the harms inflicted by trade misinvoicing, transnational crime, financial crime and kleptocracy. For those of you who have been in the financial crime or anti-financial crime world, for sure have heard about GFI for a long time, they have produced magnificent outstanding reports and news on items, on information to control, combat and prevent financial crime. And they will be presenting today the latest report financial crime in Latin America and the Caribbean, understanding country challenges and designing effective technical responses. So I invite, we invite you, if you have any question, if you have any comment, you can send us all those questions, all those comments through the chat here. So you have it down there. Also for those of you who want to listen to this in English or in Spanish, you have to, you have also there at the bottom of the page, the interpretation switch that you can, you can hear this in English or in Spanish depending what is your preference. So it is an honor to be participating in the launching of this magnificent outstanding report that I am eager to go through once this is over, but our, our, I know the staff from GFI will present it today. Before they, we present the people, the professionals from GFI, let me this is an honor to introduce our keynote speaker today, Senator Ryan Pinder, who is the Attorney General and Minister of Legal Affairs for the Commonwealth of the Bahamas, having been appointed in September 20th this year after the general elections were held in the Bahamas and the Progressive Liberal Party were voted in as the government. Upon his appointment to Attorney General, Senator Pinder took over the chairmanship of the Caribbean Financial Action Task Force. Senator Pinder is the former member of Parliament for the Elizabeth constituency and the Minister of Financial Services and Trade in the former Progressive Liberal Party government. Before becoming the Attorney General, Senator Pinder was a partner in a leading law firm in the Bahamas in the, in its commercial and financial service practice group. His practice focused on private client, client planning and structures and regulatory and licensing matters for financial services institutions. As a commercial attorney, he represented commercial interests in the hospitality and real estate development in front of the government and regulatory bodies in securing the necessary approvals to do business in the Bahamas. In this capacity, he represented some of the largest hotels and real estate development projects in the Bahamas. Senator Pinder is admitted to the Bahamas Bar and has, and was admitted to the Florida Bar as a board certified as a tax attorney. He received his bachelor and master of business administration, jury's doctor, as well as master of law in international taxation from the University of Miami. It is an honor, Senator Pinder, to have you here today to, to open this, this presentation. Welcome. Thank you very much. And thank you for that introduction. And I welcome all of the participants get and certainly I, I, I welcome my participation as the incoming attorney general of the Bahamas and the chairman of, of CFATF. So certainly the good morning to all. It's a pleasure and honor for me to address you today at this event to publish the Global Financial Integrity's report on financial crime in Latin America and the Caribbean. I would like to start by congratulating the GFI and the authors of the report who have created a useful document that will assist all of us and all of those involved in combating financial crimes. The report comprehensively reviews and examines criminal activity occurring through the crimes and drug trafficking, mineral trafficking, human trafficking and migrant smuggling, and also the financial crimes of money laundering, trade based money laundering and certainly terrorism financing and corruption. The CFATF welcomed the opportunity to participate in this GFI venture and notes the impressive number of participating countries, 33, and participants, 250 plus individuals and entities that certainly a large number and something to be proud of in producing such a comprehensive report. The level of participation is significant because it shows that the region understands the need to address these types of criminal activities in order to counteract or counter money laundering and terrorist financing and other financial crimes to achieve compliance with international standards that have been set by the FATF. A review of the report shows that regionally we have laws to address money laundering, terrorist financing, trade based money laundering, corruption, human trafficking and smuggling, and mineral trafficking. I know from the Bahamas point of view, but certainly for the entire region, we have all worked extremely hard in the recent years to upgrade our laws, to make them compliant with international best practices and to ensure as a region we are viewed as a region that takes financial crimes seriously. There's also a high level of ratification of relevant treaties to address these crimes that countries in the region have been part of. We therefore have some strong legal frameworks which we need to continually effectively implement not only for domestic purposes, but also to facilitate international cooperation throughout Latin America and the Caribbean and beyond. Certainly in our region in Latin America and Caribbean, we as countries frequently do business together and have clients from throughout the region. So understanding the inclusiveness of our region and the cooperation of our region is exceptionally important. Through a review of the country's summaries in the report, it reflects some common issues that can be facilitated by cooperation and collaboration. We are all brothers in this region and sisters in this region and we should work together in collaboration to achieve the end goal. These crimes are global significant and we can certainly play a strategic role in fighting these crimes at all levels, domestically, regionally and internationally and certainly across the globe. Many of us here that are represented, especially in CFADD, are small nation states with limited resources and we have financial and other issues that we have addressed that have all been worsened by the COVID-19 pandemic, but we must continue to persevere for the sake of our societies. In doing so, we also must continue to realize that the damage done by COVID-19 will take a collective effort to come out of. We all have strengths and we all have our own weaknesses and we can therefore aim to share our strengths and in doing so hopefully diminish some of the weaknesses that each and every one of us may have through collaboration and collective effort. I think we are stronger when we are united. This report represents an excellent guide as to not only what our challenges are and how we have addressed them, but it will also allow us to learn from each other what has worked in other areas and what we can do to improve ourselves domestically and regionally. The recommendations provided are comprehensive and will certainly assist in addressing aspects of the criminal and financial crimes that are the focus of the report. The report also allows our regional donors and those that provide technical assistance to focus on areas where we most need assistance in curbing financial crimes and illicit flows of funds. As I mentioned, many of us are small developing states. Many of us have challenges that we have to face on a daily basis and this collaboration and technical assistance from our partners I think will go a long way. There's a lot of work to be done in the region to continuously curb the financial crimes of money laundering, mineral smuggling, corruption and human trafficking and smuggling. As chairman of CFATF, I can state that we will continue to play our part to ensure that our members address these financial crimes and confiscate the illicit funds that are generated from them. We stand ready and willing to continue partnerships with the UNODC, the OAS, CARICOM and our Latin American counterpart GAFALAT and others to keep our region focused on raising public awareness and sharing of information between our law enforcement and other competent authorities to achieve a higher level of success in limiting these criminal activities. Again, through cooperation amongst ourselves, we believe that we can tackle these issues of financial crimes. In closing, I wish to sincerely thank the global financial integrity for this stellar report that will allow us all to review, reflect and move forward better equipped to facilitate the challenges to address financial crimes in Latin America and Caribbean. Our economies and our countries will only be strong if we demonstrate a commitment to integrity and a commitment to law and order. And this extends of course into what the topics in the GFI report certainly matters of financial crimes. So I want to thank everybody for the opportunity to just bring these brief remarks. I know we have a full day and then we have a full analysis on a very comprehensive and very large report. And I look forward to hearing the presentations by our panelists. Again, thank you very much. Thank you for the opportunity to participate and certainly thank you for the opportunity to introduce myself as chairman of CFADD and the new