Following the money trail: Implications for regional security

The concern about the consequences of money laundering on our region’s economy is growing, as is the illicit money being washed daily in our countries. Here is some basic information about this crime, which is already acquiring a destructive corrupting power on our societies and our weak democracies.

Money laundering is a criminal activity that goes almost unnoticed but has a lethal impact on our societies and our institutionality: the legitimization of assets coming from illegal activities would seem to be invisible to the common citizen and only important for those authorities responsible for supervising banks and overseeing monetary stability. Primary attention always concentrates on violent deaths, but the issue of money laundering or legitimization of assets is seldom dealt with in the region.

Laundering money is an operation that per se does not yield blood, corpses or strident violent deeds. But it has a tremendous corrupting power in our societies and institutions. The preceding crimes that generate the need to launder their gains in our productive and financial systems, as well as the number of crimes that result from those actions, when they create networks and processes and laundering enterprises that corrupt a large diversity of activities and public and private institutions, should be enough to have this activity in the sights of our national and regional efforts to strengthen the prevention and prosecution of crime. Moreover, we are small countries with fragile institutions and security systems, suffering from a constant drain of public resources to meet the fight against crime and citizen insecurity.

The temptation of
“practical realism”

Until recently, we didn’t produce any drugs in Central America. They were mainly generated in the Andean countries—only recently were some signs detected of the existence of small clandestine laboratories for the production of synthetic drugs in three of the Central American countries. And the major market is to the north. But our public budgets are “skewed” and augmented for the fight against and control of drug trafficking, taking away important resources from other development issues, and even other citizen security issues that are important for us.

In the face of these distortions and citizens’ perception of the inefficiencies in the fight to secure their security, it is possible to succumb to the temptations of practical realism, to think that it might be politically “more reasonable” to implement public actions with a media impact, ones that public opinion could interpret as examples that the State is doing what it can, when in practice it seems resigned to leave things as they are. This is added to the perception that some of the institutional structures called into this fight, precisely justice, security and the financial system, which are the ones that should guarantee public security and the rule of law, are’t making the necessary efforts.

Strike against laundering “where it hurts most”

Falling into these temptations of practical realism might put the State on the path of a very delicate and complex gestation and development of the “Mask-State” or “Shell-State”: a formal public institutionality that actually covers up for high levels of impunity. But on the other hand, setting one’s sights and developing skills in the field of money laundering from illegal activities requires concentrating efforts where it hits those transnational criminal organizations of any kind the harderst: in the possibility of enjoying their gains once they have been legitimized. Here some efficient actions can be implemented to prevent illegality and the infection of our economies and political systems.

Nonetheless, we had enormous difficulties gathering reliable and publicly verifiable information on concrete facts directly related to money laundering for this paper, mking it extremely hard to grasp the size and scope of these activities as well as their real impact on the legitimate universe of our economies. The authorities consulted shared official documents (the current legislation and regulatory aspects) and in private even shared their views, assessments and suggestions about how to improve. But the banking institutions consulted in all the countries were reluctant to provide concrete information that could be cited. The institutions that make up laRed wish to thank all those who collaborated to generate the inputs for the analysis of this study, including those that cannot be mentioned as sources of information.

A very old crime

The history of money laundering, just as other national or global economic crimes, is as ancient as the history of society itself. It goes back as far as the moment money began to be minted and in fact, the crimes with money (both forfeiting and laundering) have existed even before money as we know it today existed, through the custom or usage of practices to disguise income from illegal activities when usury was declared a crime.

Nevertheless, the concept of “laundering” per se began to be used in the 1920s in the United States, when the Mafia that was trafficking in alcoholic beverages created a series of laundries to hide the illegal origin of the money made off their criminal activities. The mechanism they used was to present the earnings from illegal activities—extortions, prostitution and trafficking of weapons and alcoholic beverages—as coming from the business of cleaning clothes, mixing it with the laundry income. By making it impossible to distinguish which money came from a legal activity, they managed to circumvent the authorities for a long time.

Money laundering on a
grander scale began with drugs

In the 1970s, money laundering became associated with drug trafficking, when large amounts of money were deposited in banks in the United States, without control, as a product of the marketing of drugs. “The first time the expression was used judicially was 1982, with the seizure of bleached money allegedly originating from the smuggling of cocaine,” according to Bruno Tondini.

