 Thank you very much, Tom, and congratulations to Raymond, Tom, and the team at Global Financial Integrity for this wonderful achievement, a celebration of the work of many years and a precursor to the very good work toward curtailing illicit financial flows that is to come. My name is Les Meyers. I'm the president of Center of Concern, which is a think tank here in Washington, D.C. that for 45 years has been working through research, education, and advocacy to promote global social justice. I'm also pleased to be a member of the board of directors of Global Financial Integrity and to facilitate this discussion with two quite accomplished colleagues in the area. I have immediately to my left, John Casara, who has 26 years of public service working in clandestine service on the intelligence side, but also in law enforcement in a variety of agents including FinCEN and Treasury Secret Service. And since leaving government service has been a wonderful thought leader helping to guide the profession, both the public and private sector execution, looking at trade-based money laundering in a variety of forms of illicit financial flows and corruption. And then we have as well Rob Sbersky, who spent most of his 25 years in public service working for customs down in Florida, but also in Latin America, and also focusing on various forms of trade-based illicit financial flows, trade-based money laundering. What we're going to be doing this afternoon is talking, each of them will take about ten minutes to discuss his approach to the issue of trade-based money laundering. We typically think of the three main ways of moving the money around, financial system, moving the currency itself, and then of course the kind of illicit financial flows, the money laundering that occurs in plain sight through manipulating trade. And so with that, we will have their presentations first, and then we will have a discussion among them and an invite conversation with our guests as well. So please, do you know which of you would like to proceed first? Okay, we'll have John go first then. Thank you. Please. Absolutely. Please. We'll sit over here. Good afternoon. Good afternoon. It's probably about 2002, not too long after the attacks on 9-11, I had a conversation with a Pakistani businessman who I think we could charitably say was involved with the gray markets. We were talking about many of the things that we talked about already this afternoon and again tomorrow. We were talking about illicit financial flows. We were talking about over and under invoicing. We were talking about counter-valuation in underground markets. We were talking about Huala, and he said something to me that made a profound impression. He said, Mr. John, don't you know that your enemies, your adversaries are transferring money and value right under your noses, but you don't see it. Your enemies are laughing at you, and he kind of hit it, but it infuriated me because I knew he was right. They're laughing at us. We're talking about multinationals. We're talking about abusive transfer pricing. We're talking about abuse of misinvoicing. We're talking about trade diversion, but we're also talking about things like capital flight. We're talking about tax evasion. We're talking about underground financial systems, but what Rob and I want to talk to you about is part of the equation as well that sometimes perhaps gets ignored, but from our perspective, it's extremely important. That is the illegal part of trade-based money laundering, not illicit, but illegal. We're talking about things like proceeds from narcotics trafficking, proceeds from human trafficking, simple customs fraud. These are all illegal. We're going to take just a few minutes here to kind of introduce the topic for those of you that don't know that much about it, and then I think Rob's going to fall off and give me some of his perspectives on these issues. As let's start out by saying the financial action task force, there's three major ways to launder money, but according to that same financial action task force, yes. That's it? Yes. According to that same financial action task force, they define trade-based money laundering as the process of disguising the proceeds of crime and moving value through the use of trade transactions in attempt to legitimize their illicit origins. The key word in that definition is value. We often think about money, right? Money as cash, money through a bank, money through an electronic transfer, money through an ATM machine that we transferred around the world, even cyber today, but for some reason or another, it's very difficult for us, particularly in the West, to get our heads around this concept of value transfer. Now there are all different ways to do this, but it really all involves invoice manipulation. This is a pen. It's a very nice pen. It say it's worth $20. It's real costs, manufacturing, insurance, freight, et cetera. But if a buyer and a seller are working together, the price of this pen can be whatever it wants we want it to be. If I'm working with Rob on the other side of the ocean through invoice manipulation, we can make this $10 pen or $20 pen appear to be $30 pen or $5. We are over or we were under invoicing. You send enough pens, you sell enough pens, you're transferring a lot of value. I spent a lot of my time in Italy combating Italian American organized crime to mafia by looking the illicit flows of money going back and forth between Italy and the United States. A very, very common procedure at that time where you had couriers going every day from Rome Malpens' airport flying into JFK carrying satchels, bags full of manufactured 18 carat Italian gold jewelry, right? And they would land to JFK and they would officially declare this stuff and have the supporting documentation that this bag, for example, was $500,000 worth of Italian gold jewelry. But was that really 18 carat Italian gold jewelry? Perhaps