attorney general of the Commonwealth of the Bahamas. I wish everybody a good day. Excellent. Thank you very much, Senator Pinder, for your welcome words. And it is an honor to have or be working near hand in hand with the CFTF and these global organizations in charge of establishing certain standards to combat and control money laundering and other financial crimes. Let me go and introduce the professional, the people behind the force behind this report, this magnificent outstanding report, and behind the work at Global Financial Integrity that I will be presenting today, today report. We have Channing Mavreles, who is the Global Financial Integrity's illicit trade director. She focused on the intersection of illicit financial flows, transnational crime, and international trade. Channing has over a decade of experience working on issues related to AML-CFT and has been conducting data-driven analysis of illicit trade and trade-related IFF since joining GFI in 2013. Prior to joining GFI, Mrs. Mavreles worked in banking and has taught in South Korea and Morocco. Also is with us, our friend Lakshmi Kumar, who is the policy director at GFI with several years of experience working on issues of financial policy, securities investigation, regulatory governance, anti-corruption and anti-money laundering, terrorist financing. Before joining GFI, Kumar was a lawyer and policy professional in India working with governments and regulatory agencies across South Asia, East Africa to investigate money laundering and terrorist financing risk to their financial systems. Also our friend Julia Jansura, who is the program manager of Latin America and the Caribbean for GFI. She coordinates projects and partnerships in the region that promotes transparency, security and economic development. Her specific research interests include remittances, de-risking, informality and financial inclusion. Prior to joining GFI, Julia conducted research on remittances, migration and economic development at the Inter-American Dialogue at Washington, based think tank. Last but not least, Claudia Helm, who is a research associate in the Latin America and the Caribbean program for GFI. Claudia is primarily part of a project that analyzes corruption and financial crimes in Latin America and the Caribbean. Her interests include corruption, security, democracy and women empowerment in the Western Hemisphere. Prior to joining GFI, Claudia worked for several years at the OAS in the Department of Electoral Cooperation and Observation. Having introduced our professionals from GFI, I give them the microphone, the floor to you to present. Good morning everybody. I'm really pleased to have you all join us today to share this report. It's something we're extremely proud of. I think it comes as no surprise to everyone here that countries in Latin America and the Caribbean face a complex dynamic and challenging financial landscape. The same security threats that make the region one of the most violent in the world also generate large amounts of illicit proceeds which are subsequently laundered back into the region's economies and often are used to perpetuate further violence and insecurity. Countries in the region face a daunting task in effectively responding. So this project provides a comprehensive in-depth analysis of financial crime and crime threats in 33 Latin American countries. It includes a country by country overview that lays out the scope of financial crimes, the main threats facing each country and the effectiveness of the current national anti-money laundering and counter-terrorism financing or AMLCFT response. There are six case studies that exemplify some of the financial crime methodologies used such as the black market peso exchange, corruption and mineral trafficking. There's an analysis of four illicit economies that generate criminal proceeds regionally, drug trafficking, mineral trafficking, corruption and trafficking in persons and smuggling of migrants. There's a regional overview of four specific financial crime types, money laundering, trade-based money laundering, terrorism financing and corruption, as well as an analysis of efforts to address these financial crimes including programming efforts such as technical assistance programs, as well as a mapping of relevant national laws and international treaties. Next slide please. For this massive undertaking, GFI carried up 250 interviews with subject matter experts from government, civil society, the private sector and international organizations. Our analysis of financial crime threats, channels, routes and facilitators, as well as our assessment of the effectiveness of current national AMLCFT efforts includes the results of these interviews. In addition, GFI analyzed other materials regarding financial crimes including national risk assessments and mutual evaluation reports by the FADF and regional bodies such as Gaffrey Latin C FADF. Furthermore, GFI reviewed national legislation and international treaties on financial crimes and illicit economies. We mapped and analyzed current interventions to combat financial crimes including donor technical assistance programs initiatives by international organizations and regional or national efforts led by countries in the region. We used a variety of quantitative methodologies to estimate the scope of financial crimes. For national estimates of illicit proceeds, GFI used the two to five percent consensus range for criminal proceeds which has been widely used by organizations such as the United Nations Office on Drug and Crime, UNODC and the FADF. Now I'm going to turn it over to my colleagues to take you more in depth into the report. Thank you Channing. I'm going to switch to Spanish to have a bit of a balance in language and so if you need translation that is available. Como parte de ese proyecto, buscamos identificar cuáles son aquellos delitos financieros que más afectan la región, cómo se mueve este dinero sucio a través de las economías y quienes están involucrados a nivel regional en estos delitos financieros. Sacamos ese análisis hablando con más de 250 expertos de los países de la región. Primero les pedimos identificar cuáles son aquellos delitos financieros que más afectan sus países. Como podemos ver a nivel regional, la corrupción fue el primer delito financiero que más afecta toda la región. Le sigue el lavado de activos en segundo lugar, el lavado de activos basado en el comercio, en tercer lugar y el financiamiento de terrorismo en cuarto lugar. Claramente hay diferencias interesantes a nivel de subregión que podemos observar también. También les preguntamos a los expertos identificar principales fuentes de ingresos ilícitos que ven en sus diferentes países de la región. Lo que podemos observar aquí es que en la región en general la principal fuente de dinero ilícito es la corrupción. Le sigue el tráfico de drogas en segundo lugar, el trata de personas y tráfico de inmigrantes en tercer lugar y el tráfico de minerales en cuarto lugar. Obviamente también podemos observar diferencias interesantes a nivel de las subregiones. En el caso de Centroamérica, por ejemplo, la principal fuente de ingresos ilícitos es el tráfico de drogas. También les preguntamos acerca de los principales facilitadores que están involucrados en estos delitos financieros, prestando el término de GAFI, los gatekeepers. Estas son personas o profesiones que podemos imaginar como en las puertas del sistema financiero y ellos deciden quién puede tener acceso y quién no. Pueden ser profesiones como abogados, notarios, consultores, por ejemplo. Lo que observamos es que hay diferencias interesantes a nivel de las diferentes subregiones, pero por lo general los abogados y los notarios son los principales facilitadores involucrados en ese tipo de delito financiero. Esto según las más de 250 entrevistas llevadas a cabo para este proyecto. También tratamos de identificar los principales canales utilizados para mover dinero ilícito de una jurisdicción a otra. Obviamente, identificar los canales utilizados es clave para luego poder crear una respuesta de prevención adecuada. Entonces, tenemos que primero tener ese diagnóstico de cómo se mueve el dinero ilícito para luego diseñar y intervenciones efectivas. Lo que observamos es que aunque hay diferencias en las diferentes subregiones, por lo general hay cuatro grandes canales a nivel de Latinoamérica y el Caribe. Y estos son primero instituciones financieras. Esto no es gran sorpresa porque obviamente hay muchos activos y mucho dinero en estas instituciones financieras. Otro canal que vemos que es muy prevalente a nivel regional es bienes raíces, y si no han visto, les invito a ver un nuevo informe de GFI que publicamos acerca de lavado de activos basado en bienes raíces. Otro canal que es muy importante y muy prevalente a nivel regional es el comercio internacional. Aquí vemos, por ejemplo, el papel de la facturación fraudulenta, el lavado de activos basado en el comercio internacional. Y por último, es importante mencionar el nivel de contrabando de efectivo a granel, o el bulk cash smuggling. Esto también es uno de los canales principales. También en el transcurso de las entrevistas que hicimos, les preguntamos a los expertos cómo califican el esfuerzo nacional en prevención del lavado y otros delitos financieros. Aquí las respuestas son muy, muy interesantes. Generalmente, lo