It is sometimes said, in the money-laundering field, that “cash is king.” It may be more appropriate to say that cash is a Sisyphean burden that many professional criminals must bear (or find professional money launderers to bear for them) in order to realize long-term benefits of their criminality. Street-level transactions in crimes such as drug trafficking, arms sales, and human trafficking, generate tremendous volumes of smaller-denomination bills that must be exchanged for higher-denomination bills. Even after exchange, large masses of those higher-denomination bills cannot easily be deposited in banks attentive to money laundering risks. As a result, major criminal operations remain dependent on bulk cash smuggling networks to begin the laundering process in less attentive jurisdictions.
A recent criminal prosecution shows the extent to which bulk cash transportation remains an essential service in money laundering operations. On July 28, the Isleworth Crown Court in London sentenced Abdulla Mohammed Ali Bin Beyat Alfalasi, an Emirati national, to nine years’ and seven months’ imprisonment, after he pleaded guilty to removing criminal property from England and Wales in violation of section 327(1) of the Proceeds of Crime Act. The Crown Prosecution Service (CPS) stated that Alfalasi arranged a service designed to transport cash that constituted criminal proceeds of crime out of England and Wales. According to the National Crime Agency, which investigated the operation, first Alfalasi, and then a number of “couriers” whom he recruited, transported a total of £104 million in cash on at least 83 occasions between November 2019 and October 2020.
The NCA stated that Alfalasi’s operation collected cash from criminal groups around the United Kingdom and took it to counting houses, usually rented apartments in Central London. Alfalasi’s money laundering method consisted of four steps: (1) filling suitcases each with around £500,000 in cash; (2) spraying each suitcase “with coffee or air fresheners in an effort to prevent them being found by Border Force detection dogs”; (3) Alfalasi or a courier flying business class to Dubai, which allowed increased baggage allowance, and checking in as late as possible to avoid detection of the cash; and (4) declaring the cash on arrival, supported by a letter from a company that Alfalasi owned, saying that the couriers were authorized to carry that amount of cash. Alfalasi set up the company, Omnivest Gold Trading LLC, specifically to legitimize the funds.
At the time of Alfalasi’s arrest, officers of the National Crime Agency recovered three phones that contained numerous messages between him and others that discussed the collection, consolidation, and movement of the cash. According to the CPS, the phones “also contained pictures of suitcases filled with cash, a read-out from a money counting machine and an itinerary for one courier’s journey, with Alfalasi checking in at every stage of the process to ensure the money was delivered safely to Dubai. Credit cards were also recovered from Alfalasi’s home which had been used to buy the flight tickets.”
The Times reported that one of Alfalasi’s couriers “travelled from Heathrow to Dubai three times in August and September 2020, checking in 19 suitcases with a combined weight of almost half a tonne. She returned a few days after each trip with the same baggage weighing significantly less each time.” To date, four of Alfalasi’s couriers reportedly have been convicted as part of Alfalasi’s operation and others remain under investigation. The CPS deemed the case one of the largest money laundering cases that it has ever prosecuted.
This set of prosecutions shows why both customs authorities and airlines need to maintain vigilance in watching for bulk cash-smuggling operations. As the Alfalasi case shows, experienced money launderers can be counted on to try to exploit situations in which that vigilance can weaken – such as the temptation to clear passengers and luggage quickly when departures are imminent. Moreover, that temptation is likely to increase in the near term, as international air travel continues to grow apace despite rising ticket prices. Bulk cash-smuggling launderers will readily bear those costs so long as they can successfully run the gauntlet and deposit their customers’ cash in jurisdictions that fail to implement effective anti-money laundering measures.