it was 22 carat. Perhaps it was 24 carat. Perhaps it was 12 carat Walmart special. Perhaps it was gold plated lead. Was that really worth $500,000 or was it $700,000 or was it $50,000? Just the transfer of value via the gold trade. Now, there's lots of different examples in invoice fraud and manipulation. You can overstate quantity, you can talk around the quality, but it comes down to moving money out and moving money in. I'm not, let's put it this way. Sometimes I get challenged by invoice manipulation, so I came up with a cheat sheet, a handy cheat sheet for special agents like myself. If you want to move money out, you import goods at overvalued prices or you export goods at undervalued prices. You want to move money into a country, you import goods at undervalued prices or you export the goods at overvalued prices. Let me give you a couple of really quick examples of how this is done. Again, what we're talking about here is the criminal use of trade. Here's true examples of abnormal U.S. trade prices. This is all true, I don't have to make anything up. You know, for example, that the United States is importing plastic buckets from the Czech Republic at $972 a bucket. That we are importing briefs and panties from Hungary at $739 a dozen. That we are importing iron bolts from France at about 3,000 a kilogram and toilet tissue from China at $4,000 a kilogram. That we are exporting live cattle to Mexico about $20 a cow. That we are exporting bulldozers to Colombia for about $1,700 a bulldozer and missile launchers to Israel at $52 each. What a deal. All right? Now, remember what I just told you about over and under invoicing? You think maybe, just maybe this stuff needs closer examination? I'm here to tell you, as a former specialization for the U.S. Customs Service, it's not happening. And if it's not happening in the United States, it's not happening elsewhere. Right under our noses. All right. Here is a slide from a real case involving the exports of refrigerators from the United States to a drug-producing country in Latin America. All right? So if you look at the purple ups and downs, the peaks in the valley, that represents the sale, the exports of refrigerators from the United States to that other country. The horizontal line represents time. The vertical line represents value. The kind of that lighter blue color is the corresponding data from that other country. If I am exporting 1,000 widgets and each widget costs, say, $100, when it gets to the other country with some recognized variables, we should still have 1,000 widgets and each widget should cost $100. But that's not happening here. The peaks in the valleys, the difference between the purple and the blue is the transfer of value in the form of refrigerators, all right? And it only is at the very end, when we started comparing our data, U.S. data, with that other country's data, did that basically reach market level, all right? We put them out of business. I'll give you one other quick example, all right? Very sensitive. Come on. There you go. Ow. I'm not even touching it. There. Very easy. Okay. All right. What we're doing here is we are comparing what we call 49 gold, 99.99% pure goleon with scrap gold, all right? This is all gold coming into the United States, and by the way, the United States is a gold-producing country. All this gold is coming into the United States in this particular example from countries in Central South America, all right? So let's look at that pretty much solid red line. Again, we're talking about time and value. That solid red line represents, again, supply and demand of 49 gold, pretty Fort Knox type gold bullion, okay? And you can see how it goes up over time. There are a couple outliers there. Statistical anomalies doesn't mean anything, all right? That's 49 gold, and then all those blue dots represent gold scrap. Gold scrap for customs valuation purposes is really not precisely defined. It could be literally anything from the insides of computers to, say, gold teeth taken out to, well, what a customs inspector once told me, he said you could get a 40-foot shipping container and you could fill it up with metal scraps and shards, stand on top of it, take a salt shaker filled with gold dust, sprinkle it over the top, and then for customs classification purposes, you would then have gold scrap, okay, everybody with me? So then why are we importing gold scrap at prices higher than gold bullion? Or for that matter, anywhere close to gold bullion? It doesn't make any market or economic sense. But if you're talking about criminal, trade-based money laundering, it makes all the sense in the world, okay? All right, Rob. Thank you, John. That was excellent, and having you in an 18, GS18-11 special agent and having worked in this field, let me say John has not exaggerated at all. It's very true, all that he said. Channing, would you, I don't see you Channing, but she's there, okay, would you flip the slides for me? Okay. The first one's corrosive effects. What I'd like to do in about 10 minutes is just provide you a little bit of a boots-on-the-ground perspective, that of a GS18-11 special agent and subsequently as a contractor. And in doing so, I want to focus on the corrosive effects. And as Ray Baker and the staff here at Global Financial Integrity, who are my heroes, by the way, have very aptly pointed out that the corrosive nature of illicit financial flows are often hidden by the headlines as to volumes. And that certain volume, flows below a certain volume appear to present a lesser challenge. And that troubles me, because one person being shot and killed is just as bad as multiple people being shot and killed. But with respect to the corrosive effects, I just want to touch on a few of how to effect your economy and undermining the legitimate economy. And as you see on the slide here, I have certain, that by all means is not inclusive, but certain ways it