que podemos observar es que los áreas más fuertes son prevención investigación de delitos financieros y que los áreas más débiles tienden a hacer enjuiciamiento de estos casos. Y esto lo podemos observar también cuando miramos los diferentes casos, los diferentes procesos judiciales y vemos que a nivel regional hay muy pocas condenas por delitos financieros. Sabemos que hay investigaciones, sabemos que hay casos, pero no siempre llevan a enjuiciamiento, no siempre llevan a condenas. También les preguntamos a las personas durante el proceso de entrevistas cómo ellos califican los esfuerzos de su propio país en cuanto a hacer frente a los delitos financieros. Esta calificación en realidad refleja la percepción de quienes viven en este país y quienes trabajan en prevención de delitos financieros en este país. No necesariamente refleja la percepción de GFI, verdad, ni de los autores de este informe. Sin embargo, sí es interesante ver cuál es la percepción de la efectividad de la estrategia nacional de prevención del lavado y otros delitos financieros. Aquí podemos ver las respuestas en una escala de uno a cinco, donde uno representa una respuesta débil, verdad, y cinco refleja una respuesta muy fuerte, verdad, muy efectiva para controlar delitos financieros. Lo que podemos observar a nivel regional es que el promedio recibido fue solo 2.47 de cinco puntos, verdad. Yo creo que esto refleja que entre muchos de los países de la región hay hasta percepción de que tenemos que hacer algo más, tenemos que fortalecer más nuestro sistema de prevención de lavado y otros delitos financieros, verdad, refleja esta percepción de que lo que estamos haciendo actualmente no es suficiente, tenemos que hacer más. ¿Qué tendrían que hacer los países de la región para fortalecer su trabajo en hacer frente a esos delitos financieros? Primero, tendrían que abordar el tema de voluntad política, que es una barrera en muchas de las subregiones. Lo otro que tendrían que hacer es fortalecer la implementación. Observamos que en muchos casos los países tienen buenas leyes y buenas normas en papel, pero no siempre se llevan a la implementación, no siempre se implementan al 100%. Lakshmi. Thank you, Julia, for that. I have the pleasure of now talking about the first of our four different financial kinds. Now, when we talk about money laundering, I think we have such a great expert audience before us, we can slice it in several ways. I would encourage everyone here to look at our report because it's filled with rich detail, but for the purposes of this presentation, we're going to look at it through four different lenses. The first of which is what role does the region, the Lak region play in money laundering? Does it act as source, transit or destination? And the truth is, much like everywhere else in the world, all the countries in the Lak region also take on the role of source, transit and destination for money laundering. And this is because the region is complex in terms of the types of economies that it represents. So you have high-income, low-income and middle-income. And so therefore, they all take on the role. And again, this turn is therefore then reflected in the types of channels that are used to money laundering. And you can see from this chart, which is sort of a compilation of our 250 interviews, that it cuts across a whole host of channels and there's a wide diversity. But what is also positive about this is you see that the high-risk channels including real estate, remittances, free trade zones, stocks, offshore accounts, those are also high-risk channels that we see elsewhere in the world, which tells you the solutions to address money laundering are really about more greater cooperation because the same channels used in the Lak region are used in Africa, they're used in Asia. And so trying to see how we can weave together more cooperation is really the answer. At the same time, we saw some things that were unique. The mentions of sort of cattle ranching or rural land or sports associations, horse racing, some of those are a little more unique and not necessarily reflective of other parts. And ensuring that there is enough attention paid to those channels is also equally important. Can we move to the next slide? Now, once we've sort of talked about these two things, the other big thing I would say is the challenges that we have. The challenges that we have really can be split into four distinct categories. Now, the first of which is that AMN laws in the region are relatively recent. In many cases, they've only started in the last 10 years, which means they are very much still trying to catch up and figure out how to do this. There is not as much institutional knowledge, unlike what we see in the US and elsewhere. The other next challenge that we see is that the focus on US drug, in the US has been primarily on drug trafficking. This has been a double-edged sword for the Lak region. Now, what I would say is that while it has proved beneficial, our expert interviews really talked about at the same time that it was incredibly restrictive and it didn't allow resources to focus on other crimes that were just as important, which you can see in the multi-various channels that we've seen. Third was the issue of the mutual legal assistance process. As you know, money laundering is a cross-border issue. Because it is a cross-border crime, cooperation is important. A lot of our experts talked about how the foundational block for cooperation, which is the MLAC process, was incredibly limited in how effective it could be. And this was several reasons. For example, between the US and the region as a whole, there were sometimes language challenges. A lot of countries were civil law versus common law. There were different evidentiary standards. And finally, and perhaps most interestingly, while in all of this is the relationship that the US has with the region, in that we clearly see money leaving the region. And therefore, there's a question about the money laundering controls. But also, perhaps concerningly, there is the fact that the US continues to be a safe haven. All of the money that we see leave the region comes and still finds a home in the US, whether it's through real estate, whether it's through the use of US corporation services. So unless we figure out that relationship, figuring out the issues with financial crime and criminal activity doesn't work unless the US orders an equal part to play in it. And lastly, we can't talk about money laundering without talking about beneficial ownership. And if you see this beautiful graphic we have here on the right, and there are several others like it, there is a much better development of money laundering beneficial ownership registries in the region than in the US. But even within that, we see sort of four distinct buckets, countries that have not yet committed, countries that are committing to pass the laws, and those that have a public and private registry. And the biggest thing before I conclude is that for to make this effective, there has to be a uniform way of exchanging information between them. But I will stop here and hand it over to my colleague, Channing. Of course. Fleming, two years, can't turn off the mute button. So overall, experts interviewed for this project perceived TBML to be on the rise in Latin America and the Caribbean. And drug trafficking was the most common criminal activity linked to TBML. I'm going to discuss one emerging threat as well as two challenges that seemed most salient to me. One of the emerging threats in the region is the increased involvement of Chinese professional money laundering networks, particularly involving the US and Mexico and Colombia. TBML typologies have often been discussed in a two-country scenario where the criminal proceeds in the destination country, such as the country where our products are sold, are repatriated to the source country. That is the country where the drug trafficking organization or DTO or where the goods have been cultivated. With the increased involvement of Chinese professional money laundering networks, a third jurisdiction, China, has entered into the equation. In this three-country scenario, individuals in China purchase the criminal proceeds in the destination country, for example, the US. And in return, they make an equivalent amount of Chinese yuan available to individuals in the source country, let's say Mexico, so that individuals in businesses in Mexico can purchase goods in China. These goods are then exported to Mexico and sold with the proceeds in Mexican pesos given back to the drug trafficking organization. In fact, the US 2020 National Risk Assessment noted the increase in complex money laundering schemes involving Chinese citizens residing in the US who, acting as peso brokers, laundered drug-related cash proceeds via black market peso exchange schemes in order to repatriate money to Mexico. There was a symbiotic relationship between TBML and informal currency exchange. TBML schemes allow criminals to repatriate proceeds as well as allow individuals in one country, such as China or Colombia, to access foreign currency, that is, US dollars, without having to move money or go through formal channels avoiding potential restrictions or steep exchange rates and fees. For these networks, engaging in such schemes is not only a