With the upsurge of drug trafficking, money laundering rose to a higher level. Since the sale of drugs takes place with low denomination bills, the amounts of money are so large that they literally exceed the weight of the trafficked drug. It is important to point out that the logic of deregulating the global financial system, as well as interconnection and the ability to carry out global financial transactions over the past 20 years, which mainly originated in the developed countries, have resulted in increased facilities to launder money. Banking secrecy, difficulties involved in information exchanges in real time and the practice of establishing tax havens (or shadowy jurisdictions) worsen the magnitude of the problem.

Definition of this crime

The recycling of money has been defined according to the characteristics of each country and its respective legislation. In most concepts, however, it is considered a crime in itself, distinguished from the crimes that originated it, and has therefore been assigned independent treatment by the criminal justice system.

Dr. Guillermo Ritcher, president of the Commission of Government, National Police and anti-Drugs Action of the Congress of Bolivia, defines money laundering as the selfish clandestine procedure by which the funds or earnings coming from illegal activities such as weapons; prostitution; trafficking of women; common crime; economic, political and related crimes; contraband; tax evasion and drug trafficking are recycled to the normal circuit of capitals or goods then used with heterogeneous and tactically skilled cunning.

The “Reference Guide against laundering of assets and the fight against the financing of terrorism” refers to the laundering of assets as a basically simple concept: “It is a process through which the earnings obtained through a criminal activity are covert in order to hide their illegal origin. Basically, the laundering of assets covers the earnings obtained from goods of a criminal origin rather than from the goods per se.”

The Financial Action Task Force (FATF, but best known as GAFI for its French initials) is an inter-governmental institution created in 1989 by the G7, the purpose of which is to develop policies that help combat money laundering and financing of terrorism. It points out that the crimes producing considerable gains that are later legitimized are trafficking of persons for sexual exploitation, prostitution, marriage or forced labor; illegal adoptions; trafficking of migrants; marketing of boys, girls and human organs; trade and trafficking of weapons: drug trafficking and its wholesale or retail distribution; the manufacture of precursors; smuggling and corruption.

Washing = placing-hiding-investing

To understand the complexity of the legitimization process, it is necessary to know the different phases or stages of the laundering or bleaching of capitals on which there is agreement among those who study the issue.

The stages of money laundering are:
- Placement. It refers to placing the funds of illegal origin in the financial system in various ways: opening bank accounts, currenty transactions and purchase of financial instruments, among others.

- Hiding. Called stratification, collation or diversification by some theoreticians. The objective of this stage is to zoom out the illegal gains from their criminal source. The methods used in this stage are:

- Money converted into instruments of payment through the purchase of securities, transfers between jurisdictions or “payments” made for acquired goods or services.

- Electronic transfer of funds (currently the most used and efficient method). At the end of this stage, “the legitimizer” has separated the money from its illegal origin and erased any accounting traces of that origin, covering it by means of complicated and diverse financial transactions.

- Integration or investment. In this stage, the money becomes integrated into the legitimate economy and the now “clean money” is injected into the national and international financial systems. At this point, the objective is to invest the clean money in various forms of the chosen economy/ies; once it has been integrated into a particular financial system, these gains appear to be legal, melting and blending with the rest of the legal activities of the infiltrated economy.

Money laundering just in the Cayman Islands

Due to the characteristics of the laundering of assets, no accurate statistics can be made that give an exact account of the magnitude of the problem at the world level because the persons and organizations dedicated to illegal activities avoid being detected and do not leave public records of their transactions.

Calvin Wilson, director of GAFIC (Caribbean GAFI), told a TV program in Venezuela during GAFIC’s 34th Plenary Meeting and the 18th Meeting of its Council of Ministers that the world’s money laundering just in the Caribbean’s Cayman Islands amounts to US$500 billion per year.

In this regard, Gabriel Gómez, a Guatemalan Supreme Court Justice, pointed out that the three major crimes that precede the laundering of assets in the world, and particularly in Latin America, are the sale of drugs, corruption of public authorities and tax evasion.

Most frequent typologies in Latin America

The several methods criminals use to legitimize assets generated through illegal activities depend upon the characteristics of each country. In addition, these methods, which are known legally as typologies, change with time according to the measures the States implement to deter and tackle the problem. In this regard, both GAFI and the regional groups are constantly drafting and systematically updating technical tabs on money laundering typologies.