does. This undermines the economy. It also generates crime and corruption, absolutely. One of the big ones and one of the reasons we're here today is the loss of tax revenue, huge. But as I speak about this, I want you to do something for a moment for me. I want you to envision you're out at a land border crossing. A land border crossing is not very well traveled. And as you're standing there with some of the officials, the border guards, the police, whatever, you see a tractor-trailing approaching, and this tractor-trailer is pulling a flatbed. And on the flatbed is a bulldozer. You can see it doesn't take much to realize this is a very expensive, very well-manufactured engineered bulldozer. And it's got some mud on it, so it looks like it's been used, so it's not, you don't have a brand new invoice for it. But as it pulls up, the law enforcement people, the border guards, customs officials, they scurry about. And what are they doing? They're looking, as they examine that, they're looking at all the crevices, they're looking for money, they're looking for drugs, perhaps weapons, explosives, things of that nature. And something like this, you're not going to be able to hide people, so that's not an issue. So they don't find any of that. And they'll take a glance at the paperwork, yeah, yeah, yeah, that looks okay. Go ahead. They'll wave it through. Well, what just happened? Well, no, it may or may not be. However, that bulldozer may in fact be the proceeds of an illicit narcotics transaction. Instead of coming back in suitcases or duffel bags on a small plane to a desolate airport somewhere, a strip, or instead of wire transfers, that right there is the value of that cocaine shipment. Or in the case of, say, Afghanistan, I don't know if Heather is in the room today, but in that part of the world it could be opium. That right there is it. And it's in plain sight. And it's, you know, it's pretty interesting, and it's one of the many ways of transferring value. But now let's take it down, and again, my area of responsibility was Central America, so let me focus on that a little bit. There was an individual by the name of Waldemar Lorenzana. He was the leader of one of the largest drug trafficking organizations in Guatemala. Well, he started out as a customs agent. So a little smarter than the average bear, I'd say. As he developed his drug empire, included in the different aspects of it, he had front companies to include, to report it, 15 construction companies. So you have 15 construction companies now. Are they able to drown that lawful business, lawful construction companies? Oh, yeah. His costs are so much lower. Front companies. Now his companies, hey, they're doing, they're doing construction business, but they're also using that business as part of the integration stage of money laundering, three different stages. He's putting it in, so it's really warping the economy. And talk about policymakers who are trying to look at amounts of, you know, money, the amounts of flow so they can set policies, how can you do that? You really can't. But that's one of the things that, in order to get a visual on how this could be taking place in some of the corrosive effects I just wanted to point out. Next slide, please. Okay. John pointed out and did an excellent example zone on trade-based money laundering, let's say for inbound flows into source countries. And trade-based schemes can be used in part in what's called black market-pacel type operations. In different parts of the world they use different names, but Latin America they call black market-pacel. But all too often. You know, people hear about that from time to time. In fact, there was a really good article in the New York Times about a week ago about a black market-pacel operation that was just uncovered and arrests were made. But what about the outbound flows, outbound from the developing countries? The cross-border transfer, the proceeds of corruption, commercial tax evasion. Done so, and to the credit of global financial integrity of exposing this to the large part by trade mispricing, which is by and large is trade fraud. What does this do? It ends up depriving developing countries of a much needed and actually better described desperately needed tax base. Next slide, please. Okay, that leads me to an issue which I'll, in a broad sense, I'll refer to a sustainment. But let's start off by talking about training, organizing, and equipping. This is very, very dear to me and important to me. The United States and its partner nations do a marvelous job at training, organizing, and equipping the military services and the security agencies. And please keep in mind. When I say security agencies, I'm doing so in the context of their national police, your federal level criminal investigators, your customs officers, prosecutors, and your correction officials, the prison officials of the developing nations. However, following that, it needs to be, it should be, and it needs to be, the responsibility of the respective countries to fund these agencies, to fund the yearly budget. Should it be your tax dollars and my tax dollars that funds each and every one of their agencies? I say no. What's needed is an adequate tax base. If they're to do the job that we want them to do here in the United States, that the people want them to do in their respective countries, you know, to make, give somebody a fair playing field if they want to be a business man, the members of the security agencies, which I'll say, they need to have salaries that enable the recruitment of the best, the brightest, most ethical personnel. And with the emphasis on quality over quantity. Now, a lot of you say, well, this really maybe is not that tough. We don't really need them that bad. I want to remind you all of something called the Plata versus Plomo. Okay, in Spanish, it's the lead or the bullet, or money or the lead, basically, a polymer