tried-and-true way to launder money, it is also a method for evading China's capital controls. This relationship is likely to grow in coming years as Beijing recently announced its plans to address the country's growing inequality through wealth redistribution by, among other measures, targeting the country's super-rich to reasonably adjust excessive incomes. In regards to challenges, the principal vulnerability to TBML in the region is that it is not well understood even by financial crime experts. The interviews as well as research left me with the impression that we, as a financial crime or transnational crime community, are not all on the same page. Some experts be spoke to falsely conflated TBML with the use of trade misinvoicing or the smuggling of legal goods such as cigarettes in order to evade customs and taxes. Others talked in essence about TBML, specifically using criminal proceeds to purchase legal goods that were smuggled across border and sold as a mechanism to legitimize the funds, but did not specifically use the term or seem to understand they were describing TBML. In addition, speaking with experts, you get the sense that TBML is this nebulous activity. There's an overall consensus that it is a very prominent methodology, but there weren't many specifics in terms of the magnitude or the actors involved, common typologies, impacted jurisdictions, etc. Finally, this is something not just confined to the Latin American and Caribbean region, but something a global issue, but definitely plays out here as well. And that is that much of the global AML CFT regime has largely focused on efforts to guard the formal financial system and, to a lesser extent, combat currency smuggling with a little attention paid to the international trade system. Up until the last five or so years, coverage by TBML by both domestic and international policymakers was rather lacking. And it was only recently that FADF last year issued an updated TBML report. Though, even with this updated report, one shortcoming that still exists in the FADF's response is that none of its 40 recommendations specifically focus on the trade sector or on combating TBML. In regards to the financial sector, one of the largest challenges is that financial institutions have very limited visibility over trade transactions. According to the Wolfsburg group, globally only 20% of international trade transactions are financed, with the remaining 80% of trade completed through open account transactions. As such, banks would not receive any documentary information related to the trade transaction. They would have to rely on traditional AML controls, including know-your-customer controls, to determine the risk of the transaction. Even if a trade transaction is financed, there is often a disconnect between the AML compliance department and the trade finance department, which typically focuses on detecting sanctioned individuals and to teaser countries, as well as dual use goods, versus detecting or having the training to know how to detect TBML red flags. I'm now going to turn it back to my colleague, Julia, to talk about terrorism financing. The region faces several challenges in order to respond to this threat in an effective way. First of all, although it is a violent region with a lot of intentional homicides, it is not a region that necessarily faces terrorism day to day. This is obviously a positive response, but it is a bit difficult to implement measures against terrorism financing. According to several of the countries, and according to the interviews we did, the countries have the laws and have the rules on paper, but sometimes they feel that they do not have much opportunity to practice and to ensure that they are really working. That is also a bit difficult, the regional response. The other thing is that, although there is a clear consensus about what terrorism financing is, there is not so much consensus about what it counts as terrorism. We see that regionally, the definitions of terrorism are a bit different. There are many differences between countries. The definitions sometimes are political, contradictory, sometimes even non-democratic. And here I am going to cite an example from Venezuela, which, for example, has designated groups of democratic opposition as terrorist groups. This is a very good example of the type of problem we see. Obviously, this is not the right use, of the term of terrorism, and the effective implementation of a policy against terrorism financing is very difficult. The other thing that is a bit difficult, the regional response, is that most of the channels used for terrorism financing are informal. So for national authorities, it is difficult to be able to face it. If the channels are informal, they have little ability to supervise or detect the flow of money. The main channels that we identify through the interviews are contraband of effective agrenel, informal remittances, and informal international trade, right? As for the facilitators involved in that type of crime, we must mention informal money, right? That they have a very important role to play. And finally, we must mention that terrorism financing usually happens with smaller amounts of money. This is also a threat, because if we compare it with active money, for example, this sometimes is with thousands of dollars, millions, millions of millions of dollars, right? There are large amounts of money, but terrorism financing can happen with 100 dollars, 1,000 dollars, right? So it is much more difficult to detect for smaller amounts of money. This does not mean that it is impossible to detect, obviously, but it is a threat for the countries of the region. With this, we are going to look at our last financial crime, Claudia. Perfect, Julia. Thank you very much. The financial crime that refers to corruption, in reality, was a financial crime that rose in all the interviews, rose in all our analysis, and we have defined it within reports as the abuse of power for personal benefit. But this definition, in reality, is quite general. We have complemented it with the definition of FATAR, the World Bank, and so on, international entities. But what we see that is very particular for the region is that it is present in all countries. And we see that it depends a lot on the context of the country itself. So we see that there are certain circumstances that define that a country is more or less corrupt. For example, poverty levels, informality, culture, the basic needs not covered, lack of education, low salaries. We also see that there are certain countries that do not necessarily want to fall into corruption, or want to do corrupt practices, but are a kind of victim, given that for their own culture and for the country's own size, the number of inhabitants makes it almost inevitable that, for example, in the same institution, there are businesses between the father who is the owner of the company, with a cousin who may be a minister. So we see that this dynamic is quite common, especially in small countries. Clearly, this, in front of international eyes, could be a conflict of interest, or that the necessary circumstances could be given so that they can go into corrupt practices. We see that throughout the region, we see that corruption is often unknown, even tolerated, and even animated, so that it is committed. Within the report, please, in the next slide, Julia, we see in the report that we have defined it as both a financial crime and an activity. What happens? What happens is that the financial crime, in itself, as a corruption, can erase different conducts, for example, fraud, theft, bribery, fiscal evasion, background evasion, money laundering, and all these annexed conducts, but it is much more difficult to identify it as illicit activity, because it is there where it is beautiful with immorality, with no ethics. We see that there are conducts, for example, such as nepotism, clientelism, influence. So we see that corruption is not only identified in the legislative norms, but that it is also given at the cultural level, at the practical level. So we see beyond this definition, which can be very practical, that the characteristics in the countries that have large amounts of corruption are that there is a social inequality, the institutions are weakened, there is distrust in the society itself among its own citizens, even in its own institutions, and the private benefit is always promoted. So we also saw that within our analysis, anyone can be a corruption agent, can be a lawyer, a notary, a customs agent, can also be an official, a middle-class, initial-class, so everything in the chain can be victims, they can be agents, promoters of corruption. And we see that the long-term that they continue to promote corrupt conducts, the democracy, the capacity of the governments to supply basic needs and basic services is impacted and not only is it going to affect the generations of now, but also the capacity of the state to provide quality services for future generations. So if there is no predictability of how it is going to act and if there is no specific guide, that becomes a problem that should actually be addressed both by the government and at the regional level. So we see that depending on how much corruption there is in the country, it can be from the normal, generalized, to systemic. So we also see