The Egmont Group, an international umbrella organization made up of governmental Financial Intelligence Units, is creating an international network to exchange information, knowledge and technology in order to fight against the laundering of assets and financing of terrorism; it has also made a broad compilation of cases to share with its members.

And the Financial Action Task Force of South America (GAFISUD), which groups together Argentina, Bolivia, Brazil, Chile, Colombia, Ecuador, Paraguay, Peru, Uruguay, Mexico, Costa Rica and Panama, created a support tool in 2010 to contribute to the implementation, adjustment and improvement of controls in tackling money laundering; it contains the typologies used most frequently in Latin American countries, among which are:

- Laundering of funds coming from defrauding public funds,
- Laundering of funds through casinos,
- Exploitation and marketing of gold to finance terrorism,
- Utilization of financial products of cooperative societies and mutual associations,
- Declared income of foreign currency for exchange operations,
- Transport of currency across borders,
- Creation of investment societies,
- Clandestine transportation of precious metals across borders,
- Utilization of front companies to support the activities of laundering assets (tax havens),
- Use of call centers and online businesses to mobilize and hide funds,
- Irregular utilization of pension funds,
- Importation of raw materials and machinery, and
- Utilization of nonprofit entities that provide education services.

International standard-issuing organizations

The existence of more flexible transfer mechanisms in an interconnected world, together with the recognition that drug trafficking is a worldwide problem, is eliciting multilateral collaboration efforts to deal with it.
The United Nations was the first to establish a universal basis of actions to combat the laundering of assets and juridical instruments through which it has initiated the following actions:

- The Vienna Convention. Through its program for drug control, it began with the international agreement “United Nations convention against illegal trafficking of narcotic drugs and psychotropic substances,” passed in 1988 and put into force in 1990. It was signed by 169 countries.

- The Palermo Convention. This is the UN’s “International Convention against transnational organized crime,” which broadens the range of crimes underlying the laundering of assets. It was signed by 147 countries and ratified by 83, and entered into force in 2003.

GAFI, a sui generis organization, is another multilateral collaboration effort. It accepts members by invitation only, not by compliance with requirements, as is the case in other international organizations. As of June 2012, it was made up of 32 countries of which three are in Latin America (México, Brazil and Argentina). This group certifies the international standards by which the rest of the countries in the world are rated. On this basis, “black lists” are drafted and sanctions imposed on nations that do not comply with the established standard.

GAFI’s three main functions with respect to the laundering of assets are to oversee the progress of the members in applying measures against the laundering of assets; analyze and issue reports on the trends, techniques and countermeasures of the laundering of assets; and promote the approval and application of the GAFI standards against the laundering of assets throughout the world.

The instruments through which GAFI makes its functions effective are mainly its 40 recommendations on the laundering of assets, which are a series of principles for the countries to act on in their fight against the laundering of assets; supervision of the progress of members, which takes place in two stages: self-evaluation and mutual evaluation; reports on trends and techniques of laundering assets; and lists of Non-Cooperating Countries and Territories.

Since GAFI can only give sanctions to its members and since its main objective is to certify standards for international compliance, it uses this certifiction instrument and its reputation to get countries to implement the 40 recommendations on money laundering and those on financing terrorism.

Central America:
Vulnerable borders

Central America’s geopolitical location and the C-4 Regional Agreement on procedures for extending a single Central American visa, which enables free transit for persons and goods without any immigration control, have the negative effect of making the borders more vulnerable and facilitating transnational marketing of illegal products, persons, psychotropic substances and contraband goods.

Covered by this agreement and the weakness of controls, crime easily passes across the borders of the Central American nations and has a domino effect in the isthmus, since what happens in one State affects its neighbors. This explains the intra-regional displacement of the interrelated organized crime networks when prosecution increases in any country of the region.

The hardening of the financial regulations and strengthening of actions for a direct fight against drug trafficking in Mexico have caused the laundering activities to move into Central America. This calls for legal reforms, the strengthening of institutional prevention mechanisms for money laundering and of the judicial system to prosecute and sanction those responsible, and for a strong pressure against criminal and drug trafficking organizations by the States located in the geographic ends of Central America: Mexico to the North and Colombia to the south.

Such is the case of Guatemala, whose weakness might be evidence of the increase in the presence of these groups in the region. As a 2011 report by laRed indicates, “The activities of organized crime have evolved in such a way that they go beyond the idea that the region is a bridge or a warehouse,” turning it into a service station that drug traffickers and organized crime use to stock up and guarantee shipment of their merchandise to the United States of America. The traffickers have adequate conditions for the return of the earnings that illegal activities generate.