of the bullet. And what happens in a lot of these countries is that they'll look for young men and women coming out of different universities or working in private industry, and they know they're really sharp at manipulating money and trading, things like that. And they come up to them and say, you're not working with us. And we're going to give you a great salary. Well, they may be ethical. They may have a heart and say, no, no, I don't own any part of that. Well, the next thing they're told is that, no, you will work with us. And if you choose not to, you'll die, and most likely your family. And it won't be pleasant. And it's not an idle threat. So if we're going to action this, they're going to action it. They need the best and brightest as well. They need salaries to add up with either families, the workers, medicine, medical care, afford housing. Here's something very important. And I know it seems insignificant. It's the money, the salaries that enable them to travel safely, securely, to and from work. I'll touch on that in just a moment. They also need protection. And it's not if it's when they're threatened for doing their jobs and doing them well. I can't stress that enough. Then lastly, and I'll touch on this in a moment as well, the aggressive all-out investigation, apprehension, prosecution, and confinement of those identified as being involved in the threats, assaults, and the killings. Very, very important. And I won't say which country it is. I'm not trying to demean a country. It applies to a lot of them actually. I was working with a unit, and this is a very, a unit doing very important work. And I was asking them about their salaries. And what I learned was, I mean, I was amazed, like, how do you live? How do you feed your families? How do you take care of the basic necessities? And then I was asking, well, how do you, because I noticed there's certain time, they're in certain time, they're out. How do you get to and from work? And the answer was, oh, taxi or buses. Not the good taxis, the ordinary taxis, the same ones that are compromised by the pandillas, or not Spanish, the gangs, the criminal gangs. And so what happens? They are very, very dangerous. The embassy tells us, do not ever get in those at all. But they have to use those. And you think, well, I hope nothing happens to them. Well, it does. And while I was down working in one country, one of the, I don't want to go into all the details, was assaulted. A woman was insulted, assaulted rather, gun to the head. And it went from bad to worse. And the poor thing was so afraid because she didn't have the money to live in a better area. So she lived among the very people that did this and knew she would confront them again at some point in time. And very little happened. So how do we expect those kind of people to be motivated to do the job, to stand up when they have to? It's tough. So there's some of the things that I think we have to keep in mind. But also here's another one. They need to have the money to maintain the facilities. Again, training, organizing, and equipment. We help them build facilities. Training facilities and equipment provided by the United States and other donor countries. And just to give you one more example, I could stand here all day and give you these. But I don't want to do that. I just want to give you a couple. I was working with a certain. And I call very elite unit of one country, their Federal Investigative Force. And a money laundering lead had been sent down by a special agent in the United States. And we were covering it. We were out in a rather bad section of that particular city. Spent several hours out there gathering information. And we came back in. The fellows were great. And they gave me a desk. And I got out my paper. And I started writing up by hand the report, basically surveillance report, and report of investigation. So they didn't have to. And it could be used for both of us. This was what we both saw. And as I'm doing that, the main fellows working with who, I mean, this guy's sharp, the whole unit was good. He came up to me and said, Rob, I'm sorry, but we have to go. And I looked at him. I said, sure, sure, no problem. I said, what's up? And he said, we just had it. And I can't remember the exact crime. A very horrific crime, it just occurred. And he said, it's not just one or two of this. The whole unit, we have to scramble. We have to get on this. And so I said, oh, no problem. So I start packing up my things. And as I'm watching, I'm not seeing what I would see as far as an investigative enforcement group in the United States, how they would act, how they would prepare if they're saddling up to go do battle, so to speak, and get on something. So I asked him, I said, well, where did this occur? And he told me, I'm thinking, it looks like at least 20 minute, 30 minute drive from here. I said, how are you getting there? And he looks down and goes, we're either going to have to take taxis, buses, or hitchhike. And I said, wait a minute, wait a minute here. It wasn't that long ago that I know the United States provided vehicles, good vehicles, enforcement vehicles. So where are they? And he said, come here. We walk to the window and look down. He said, there they are. He said, they're great vehicles. He said, but we don't have the money to maintain them. They're sitting inoperable in a fence scenario. And my gosh, we provide all this, but should not the country, should not they have the funding, the funds to maintain these vehicles? So next slide, please. One of the things you may be thinking, and I've had this pointed out to me many times or said to me, I should say, in speaking to different groups, is, oh, they're poor countries. They're unable to afford it. They can't do this. Oh. Well, I was in a conference just not too long ago, actually. And in the group, there were several CEOs of international businesses, many of which