that part of the causes of corruption is that there is, for example, a vulnerable public sector that precisely allows these corrupt practices to grow. Maybe there is not a good preparation, many of the people who we talk to say that they actually have the rules and the regulations, but they don't have the political will or sometimes some cases are underestimated. So this, if it is mixed with bureaucracy, creates the perfect condition for it to continue committing acts of corruption. So what is the way out for all this? There is not a single size for all the countries, because there are definitely countries that have much more resources, more knowledge, more technology than others. So we actually see that the initial initiative is not only to have a vigilant law, because we see that all countries actually comply with the normative of fatalities of the regional fatalities and so on. That is not the problem, the problem is implementation. Implementation because there is no connection to what actually happens in the country and what exists in that norm. So it is necessary, political will, it is necessary that there is a connection between the private sector, the society and the public sector so that in the end the results are the wishes that are generally in the law, but there is no request that is multi-sectorial, multi-factorial. So the first thing you have to do in reality in the countries is just to investigate what is happening, with what resources they have, to have an empowered judicial power, that they do not have a legal career for decades, in reality there are cases that do not have sentences. Also what we promote as GFI is that there is much more transparency and exchange of information between the own institutions so that they can talk among themselves, they can exchange information and so pursue the cases of corruption and prevent, above all, these corrupt conducts that affect not only the country, but also at a regional level. Part of the measures we promote is not only working at the level of the country, but with the neighbors, social, commercial, international entities, for example, such as VACILAT, ICG, the OEA, Edmund Group, where all the intelligence communities can work together. So we see that it is a joint effort. Until then, we arrive with corruption. Lakshmi, let's move on to the next theme. Thank you, Claudia. First, I just want to apologize if I was slightly distracted. I had a small issue with Zoom, but I promise you everything that I did say in the presentation is provided in glorious detail in the report itself, in a rather concise 15-page chapter. Claudia did a fantastic job of covering this. She very eloquently said corruption is both a financial crime and criminal activity. And I'm going to talk about the next criminal activity that we've looked at, which is mineral trafficking. I'm sure to many of you that are sitting here today, this has become a fairly important issue right before the pandemic and through the pandemic because of the attention that's been placed on gold. Now, for the purposes of this presentation, I really want to focus on a couple of things. The first pitch is, when we say mineral trafficking, what does it mean? What does it encompass? What stage of the process? When does it start? Does it cover just the point of extraction? Does it cover the point of export? Does it cover licensing? And then what else is included when we talk about mineral trafficking? Now, the truth is when we say the word mineral trafficking, there is no internationally accepted term for what is mineral trafficking. It encompasses everything from gold to iron to coal, because all of them in some form are minerals. Now, additionally, what it also includes in it, it's not explicitly included, but because it involves every stage of the process from contracting to licensing to environmental impacts, because there can be corruption or illicit activity that allows you to gain a profit margin through this. So you also have the issue of environment that is folded into an environmental damage and the profits from environmental damage. The next thing is especially in the region, land ownership is particularly complex. And there are both sort of historic and cultural reasons for why the issues of land ownership are deeply tied into the problems and the problems around minerals acting as a source of financial framework or acting as a source of illicit financial flows. Because again, as we found during our work is that there is both horizontal and vertical land ownership, meaning that someone can own the surface, but that doesn't mean you own the resources under it. And this has been fraught with problems. And the last thing is that, depending on where technical assistance is coming from, sometimes it can be entirely national security focused when the assistance is coming from the U.S. And in other times, it can be really through the lens of environmental damage. And that in turn affects the ability to how you prosecute and address this. The second issue is because the focus has been so much on gold, it has excluded so many other extractive commodities. We saw 16 other extractive commodities in the region that were high risk and susceptible for acting as a source of criminal activity. And more importantly, we saw illicit financial flows flowing through the use of these sectors. Now, great examples when this can use a switch to the next slide. Please. Thank you. Now, important examples in this we saw were, for example, there's Jade in Guatemala, which is a source of revenue for groups, which is not yet explored. Similarly, in Venezuela, so much attention has been paid to the use of by the Maduro regime of gold. But the country also has naturally a curving source of uranium, coltan, bauxite, all of which we have reports. And if you look at our report, we have divided by country, you can see the different geographic roots that different extractive commodities take when they are being used as mechanisms for illicit activity. Columbia Emeralds was something that a lot of attention, which was paid to at the height of the problems with FARC, it's dropped off through the radar. And there are still important questions around it, copper and Haiti. There are also questions around sort of undeveloped resources that we have seen, for example, lithium, which is worth billions of dollars and is found in Bolivia, Argentina, Argentina and Chile, which is expected to provide a lot of resources, but there are still questions about its rich potential for corruption. And if you look at our report, which I highly encourage you to see, you can see how much more commodities exist. And sometimes the attention of gold is taken away from the easy use of these other extractive commodities to facilitate crime. Finally, once again, for those that are interested, I do want to point out that we have seen that the flows of gold are incredibly interesting and varied, but the solutions really to mineral trafficking and addressing it as a problem remain ensuring that there are equal number of resources, not just for gold, but for the other commodities that are valuable revenue sources for the region. Hand it over to my colleague, Chanu. That's lively. Oh, already there. So talking about drug trafficking, it's one of the largest generators of criminal proceeds. And in conjunction with corruption and money laundering presents arguably the greatest challenge to the region. There is a strong symbiotic relationship between drug trafficking and financial crimes as drug proceeds are frequently laundered, but can also be used for type terrorism financing. Well, corruption is typically a critical component facilitating trafficking. In addition, drug trafficking often gives way to other transnational crimes such as human trafficking and illegal mining. Drug trafficking is a longstanding, deeply rooted activity in the region. So there are consistent trends largely related to cultivation, as well as newer trends related to supply and consumption. For the sake of time, I will highlight a few newer trends. First, Mexico's supply of cannabis to the US has decreased due to the growth of legalized and decriminalized cannabis across the US. One expert noted that it formally represented anywhere from 40 to 60% of the cannabis sold in the US. Inversely, Mexico is now the largest source of methamphetamine consumed in the US in comparison to domestic production due to its high purity and low price, which Mexican drug trafficking organizations are able to do through low production costs. Experts noted that fentanyl has been a game changer principally from Mexico in the US. It has not bled out too much into other countries. Fentanyl was largely arriving in the US either directly from China in small quantities by international mail or from China via Mexico in larger quantities. Over the last two or so years, there's been a marked decrease in direct imports from China as Mexican DTOs have begun importing the precursor chemicals required to make fentanyl from China and synthesize it on their own. Domestic consumption of drugs besides cannabis had been relatively low throughout the region. However, the last 10 years, the trading consumption of kind of quote, new drugs or newer use drugs, particularly synthetics like methamphetamine and ecstasy, has increased in certain countries. One expert noted that