Lack of harmonized legislation

Concerned about the multiplicity and expansion of the mechanisms for legitimizing of capitals and their consequences, the Central American countries have adopted a series of commitments following the ratification of international conventions that regulate the issue (the Vienna and Palermo Conventions).

In conformity with these conventions, the States must update their internal legislation according to the provisions contained in them. In this sense, important progress has taken place in the enactment of internal legislation, especially of a criminal nature since the crime of legitimization of capitals has been typified and other criminal conduct such as corruption, abuse of authority, illicit enrichment and influence peddling has been added.

Some advances can also be identified in the criminal processing legislation; some countries have special investigation techniques that are adequate for investigating and prosecuting this type of crimes as well as tax regulations to prevent contraband, tax evasion/elusion and money launder¬ing. But the fact that a certain type of legislation exists only in some countries and not in others is perhaps the greatest difficulty in the efforts to efficiently deal with this problem.

Despite the legislative progress taking place in the region’s countries, they show a lack of legislative uniformity in the regional level that explains why their scope is uneven. Thus, for example, in El Salvador the related crimes are placed among those that go against the economic order, while in Costa Rica they are in the category of crimes against the administration of justice. This makes it difficult to have a harmonized regional judicial interpretation.

Another point to be considered is the importance of distinguishing between the crime of legitimization of capitals and tax evasion. The difference is in the origin of the operations, as well as in their end purpose: tax evasion originates from legally acquired income that one tries to hide in order to avoid paying taxes, while in the legitimization of capitals the opposite occurs, it is based on income acquired through illegal means that is made to appear as legal.

These difficulties become worse if we consider that in some countries of the region, other conduct intimately related to the legitimization of capitals has not yet been regulated. These include illicit enrichment or criminal responsibility of employees and directors of banking, financial and controlling institutions that facilitate or hide information regarding these activities.

A problem for democracy

Central American economic integration calls for a flow in the financial systems for the transit of merchandise, but such streamlining also promotes the movement of illegal flows. This implies reconciling the interests of Central American integration with the need to reduce or preferrably halt these illegal activities, so as to encourage legitimate national and foreign investment in activities that contribute to the region’s economic and social development.

The penetration of illegal capitals into the formal and informal economies of the countries as well as into their institutionality has been denounced since the past decade. There is also progressive social consent for that presence and utilization, particularly when these flows respond to the basic needs of communities, which the State has not succeeded in meeting. All these are growing problems in the region. Since the illegal trafficking of resources generates considerable financial yields and large fortunes, it enables transnational criminal organizations to invade, contaminate and corrupt the structures of public administration, legal commercial and financial activities and society in all their levels. The effects for the Central American region are of a multi-cause nature and impact on the micro and macro economy, governance and democracy.

For Gary S. Becker, Nobel Memorial Prize winner in Economic Sciences, criminality contributes to poverty and slow development when it imposes greater overhead costs to businesses and households, thus causing a negative impact on their economy. At the same time, he states that the high rates of criminality—which involves not only crimes against life, but also a broader conception of crime—are related to the population’s low income and corruption in complying with contracts and regulations. These causal relations become vicious circles that are difficult to break up. The Central American countries show the relation mentioned by Becker; in conformity with Transparency International’s 2010 Perception Index, Guatemala, Nicaragua and Honduras are among the Latin American countries with the highest indexes of corruption and the largest number of homicides, although Nicaragua has up to now been below the regional statistics on criminality. Nicaraguan security experts, however, doubt the figures recorded by the authorities because they do not include all murders, parricides and femicides, thereby estimating that these data are below the real figures.

Based on information from Central America’s financial and banking systems, the largest source of illegal assets is corruption, an illegal act that undermines governance and causes decomposition and demolition of its democratic systems. This in turn gives way to poor governance and weak democracies, and at the same time benefits the market conditions and economy of crime.

Because of all these factors, the impact of money laundering in the region is different from what it means for other countries: a problem of governance and democracy, not one of tax evasion. The power of illegal money is capable of buying judicial decisions, advocating the course of legislative agendas, acquiring protection for its goods and services, diverting the direction of public resources for its own benefit and acquiring political power by financing political parties.