do business in Latin America. And one of the speakers made a statement and said, wealth is being created in Latin America. People are making a lot of money in Latin America. And his comments and views were echoed by others. Now, for those of us or those of you in the group that have lived and worked in Latin America in these countries, think back to what you saw with a lot of the business owners, and I'm not labeling every one of them, but so many of them. Where do they live? They live in palatial type houses and states, big walls around them, and almost like machine gun nests when you look at them. They have their own private security guard force protecting them. They're not relying on the police. They're vehicles or armored vehicles, top of the line armored vehicles. They're when they have illness, do they go to a local clinic? No, they send them to the United States for the best hospital there. It's a whole different thing. So you have to look at that and say, wait a minute. There is money there. There is people making money. So next thing. So now let's just talk about now and just refocus our attention for a moment on corruption and commercial tax evasion, which again, GFI, my hat's off to all of you for pointing all this out. But let's talk about an ongoing matter that's going on right now in Guatemala. I would say because of the makeup of this crowd, most of you are probably very familiar with this. If not, there's a massive customs fraud network that's been exposed in Guatemala called La Lina, or the line. Take two bribes, alleged to have taken bribes, reduced customs duties, making millions off the foregone government revenue. And one of the things you're going to point out in this slide there, the winnowing tax base, this is very important. The Lina networks, and this is from foreignpolicy.com, was pocketing $260,000 a week while the country's schools, hospitals, and police stations languished. Pretty bad when something's happening and you're calling desperately for the police and they're not coming. Or you can't get your child to the hospital. They don't have the medicine. Or your child is not getting an education. You know it much worse. They're being bullied and nothing can be done. And that's just one example. I think back to one of the cases I was involved in during my assignment to one of the embassies in a customs attesté office. It was the Alemán-Jerez investigation in Nicaragua. The amount of money stolen was incredible. And then I'd be up in the mountains of Hinotega, Matigalpa, and different other areas, poor areas, around Manawa. And you see people living in huts that are made of mud, basically. So much money was leaving the country. Next slide, please. And then we go to commercial tax evasion. Now this is from Hondurasweekly.com. And it pertains to 2011, but by no means, in my opinion, has it really changed that much. But it was revealed by Honduran government officials that 34 major companies, Honduras, reported total sale revenues of in US dollars, roughly 945 million, but paid no taxes. OK, the Honduran government lost. It was estimated approximately in US dollars, $13 million because of these firms. One of the statements was, we have to put a stop to this bleeding. So again, I ask you, is the money there? Are the security agencies now that I just mentioned, are they adequately funded? Next slide, please. This is something that's very, very tragic. December 2009, General Julian Gonzales, who at that time is retired Army General. At that time he was the anti-drug czar of Honduras. He was within, I think, two months of retirement. He was aggressively going after the cartels. He was aggressively going after the clandestine airfields where these planes were coming in with the shipments. And because he didn't play ball with them and because he didn't back off, he dropped his two daughters off at the school and as he was pulling away, two men on a motorcycle come up, got in the back of the submachine gun, 10 bullets, he was killed on the street. April 2013, prosecutor Orlan Chavez. And I talked to some of the folks that worked with him. They said he was excellent, a very good man. Chief of their anti-money laundering division, asset forfeiture of the organized crime division of their train general's office. Shot dead on the night until he was to Gapa. In his pickup truck, the same type, two men on a motorcycle. What he would do at night, one of the nights the week I understood he was told he taught at a local law school, came out again. They just completed enforcement action and that was the payback right there and sends the message, don't even think about doing this. And as I have in the little banner, whoops, the banner at the bottom, if you go back, it's reported that those responsible for both of those killings have yet to be identified, apprehended and prosecuted, okay. The last slide is, it's important to remember that the amount or a high percentage of the illicit financial flows are conducted through trade mispricing, again, trade fraud. And with that, one of the things I'd like to do, I'd like to just mention one of the bullets of the nine bullet recommendations by GFI, that being, and I concur with them, on boosting the customs enforcement ability of the respective country's customs services. And I'll keep in mind, many of those customs services don't have criminal investigative divisions. And so, first off, what I would recommend is, yes, you wanna boost them by creating such units, preferably stand alone, because let's face it, the people in charge of the customs units are generally appointed by the incoming president and their own people, and of course, they want them to do what they're gonna do, so preferably stand alone, but if not, within the customs service. Staff, more importantly, by quality criminal investigators, begin quality over quantity and provide them with the tools or certain tools that they need to be