Brazil is the epicenter for the import of synthetics, particularly party drugs from Europe that are destined for Chile and Argentina, which have strong middle classes with greater disposable incomes. Now, it's probably no surprise that no method or channel is off limits for narcotics related money laundering. However, popular methods often involve some of the following, including again, TDML and the Black Market Peso Exchange in particular, which has been a tried and true method. Professional money launders, as I mentioned earlier, this Chinese connection, both playing a pivotal role in the flow of synthetics into the region as well as facilitating money laundering. And as Lakshmi highlighted, gold, or as well as kind of any precious metals or stones, narcotics proceeds can be invested into mining operations in order to lend the money. They can be used to purchase gold, either gold that's legally or illegally mined directly. What was stuck out to me very much was that in Suriname, the government transferred the authority, evaluation, and tax collection of gold exports from the Central Bank of Suriname to the private company Colote Suriname Mint House or KSMH. The government reported Leone's 10%, 30% is owned by former President Butters, via stock purchasers, and the remaining 60% is owned by Colote Precious Metals, a UAE-based global company plagued by accusations of laundering billions of dollars in gold. Since KSMH's formation, it has been alleged that the refinery only exists on paper for the purpose of certifying real and non-existing gold shipments. As Suriname is a transit point for gold and cocaine, this provides a handy avenue for money laundering. In addition to depending on the type of money laundering, the flow of proceeds back to the source country can mirror the path of the narcotics. For example, in Dominica, cocaine coming from Venezuela and other parts of South America transits Dominica while on its way to the nearby French overseas departments of Martinique and Guadalupe before moving onward to Europe. Experts reported that corresponding criminal proceeds, often euros, return along that same route. Now, the policy and law enforcement response to drug trafficking has largely followed this war on drugs narrative, which is typically focused on the interdiction of drugs traffickers and facilitators with less emphasis on the criminal proceeds. The success from this approach typically typically occurs in what I would call a piecemeal fashion. The number of drugs and fund sees the number of individuals arrested of cases prosecuted and largely have not had a strong systemic impact on the underlying conditions, things like poverty, violence, corruption, weak institutions, etc. that drive and or facilitate drug trafficking. Proper eradication and crop substitution programs have been prevalent in producer countries either initiated by the countries themselves, as well as with foreign support. However, the success of these programs has overall been underwhelming. And while cultivation may be reduced, sometimes significantly, it often does not have the desired impact on the market. Prop substitution programs were viewed by some experts as a legitimately viable option to combat illicit crop cultivation. However, it is absolutely critical to provide long term, as in decades long, for alternative development programs. Finally, the majority of countries in the lack region seem to struggle to include meaningful financial investigations into drug drug trafficking cases, meaning that law enforcement is unable to completely understand and therefore dismantle criminal networks. Even if a country does have a technical capacity to pursue money laundering cases, the government may choose to drop the money laundering charge in order to secure a conviction or guilty plea for drug trafficking or choose to file a lesser charge in its place. For example, Colombian prosecutors reportedly will often choose to prosecute an individual for the charge of illicit enrichment rather than money laundering as it has a lower burden of proof. I'm going to turn it back now to my colleague Julia to talk about trafficking in persons of smuggling of migrants. Muchas gracias Channing. Otro delito que nosotros analizamos fue la trata de personas y el tráfico ilegal de migrantes. Fue muy interesante durante las entrevistas porque algo que observamos es que se sabe muy poco del lado financiero de estos problemas, verdad? Por ejemplo, hablando con autoridades nacionales, expertos en el tema, casi no se sabe mucho de los flujos financieros ilícitos que están detrás, verdad, del atrato o bien del tráfico de migrantes. Esto es un enorme reto, verdad? Y realmente sería importante fortalecer esfuerzos de investigación, estudio para mejor comprender la parte financiera, verdad, de estos delitos. Lo otro que creo que es un poco complicado es que aunque la trata y el tráfico en teoría son fenómenos distintos, en la realidad no es tan sencillo, verdad? Vemos casos, por ejemplo, en que migrantes contratan a un coyote, verdad, con la voluntad de emigrar, pero terminan 100 victimizados por redes de trata de él. Okay. I think what we'll do is we'll push on and get to the conclusions and recommendations, and then if we can get Julia back online and we have some time left, we will get back to the tip and some. So what we're going to do next is let's have Lakshmi talk about some of these conclusions and recommendations and we'll move from there. Thank you. Thank you, Channing. I feel confident Julia will be back with us very shortly, but with the exception of what we just spoke about, in which I know we will come back to, what we saw was that these solutions really to tackle the financial crimes that we identified and the criminal activities that they looked at are by no means simple. They have a deep intrinsic connection to the ongoing issues in the region, whether it is inequality, violence, the lack of institutional, weak institutions, institutional knowledge, and I think most fundamentally, as Claudia mentioned, the issues with corruption. What must be underscored is that there was nearly a universal appreciation for the technical assistance programs that the U.S. government had provided. And another thing that I think was incredibly valuable for us was the sophisticated, the high level of understanding that experts throughout the region had of the problems that the region faces, what the possible solutions are, what the risks are, what needs to be done to do better, and also an eagerness and willingness to sort of want to contribute. And I think that that shows that there is a lot to be hopeful for. Finally, I think before we sort of go into the main recommendations, it is that financial crime and criminal activity are not standalone issues. They exist very much in a world and they are symptomatic of the problems with governance, rule of law, democracy, and corruption that the region faces. Therefore, any future technical assistance program has to not treat them as separate but really marry them. Next slide, please. And if we are talking about what are recommendations, I will emphasize that we have country-specific recommendations, recommendations for each financial crime and each criminal activity. But if we really have to talk about what are big thematic areas where we see things that need to be done, first and foremost is that, as I mentioned, there's universal appreciation for what the technical assistance programs have done. However, the one thing that we kept coming back to was the fact that the beneficiaries of the program very often are going back to the same environments where there are political pressures not to do cases, there are low wages, there are issues with corruption, and building those challenges in and how to address them into the technical assistance program is a necessary component because otherwise you provide training, but the training is often meaningless because the opportunities to do that are not as plentiful. I see that my colleague Julia is back, so I'm happy if she's okay to hand it over to her and then finish more appropriately when Julia has done and we can truly see how everything ties together, but I will hand it back to my colleague Julia. Thank you, Lakshmi. Muchas gracias, perdón. Parece que siempre que uno está presentando le cae el internet, ¿no? Sí, como yo les decía, en realidad yo creo que para los países de la región responder a los retos de la trata y del tráfico de migrantes no ha sido fácil. Vemos que en la mayoría de los casos los programas se enfocan en concientización, ¿verdad?, sobre riesgos de trata o de tráfico de migrantes. En otros casos los programas se enfocan en atención inmediata a víctimas de trata o de tráfico. Esto es apropiado y es muy importante, pero no se trata de responder y investigar las redes financieras detrás de estos fenómenos, que en nuestra opinión también sería muy importante, ¿verdad? Otro reto que nosotros observamos es que no hay mucho consenso sobre el papel del coyote en el caso del tráfico de migrantes. Para algunos expertos, ellos consideran que el coyote forma parte o está afiliado a redes criminales más grandes, pero otros expertos consideran que el coyote es un actor individual, ¿verdad?, que está operando pequeñas redes que no necesariamente están conectadas a redes más grandes. Y por último, yo creo que un