Organized crime and drug trafficking hamper the normal development of the daily economic and traditional activities, especially in rural areas and provincial urban areas, because such operations are usually carried out in a framework of violence that generates insecurity and anxiety in the populations. At the same time, it induces the abandonment of activities that are usually less profitable. The societies or enterprises utilized to launder money can also be used to control the industries and economic activities of some sectors, artificially distorting the prices of goods and services.

Difficulties in measuring the crime

Organized crime and drug trafficking take advantage of the situation of poverty and the lack of employment opportunities inherent to the provincial communities, incorporating people into their activities in exchange for earning amounts of money that go beyond what they could earn if employed in legal tasks.
The difficulties in the level of added value for economic transactions are in the near impossibility of measuring the impact they generate on both on the flow of production volumes and the measurements of their value due to the underground nature of their operations. However, through various methodologies, among them entrepreneurial surveys, the contribution of each of the sectors that make up the gross domestic product (GDP) is determined; there has been the presumption that livestock and construction activities might be receiving and covering up investments of resources of dubious origin.

When reconciling the balance of payments at the close of the corresponding fiscal year, statistical discrepancies appear that are recorded in “Errors and Omissions,” a catch-all category to account for operations that for various reasons are not annotated in the official statistics. This account typically includes operations such as differences caused by the disparity between the criterion utilized to value transactions, for example Guatemalan exports to the United States of America that are written at FOB (Free on Board, which refers to purchase and sale operations where the the merchandise is transportated by ships without shipping charges), while in the country of destination they are valued at CIF (which includes the full value of insurance and transportation), thus generating an uncontrolled difference.

Another example is differences regarding the date on which a good is exported and the date it arrives at its final destination, which results in the values being registered at different times, causing differences in the collection of data. This could also happen with family remittances delivered personally by a relative traveling to his community and thus not registered in the banking transactions. Likewise, it is general knowledge that contraband merchandise goes in and out across country borders in the region and other neighboring countries on which not only are duties not paid but no statistical record remains about its volume and value.

While these accounting difficulties exist, a World Bank study estimates that 90% of the cocaine that arrives in the United States goes through the Central American corridor. It also points out that the related financial flows are enor¬mous and the added value of the cocaine flow through the Central American corridor might reach 5% of the regional GDP. This percentage could even be higher if one were to include the traffic originated by other illegal operations that use the corridor. For example, it is unofficially estimated that for Guatemala, this percentage might be around 7.7% of its GDP.

A destructive corrupting power

Each of the countries of the region on its own can hardly deal with the phenomenon of organized crime and drug trafficking. The experiences of other countries that have confronted these phenomena in an armed struggle with economic, technological and specialized human resources have only been able to dim the phenomenon but not eradicate it or prevent either the bloodshed of innocent persons or the insecurity in the affected areas.

Money laundering and its preceding crimes are a technical problem not only of the specialized entities in banking supervision; they are directly associated with transnational criminal schemes as well as problems of corruption and impunity in the Central American States, and therefore affect democratic coexistence in a rule of law, as well as our countries’ governance.

Money laundering and associated crimes, both by those who need to legitimize the profits of their own illegal operations, and by the public and private structures that accept them, have a corrupting power that demolishes our societies and our institutions. While an activity that per se is not deemed to be directly associated with blood crimes and violence, we must not ignore the fact that it is a key link in the criminal chain, both for the preceding crimes that require laundering and for the multiplication of later activities that are against the law.

Corruptors and corrupted become agents who infect and denature our political systems and our citizen coexistence. Combatting money laundering is thus one of the key pieces— albeit not the only one—in the confrontation with transnational criminal activities, as well as in the efforts to strengthen transparency, the rule of law and democratic participation.

We need regional and
international cooperation

Money laundering and its preceding crimes, such as drug trafficking, organized crime, corruption and terrorism, are a global problem, therefore they require an integrated and comprehensive regional vision. These crimes are no longer local phenomena that compromise citizens’ peace and security only in a given country; they have become a global problem that puts at risk the stability of nations and entire regions.

In view of this danger, Central America must work with an integrated comprehensive vision not only to combat these signs of transnational organized crime but also to articulate their prevention in an integrated manner. The national efforts to which each State and society must commit themselves must be combined with an increasingly more coordinated regional effort. Central America needs to strengthen its cooperation intra-regionally and with the international community.