provided with in order to action this. What I would say, and just in closing, my thanks to GFI on bringing this threat to light, to our attention, and I would like to see the United States action this threat to the extent we can, perhaps in this proposed one billion dollar aid package that if it ever gets approved and goes, maybe dedicate some of this money to creating office's investigation and training, organizing, and equipment, giving them a running start, and also, I'd like to point out that there are many brave men and women, I worked with a lot of them, risking their lives on a daily basis, and they need, they need a fighting chances to survive, to in dealing with these transnational criminal organizations, when I say that, both the gangs, the ruthless gangs, and the cartels, and in doing so, decrease the levels of desperation at least the mass child migrations. Thank you. Thank you very much, John and Rob, and I was thinking, something very similar to your closing comments, the thing that really becomes very vivid to me is the courage that you and your colleagues have spent in so many instances, things we'll never know that you and your colleagues have been doing both in the United States, but especially abroad, to try to confront these types of behaviors directly, and there's a certain vicious, there's a real vicious circle here, I mean, you've already had indications of it in the comments today. There doesn't seem to be enough money for the infrastructure, for the rule of law, all the way through enforcement, vigilance, prosecution, et cetera, and it just feeds on itself in terms of that corrosive effect and gets worse and worse. So these are clearly issues of social justice. When I think about the work of GFI over these years, and one of the reasons I've been so proud of GFI, I look at the leadership of Raymond and the work of Dev and now Matt and Joe, taking data and making very good use of data and turning data into meaning. And when I think about the testimony of stories like this, and I've heard so many before from my years at KPMG and working in the forensic practice alongside intelligence, military special forces, and law enforcement agents, those are two sources of data to help us inform our consciences, to form and inform our consciences. And the key task now is to figure out the moral narrative. And I think Thomas has helped us do that very adroitly in his excellent presentation as well. It helps, it causes us to have to rethink a lot of the ways we approach development about the drug trade. It's not just don't say no, but we need to think seriously about the demand aspect here in our relationship with other nations. So there are a lot of things going on here. And as we enter the conversation, let's be mindful as well that we're gonna have a visitor in our city tomorrow who has been talking about precisely the interrelatedness of all of these issues as matters of social justice and someone from the Western Hemisphere, a Latin American Pope. It seems as we think about, I also teach business school at Georgetown. And I always, when I hear these stories like the ones you guys are telling, I keep thinking if these criminals would use 10% of this effort to be honest, without having to go through all these contortions, you'd think that they would be making a fair amount of money anyway. There's a certain sense economists talk about transaction costs. And one would think that it takes so much effort to try to structure this trade-based money laundering that it simply wouldn't be worth the effort. And maybe at the level of the particular value of the things that they're moving back and forth, that's not the issue. I guess what I was struck with, John, and perhaps you could comment on this, at the beginning, you were giving all of those examples of just outrageous pricing. It was like stories we've heard over the years with Pentagon, procurement, et cetera. And you said these are actual things that are happening. What is going on on this side of the border if we are the best trained, best equipped in terms of customs, in terms of our priorities in the political process? Because these are things we can control in terms of where Congress is spending its money in terms of funding. So perhaps you could comment on the decisions in the political process here in terms of enforcement. Well, I think your point is well taken. And oftentimes, when I go overseas and I'll give a much lengthier presentation, go into a lot of detail about what the United States is able to do and what we're not able to do. First of all, I want to say the United States, in my opinion, we probably have the best customs service in the world. I think we have the most robust law enforcement in the world. We certainly have the most resources to port this problem than any other country if we had the political will to do so. But all these things that we put up there and more, this is what's going on in the United States. We have all those benefits. But when I go out and talk to the developing world, they don't have those advantages. And if this is going on in the United States, what do you think is happening in the developing world? This many, many times more. So I think what we have to do is kind of the things Rob was talking about, to reorder our priorities a little bit, support them when we can. But there's also a lack of capacity issue, lack of awareness. We have to start taking these first steps. And the other thing I would just like to add very quickly is we're very fortunate, and I think, again, GFI has paved the way in a lot of this, that we have more data than ever before. We have more analytics than ever before. We are on the verge of being able to have more transparency in international trade than ever before. So we have to get to that next level. And thank you, John. And Rob, there's that expression in politics, where's the outreach? And we think about our own country, and