reto ha sido que generalmente redes de trata y redes de tráfico de migrantes tienden a ser muy pequeñas y tienden a ser muy segmentadas, ¿verdad? Es decir que no cubre toda la ruta geográfica, sino que cubre como un pedazo, ¿verdad?, del viaje o de la ruta, ¿verdad? Entonces, lo que observamos es que el lado financiero también tiende a ser muy segmentado. Estamos hablando de pequeñas redes y esto dificulta mucho la detección y la investigación de este tipo de caso por parte de las autoridades. Next slide. Si vemos en la siguiente lámina, nosotros tratamos de calcular la escala del tráfico de migrantes. Estudiamos una geografía específica, miramos el valor del tráfico de migrantes entre el triángulo norte de Centro America y los Estados Unidos. Y haciendo el cálculo, nosotros pensamos que la escala sería aproximadamente 2.7 mil millones de dólares por año. Esto es un monto muy conservador, probablemente tomando en cuenta las olas de migración que hemos visto este año, el valor real sea mayor. Pero podemos decir que el valor es por encima de 2.7 mil millones de dólares por año, que sería tráfico de migrantes entre triángulo norte de Centro America y los Estados Unidos. Ahora, ¿cuál sería el valor aproximado de envios entre Estados Unidos y Centro America? Nosotros hicimos el cálculo y pensamos que el valor de estas transacciones desde Estados Unidos hasta los países del triángulo norte de Centro America sería por encima de 500 millones de dólares por año. ¿Por qué es menor? Es un monto más pequeño porque obviamente no todos los migrantes llegan a los Estados Unidos. Y aquí también podemos observar el problema de la deuda del tráfico de migrantes. Muchos migrantes son deportados, regresan a sus países de origen con deuda muy grande y esto obviamente también es un factor de vulnerabilidad, porque ellos lleven grandes cantidades de dinero a redes o a grupos delictivos. También podemos observar que parte del dinero que se paga para tráfico de migrantes va a oficiales corruptos y a grupos de narcotráfico. Entonces, aquí es la relación muy importante entre todos esos delitos que hemos tenido hablando. No podemos analizar tráfico de migrantes por sí solo, sino que tenemos que tomar en cuenta cómo se relaciona con otros delitos como la corrupción o el narcotráfico, por ejemplo. Muchas gracias, creo que podemos pasar. I think that we can conclude that. Thank you so much. Excellent. Thank you very, very, very much Julia and all of you. We have been receiving plenty of questions as well. I don't know Channing if you want to go over the conclusion and recommendation and then we go over some of the questions we would be receiving. That's perfect. We'll go to just the next slide and Lakshmi will go over our kind of most salient points that we wanted to share and then we'll head straight into the Q&A and then wrap up with some another keynote remarks from our friend from Gafilat. Thank you Channing and thank you Julia for sort of, you know, beautifully wrapping that up. And as you can sort of tell that from what Julia sort of, you know, to tie back what Julia already sort of highlighted is that whether you look at human trafficking, mineral trafficking, drug trafficking is that they don't exist in silos. They are a product. They are symptomatic of everything, everything else that's happening in the region, whether it's governance challenges and issues. And therefore, when you're talking about technical assistance programs, whether it's to sort of someone at the border, whether it's prosecutors, whether it's judges, accounting for those environmental challenges, rule of law challenges, systemic challenges is important. The second thing is that one of the issues that we've really seen is that the, because so much of the focus has been on drug trafficking in terms of how the US government has provided technical assistance, the US government's own response to the issue of drug trafficking really needs to take into account that it too is a product of the systemic issues of corruption and therefore making sure that policy mechanisms and outreach and assistance programs wed the two together is incredibly important. Again, another sort of the third thing on this is one of the perhaps a really interesting thing. And this is applicable to most countries in the region is that there is a tremendous backlog of cases, sometimes going over a decade, a decade and a half. And what this means is that money laundering cases, there is very little impetus to actually move them forward because of this backlog of cases. And it is very, and in turn, it means that cases never see the light of the day. So while this is perhaps will require more of an investment long-term, there's a lot more to be gained because if there were specialized courts, which could fast track cases that deal with financial crimes and associated criminal activities, it ensures that there is a high priority, but also adequate resources provided to make sure that these cases get traction and there are sufficient penalties for it. Now fourth, as we talked about the fact that a lot of countries in the region, they are still in the very early stages of implementing anti-money laundering policies in general or financial crime policies to fast track it because the notion of financial crime is not confined by jurisdiction. At its essence, it is a cross-border issue. And the greatest success stories we've had and the greatest appreciation has come from exchange programs where a DEA official or someone is involved in the MLAD process has been stationed in a country in the region, but also to talk about how this can occur not just with the US and countries in the region, but between governments in the region as well because all of the problems we've seen in terms of the routes, they don't start and end in one destination. They go through different countries in the region. Now finally, as Julie very eloquently identified, the weaponization of the financial of anti-money laundering policies is a huge issue because that is not the purpose of these policies. It is being used to target pro-democracy groups, non-profit groups and therefore because of the voice that the US has and many other member countries the Garfield Act has, it is important that during mutual evaluations, the weaponization or the misuse of AML policies also be identified because otherwise you're shooting yourselves in the foot. The policies that groups would use to support against financial crime and criminal activities, those groups are being taken out of the picture and therefore sort of addressing that is a really key element, but I will stop there and hand it back over to my colleague. Excellent Lakshmi here. If you agree, we can go over some of the questions, very interesting question we've been receiving along the presentation. I don't know if we have time to go over all of them, but we will try to answer some of them at least. Michael asks if you find that red flags for terrorist financing are essentially buried in money laundering detection red flags or basically ignored and he's asking if GFI has any statistics concerning the level of terrorist financing in the region or in the world. I don't know if Julia Channing, anyone wants to answer that? Yeah, absolutely. I think, I mean, I will invite you to read the report where we have a detailed overview of the number of terrorism financing cases that are investigated and subsequently prosecuted by country. It is very, very low. I think that, yes, there is a problem with terrorism financing cases being lost in these much larger, at least larger by financial volume, money laundering cases, but there's also the issue and keep in mind that many of the channels used for terrorism financing are informal, right? So the authorities don't necessarily even have eyes on what's happening, right? How can you identify red flag indicators over an informal transaction, right? That's not even going through sort of the normal system where authorities would have a chance to detect it. So these are some of the problems that we see. It's a great question and I definitely invite you to check out the full report. Oh, absolutely. And he makes a statement. I personally believe that low amounts, ability to hide in normal transactions and the focus on money laundering efforts causes any statistic effort in practical. So that to add to your, to your, to what you said, Julia. Now, Patricio is asking, how can technology assist financial institutions in dealing with trade-based money laundering and anti-money laundering in general? What a key and hot topic now that the FATF has published a couple of reports on technology itself, identification, digital identification, etc. I don't know if anyone has anything to add about that. Sure, definitely. I think I'll kind of break this up in two parts versus kind of what you can do on the kind of technical or IT side. I think for us, one of the biggest things, the biggest recommendations would be to improve the use of the trade data used by the financial institution. GFI has actually developed a program called GF Trade. It's a trade-missinvoicing risk assessment tool that helps to kind of answer the question, is this price appropriate that we're looking at this trade transaction? And this is, you know, designed to be used by both customs departments as well as financial institutions. One challenge