Central America has ratified the main international instruments adopted by the International Community in the framework of the United Nations, the Organization of American States, and the regional arena on the issue of drug trafficking, organized crime, terrorism, funding for terrorism, corruption and money laundering, as well as mutual juridical assistance on criminal issues. Its countries are members of GAFIC. Nevertheless it needs to deepen the cooperation and collaboration of its entities in the fight against these crimes, and in particular must coordinate actions related to prevention, prosecution and punishment of money laundering throughout its territory, as well as in the businesses and financial and non-financial entities.

For this type of task, Central America’s geographical borders: of Darien, Panama, with Colombia and of Petén, Guatemala, with Mexico must be transnationally reconfigured, as has already occurred with trade, finances or digital information.

Central America needs to harmonize the information that will enable it to follow up on suspicious transactions. It also needs to adequately coordinate and harmonize the implementation of efficient measures of diligence on clients, as well as maintain a record of requisites of the regulated financial entities and other non-regulated entities. Above all, it must coordinate the implementation of an adequate program of monitoring and prevention of money laundering throughout the regional financial sector, ensuring that its Financial Intelligence Units can work in coordination to follow up on operations suspected of money laundering in the region.

Likewise, Central America needs to harmonize the current legislation to increase its capacity to both protect legitimate trans-border economic activities and be more efficient in preventing and prosecuting transnational criminal activities.

One of the major verifications of this study is the enormous disparity in legislations of each of the Central American countries, ranging from the characterization of what is considered a crime in each country to its level of seriousness and disparity of both the penalties and the attributions and competence of the various institutions and the capacity and extent of their intervention to prevent, prosecute and punish these illegal activities. Furthermore, Central America needs to coordinate and harmonize its corresponding legislation as well as inter-institutional coordination within each country and regionally.

Not just in the banks but
in the whole economy

Central America must realize that it is not enough to make the banks safe from money laundering; it is also necessary to prevent the risks of money laundering activities in the rest of the national economy. To the extent that important individuals, both financial and non-financial businesses and sectors at high risk continue to work without adopting any program to prevent money laundering or blanching of assets,they will generate greater risks of infection for the regional economy and its financial system.

Of special importance are the financial or related companies that do not have a supervised prevention program, such as savings and loan cooperatives, micro-financing associations or societies, money remittances companies, currency exchange places, pawn shops, casinos and gaming salons. Making progress in prevention programs for these enterprises will make it easier in the future to establish some control or information mechanism on professions that are especially sensitive to money laundering activities, such as lawyers, notaries, real estate agents, jewelers or precious stones merchants, accountants, auditors and trust entities.

Regarding individual rights
and the signed conventions

Central America must comply with international standards on prevention of money laundering and the financing of terrorism, but its procedures for drafting and analyzing Reports of Suspicious Operations (ROS) must avoid putting at risk the right to privacy, honor and reputation of the persons who are subjects of a ROS, for whom the principle of presumption of innocence and the right to effective judicial protection, due process, privacy, honor or reputation and habeas corpus must be respected at all times. The region must realize that coordination of the functioning of the Financial Intelligence Units that respond to the GAFI and Egmont Group international standards is just a first institutional element in the fight against money laundering to make way for a later harmonized action. In accordance with the Palermo and Merida Conventions, such units must become “a financial intelligence dependency that can serve as a national center of collection, analysis and dissemination of information on possible money bleaching activities.”

But the actions of the region cannot be integral if there is no supra-state entity with the capacity to adequately harmonize the national anti-money laundering programs and also receive and analyze the financial information following alerts and suspicions submitted by the financial entities and companies or obligated individuals in each State.

A regional program is needed

Central America should begin to create the conditions in order to achieve, in a few years, the implementation of a regional program to prevent and combat money laundering and financing of terrorism that involves secure and expeditious procedures in handling the ROS, improve the follow-up results and better control the financial intelligence investigations to ensure confidentiality of the information given by the obligated individuals so it may be useful for judicial actions but at the same time be duly sheltered and never misused or manipulated for alien interests.

Excerpts from the June 2012 report “Following the Money Trail: Money Laundering and Its Implications for Regional Security,” prepared by the Central American Network of Think Tanks and Advocacy (laRED) and the Konrad Adenauer Foundation. Responsible editors: Eduardo Stein, Ninette Schwarzbauer and Lorena Escobar. Selections chosen and edited by envío.

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