it must be heartbreaking, the kinds of things that you're describing, you're seeing overseas, and you're appearing in an event like this, and what more can we do as we think about the resources of GFI and the network here in this room to get these kinds of stories out, and so that people ask their own members of Congress, it doesn't sound very exotic or dramatic, but we need more money for customs interdiction for things like this. We shouldn't be focusing on immigration, and not that that's unimportant, but this is a very serious issue, and how can we begin to motivate the issue, and what might be things we could do internally with our political process? Oh, that's a very good question. Let me just say this, and it complements what John was just saying. Those of us who worked customs fraud type cases during our careers, and let me preface it by saying, a lot of times you had just about drag agents into that group, kicking the string, because most agents are type A personality types. They want to be doing the real exciting stuff, kicking indoors, working heroin, weapons, smuggling cases, and they work a fraud case all month, gosh. And I was one of the anomalies I asked to go, and so you have those kind of people, and you don't have enough of those, but the other part of it is the amount of funding that's dedicated to the Custom Service for this, and not too long ago I had a conversation with an individual business man who had met with several other CEOs of major companies, and they made the statement, and they were talking about something very similar, and they made the statement that, well, why isn't more being done? And the answer that came out was, because the businesses don't want it being done, and we used to hear businessmen joke from time to time, and John I'm sure was around a lot of times, and they didn't know who we were, and they were joking around us, especially import, export, community, and they would basically be saying, oh yeah, customs fraud is a national pastime in this industry, and I'm sadly for them, there's many good ones and honest ones, but for a lot of them it is. They're gonna cheat whenever they can, and that's why you have to have an enforcement arm, and you have to staff them with really aggressive agents that approach it like a drug case and a gun case, not just like an ordinary fraud case, and give them the tools. Okay, thank you gentlemen. Joe, is it possible to get at least one question from the audience, is that okay? Okay, because I do wanna, we don't have a particularly long session, but we have two simply wonderful presenters here. If I could get, if you could briefly identify yourself and your affiliation, and just ask, put it in the form of a question. Hi, I'm James. Here comes the microphone. I'm sorry. Hi, my question is, thanks to all of you for a terrific presentation. The latest developments in Guatemala sound quite promising, particularly with the UN involvement and the independent agency. I was astonished, I know a little bit about Guatemala too, I was astonished at the results, I wonder if you could talk a little bit about that. Thank you very much sir. Okay, well keep in mind now, who conducted this investigation? It was that UN organization. Was it the Guatemalan Custom Service? I think not the director of Guatemalan Customs, I found the report I read the other day, is accurate, was just arrested as being a conspirator in that La Lina, okay? And so again, the Custom Services in a lot of these countries are really in, John, you know, police chime in. What you find is they're, I'm not saying it's the derogatory manner, but a little more than revenue collection agencies and really not very good at that, even at that. And it's done, my opinion, by design. So much money being made by businessmen, especially those that wanna get money out, listed financial flows out. They don't want anything changed. And so there has to be a revamping and I would love to see that revamping take place in all the countries. And believe me, I've worked with some people who I have the utmost admiration for in these countries. They are honest, honest, deep into the heart, honest. And they're literally risking their lives every day. And when we find those, we really need to support them. Okay, thank you. And John? I would just like to echo what Rob said. The U.S. Customs Service now, ICE Immigration Customs Enforcement, Homeland Security Investigations, different than most custom services around the world. Most custom services around the world are involved with old fashioned inspection and control. That's all they want. Collect the taxes and the tariffs, duties, all this type of stuff. If they see something like we just discussed, A, they probably don't recognize it for what it is and B, they don't investigate. And if they possibly do investigate, they pass it off to a country's financial police of some sort. They generally don't have the expertise. They generally don't have the will to do it so these things don't get worked. So it's a vicious cycle. Okay, thank you, gentlemen. Is that, can we do one more or are we? Okay, thank you. Thank you very much, Christie. Yes, sir, please. And if you've got to identify yourself. Sure, my name's Henry Balani. John, thanks for your presentation. Great, by the way. One of, I think one of the things that we need to think about when we look at TBML is one of the principal actors who haven't been actually mentioned during our discussion. And that's banks, right? Banks are essentially, you follow the money and you look at where the year flows in and so forth. It's really tying TBML to AML in terms of rules and regulations and so forth. We hear a lot about these various banks getting fined for AML transgressions and violations and so on. What in your opinion and from your perspective is how should banks play, what roles should banks play in the eradication of TBML? Basically it goes down to