that we see a lot of times is both, both kind of entities aren't quite sure, you know, when they're presented with an invoice, be it from an importer or an exporter, how do they verify that price being declared? And we've seen both people from, from financial institutions as well as from customs departments going to Amazon, going to places like Alibaba, going to this using not the best resources for determining the price. And it can be very hard because at least when it comes to the customs front, a lot of times, you know, the way it works out with the World Trade Organization and valuation rules is it's a bit of a, you know, kind of innocent until proven guilty. You have to accept that value until you can find overwhelming evidence or appropriate evidence to prove that the declared value is incorrect. And you have only a certain amount of kind of wiggle a room or steps that you could take to do so. So we highly recommend GF trade in helping, you know, both sides know kind of what the left hand is, you know, the left hand doesn't know what the right hand is doing. So helping to know on the import side, or if you're looking at, you know, financing and import transaction, what is the average per unit price declared on the export side? And helping to provide that information. We also use a tool called Pangeva that helps to actually provide transaction level trade data. So I can see transaction by transaction, depending on the country. You know, what companies or individuals have done with particular commodities, both can help you know, again, with the pricing, but whether the commodities and the countries involved to make sense. Going towards kind of training, I think this is definitely, it's hard as I kind of mentioned in my remarks, a lot has been focused on kind of the AML red flags in terms of structuring and smurfing and different things like that of certain kind of kind of very common things to look for, both kind of from the front line as well as integrating into compliance kind of monitoring systems. I think there really needs to be increased cross-training between trade finance and, you know, AML compliance departments. I think there's sometimes a preoccupation, you know, there's a preoccupation on the trade finance department of just identifying whether maybe this is a sound transaction in terms of, you know, any financial risk to the financial institution, or if it's going to violate any kind of, you know, sanction rules. And a lot of times they need to pull back and kind of take a 30,000 look at the transaction. I heard once about a trade finance transaction involving the imports of live cattle from Argentina to Nigeria by a steakhouse that were being moved via airplane. So I don't know if you know, but that doesn't make any sense, you know, the company in Nigeria was trying to say that they wanted the freshest meat and they were going to get it this way. However, if you've ever bought an airplane ticket, that's an extremely expensive way to move goods. You know, ultimately it took interacting with the AML compliance department to get, you know, some common sense into this and the transaction was recommended. One final note on this to look out for for early next year, there's the Global Coalition to Fight Financial Crime. It's a great coalition of both public-private sector as well as civil society organizations that GFI is part of. I'm part of this NENA working group and they're actually working on producing a trade-based financial crime document focused on trade finance and detecting trade-based financial crime for financial institutions. So I recommend keeping that on your radar. Thank you so very much, Channing. I mean, we are going over the time. One last question before we have the final words by Gabriela Rodriguez from GFI. But I think this issue is key to prevent and combat and control financial crime. It's a question by Patricio also. Do you think there is enough attention given to training of staff by financial institutions and corporations in order to be aware of trade-based money laundering? So I'll just refer back to just my earlier comments. I definitely think there needs to be more interaction between both sides, between AML compliance and between the trade finance departments, and kind of have a better appreciation by trade finance and some of these red flags so that in real time they can be detected and to better safeguard the institution itself as well as prevent money laundering. Excellent. Thank you very much, Channing. And well, we are a bit over the time, but it is an honor also to have Gabriela Rodriguez with us. Gabriela Rodriguez, quien es abogada y notario público de Nicaragua, ocupa el cargo de experta técnica de la secretaría ejecutiva del gafilat desde abril del 2018 y en el marco de sus funciones ha participado de la evaluación mutua de la cuarta ronda del Perú y Chile. Actualmente se encuentra a cargo de brindar apoyo al grupo de trabajo de análisis de riesgo e inclusión financiera. Previamente, antes de formar parte del equipo de la secretaría del gafilat, fue jefe del departamento de supervisión de APNF de la UIF de Nicaragua, donde también se desarrolló como especialista de inteligencia financiera operativa y estratégica. Adicionalmente participó junto a las autoridades de Nicaragua en la coordinación del proceso de evaluación mutua de Nicaragua en el marco de la cuarta ronda de evaluaciones mutuas del gafilat. It is an honor to have you here with us, Gabriela, today for the final words para el cierre de la conferencia. En nombre también del doctor Esteban Julín, secretario discutivo del gafilat, por esta invitación de este lanzamiento de un documento que tenemos la certeza de mucha utilidad para la comunidad internacional, desde ya me permito agradecer y perdón felicitar a la Global Financial Integrity por este esfuerzo de gran trascendencia que como ya mencioné es un aporte realmente importante para la región. Como podemos escuchar en las distintas ponencias de las panelistas, si en los países de América Latina y el Caive han realizado importante esfuerzos para la identificación de riesgos y amenazas, así como para el combate de muchos delitos asociados al lavado de activo, los cuales como ya sabemos generan un impacto importante en la economía de los países no podemos dejar de tomar en cuenta las conclusiones y las recomendaciones que han sido planteadas en este informe. El documento que el día de hoy se está dando a conocer señala algunas amenazas que efectivamente están presentes en la región. Bueno, ya las colegas no mencionaron muy bien, tales como el lavado de activo, la corrupción, el narcotráfico, la trata de personas entre otros, pero también hicieron referencia a algunos sectores que han sido utilizados de vulnerados, tales como los abogados, los notarios, el sector de bienes raíces y que en los últimos años los informes de amenazas y de eticolosías que el gafilata que han realizado también implican estos mismos resultados, con lo cual no quiero dejar de señalar importancia de este tipo de análisis ya que son herramientas fundamentales para los países, para el desarrollo de sus procesos de análisis de riesgo, para la realización, perdón de actividades iniciativas, para la aplicación de mayores recursos en escenarios de mayor riesgo y fundamentalmente para promover el fortalecimiento de las acciones de cooperación y de coordinación internacional en la lucha de todos estos telífons que ya hemos mezclado. No me queda más que agradecer nuevamente, felicitar a los ponentes que nos acompañaron y a todas las personas que involucran en el proceso y hacerles un gran día. Muchas gracias. Thank you so very much, Gabriela, muchísimas gracias por las palabras. And without further, I'll let you, Channing, Lakshmir, Julia, Gloria, if you want to close this up. I think I'll just say a quick thank you to everybody for joining us today. This was definitely a project we just absolutely enjoyed working on both in terms of what we, you know, we're able to learn from this and the ability to take all of this information and put it into some really strong recommendations and provide this information to our colleagues that are out there working on financial crime, working on transnational crime and hopefully, you know, it has a really great impact. We encourage you to follow us, you know, follow GFI at Adelisa Flows on Twitter and check our webpage for kind of reports. We have them coming out all the time. Definitely going to highlight a report by my colleague Lakshmi and Kaiza Debell on money laundering in real estate in the U.S. that came out recently. But keep an eye out, we hope to continue this and we'll be looking more into financial crimes in Latin America and the Caribbean over the next year in particular looking at fraud, extortion, cryptocurrency, and forgetting one who's going to jump in. It happens, but investment funds. Excellent. Okay, now we will be looking, we will definitely be looking for those new reports coming out from GFI. I'm telling you from myself and my personal experience, I've been involved in the financial crime field for 20 years and I find everything GFI does fantastic, a great tool, great resources, great information to be to be abreast in the fight against crimes, in the fight against money laundering and financial crimes overall. Thank you so very much and it was a really a pleasure.