Arizona Attorney General

Mark Brnovich

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Southwest Border Anti-Money Laundering Alliance

The Southwest Border Anti-Money Laundering Alliance (“Alliance”) www.swballiance.org is the result of a Settlement Agreement reached between the Arizona Attorney General’s Office and Western Union Financial Services, Inc. The purposes of the Program are to: enhance and better coordinate investigations and prosecutions of money laundering in the Southwest Border Area (that area within 200 miles of the United States/Mexico border on either side of the border and including all of Arizona) (“SWBA”) and other areas affected by money laundering in the SWBA, with the goal of reducing money laundering and thereby reducing violence associated with smuggling organizations operating in the SWBA and in other areas affected by money laundering in the SWBA; enhance coordination of the Alliance states’ anti-money laundering (“AML”) efforts; and fund related training, information sharing, and related expenses in the Alliance states and in Mexico (collectively, the “SWBA AML Purposes”).

Alliance funds were available for federal, state, county, local, tribal, and Mexican Initiatives, including technical assistance, training, personnel, supplies, and contractual support to accomplish any one or more of the Goals of the Alliance Strategy, which are listed below:

  1. Disrupt criminal organizations that engage in cross border violence.
  2. Disrupt the movement of weapons that flow across the southwest border into Mexico.
  3. Develop a Southwest Border Area information sharing network.
  4. Provide training for law enforcement, prosecutors, and private sector partners regarding money laundering.
  5. Support multi-jurisdictional domestic and international money laundering investigations.

INTRODUCTION

The Alliance is governed through an Executive Board consisting of the Arizona Attorney General, the California Attorney General, the New Mexico Attorney General, the Texas Attorney General, the Director of the Arizona Department of Public Safety, the Superintendent of the Arizona Department of Financial Institutions, and the Chief of the Police Department of Phoenix, Arizona (the “Board”), for a total of seven voting members. The Alliance distributed funds for the Southwest Border Anti-Money Laundering Alliance Program to law enforcement initiatives along the Southwest Border Area.

The Alliance prioritized Initiatives that involved multi-state and international money laundering mechanisms, that involved the movement of money to smuggling organizations with a record of violence, that involved the movement of weapons from the United States into Mexico or the use of such weapons in Mexico, that involved multi-state information or data sharing or analysis, or that involved training or coordination conferences relating to money laundering and related criminal activity. The Board only recommended funding of Initiatives that had potential to further the Alliance Strategy, which concentrated on a high-level financial Anti-Money Laundering (“AML”) approach, or that directly impacted substantial smuggling organizations or ongoing facilitators of such organizations.

The core vision of the Alliance is to create a network of people, agencies, task forces, and programs actively engaged in anti-money laundering enforcement in the SWBA. The Alliance plans to: 1) build an internal network of analysts, including analysts in each border state and federal analysts; 2) task its staff investigators in each state with forming a network of money laundering, financial investigation, and asset forfeiture experts and making them available to SWBA investigators and prosecutors to assist in their money laundering cases; 3) develop people and resources to train investigators and prosecutors; and 4) bring these networks together in periodic conferences to continually improve the level of effectiveness of collaborative enforcement efforts. The Alliance intends to foster cases and programs that directly address the growing power of criminal groups in the SWBA and to leave a legacy network of collaborating individuals, agencies, and efforts that includes all related disciplines and all levels of government and spans the entire SWBA, including its Mexican dimension and related industries. The Alliance evaluated all proposed Initiatives for their potential contribution to this overall vision.

The Alliance implemented this vision by allocating funds throughout the SWBA to Initiatives that fostered such cases and programs and the creation of this anti-money laundering network and collaboration among the grantees. These efforts had to go beyond the investigative resources of individual agencies. They had to cross jurisdictional boundaries and lead to the arrest and criminal and civil prosecution of money laundering violators. Although an application by a single agency was eligible, it was not considered if its stated Goals were best accomplished by a multi-agency, multi-jurisdictional task force. For the same reasons, Initiatives that coordinated efforts with related Initiatives and with other initiatives such as the Border Enforcement Security Taskforce (“BEST”) teams of the Department of Homeland Security, High Intensity Drug Trafficking Area (“HIDTA”) initiatives, OCDETF training resources, and federal, state and local multi-agency, multi-jurisdictional task forces were most consistent with the Alliance vision.