know your customer, know your customer and your customer's customer, okay? And be aggressive in recognizing trade-based money laundering in all its guises, okay? Traditional trade-based money laundering what we were talking about and it's links to underground financial systems such as the Chinese underground flying money systems or Huala or whatever it is. Banks get involved a lot with trade financing, for example, okay? They see data. If they see something that is suspicious while suspicious activity report. I am heartened because trade-based money laundering is getting increasing attention not only by banks but money service businesses. They recognize it for what it is. There has been some thought within the financial action task force that sets the guidelines for anti-money laundering, counter-terrorism, finance, programs and policies around the world. Some indication that they are focusing more and more now on trade-based money laundering issues and something I do wanna mention, I'm putting a plug in, I just wrote a book called trade-based money laundering the next frontier in international money laundering enforcement, I wrote it for bank compliance officers. It's due out in November. Go ahead, Rob. If I had one point to this. One of the things, reasons that trade-based money laundering is not just sustaining but it's flourishing is that it's so difficult to detect. And once you detect it, it's difficult to investigate it. And then once you get it investigated, it's sometimes it's very difficult even to get it before a federal prosecutor. You know, their eyes get glassy because it's so complicated a lot of times. So with that, keep that in mind. Let's go back, take a step back to the banks, okay? Well, I'm sad to say that even though there's been great strides, there's a lot of banks that really don't want their compliance officers finding things. And if you go and survey a lot of the anti-money laundering investigators you could call them or whatever, ask them how many on their staff are former customs inspectors? How many have the experience that understand import, export, that understand documents, that understand valuation, understand the type of things, the little minute, the things that the bad guys exploit and exploit well. And I bet you're gonna find very few of any. And so we need those kind of people. And thank you, Rob. One of the things I noticed many years ago is if you put a bunch of AML, BSA officers from global banks in a room together, they very quickly will identify and interact, identify with each other much more than with their own institutions. There's a sort of culture within the institution there. One other bright spot possibly that just happened about 10 days ago, we've noticed a number of high level prosecutions of banks over the last several years, including over AML related issues. And yet many of us have been very disappointed not to see individuals prosecuted. Sally Yates, the deputy attorney general, just issued what I guess will now be called the Yates memo, going back all the way to the Thompson memo around 2003, but just about every deputy attorney general will at some stage issue a memo with instructions to the US attorneys in the field. And this one, it made news because attorney general Lynch has been very, very strident about going after individuals. And if banks or any companies, but including banks, want to get credit for cooperating with the government in terms of an investigation, they need to name names and this wall of secrecy, the moral hazard, et cetera, needs to end. So at least that's the most recent, that's about 10 days old in terms of this guidance to the US attorneys in the field. We do need to conclude the session. A couple of years ago, Pope Francis talked about the problem of the globalization of indifference, the fact that people around the world simply don't care about these issues. They either don't know about them or if they do, they don't care. And these affect everything about the quality of life, the sense of the common good, about income inequality, the ability to live in a civil and stable society. And what he has exhorted us to this year with the most recent encyclical is to move to a globalization of hope, which means really doing the kinds of things that global financial integrity is doing through this research and will continue to do and to continue to engage with folks like Rob and John and other specialists in the field. So I hope that we will take this opportunity this week to be talking very seriously and openly about all of these issues of global justice. It's not just about the economy or it's not just about ecology and rent extractions. All of this is related and all of it has to do with justice. And I'll just conclude that with regard to the comment that we see in three of the gospels that there will always be poor among us. What Jesus was commenting on was not their material state of poverty, but their openness to God. And so that we don't make that a crutch or people have over the centuries. And so even in a secular sense, what that calls upon us as a responsibility to pay attention to the least well off around the world and to make the quality of their lives really the standard, the things that we're able to do and we're not doing, the very things that my colleague, my brother philosopher Thomas was talking about. So I want to thank our panelists for their service to our nation. I want to thank them for their continuing work. I want to thank them for being here and thank you for your conversation. And I'm hoping they'll be around later in the reception to continue the conversation. Thank you very much. Thank you. Thank you. Thank you very much. Thank you so much. Thank you, thank you. Yeah, I want to echo Les's thanks to John and Rob. Thank you very much for a very interesting panel. We're going to take a very quick coffee break. We're going to reconvene at 2.15. Thanks.