International Money Laundering—Airport Employees

Three women who worked at Boston’s Logan International Airport as ticket counter representatives have been arrested on charges that “they laundered U.S. currency and smuggled cash out of the United States to the Dominican Republic.”^[1] The three women—Ana Tejada-Holmes, Angie Marinez, and Marianela Sosa—are alleged to have secretly transported US currency that was represented to be the proceeds of narcotics transactions on passenger flights from Logan International Airport.^[2] They allegedly evaded security procedures at the airport to avoid scrutiny of the cash and currency reporting requirements, and then delivered the cash to another person who was waiting at the airport in the Dominican Republic.^[3]

The women have been charged with conspiracy, money laundering, and evasion of currency reporting requirements.

Conspiracy is covered by 18 U.S.C. § 371, which makes it a crime for a person to conspire with at least one other person to commit an offense against the United States, and then do an overt act in furtherance of the conspiracy. The punishment for a violation of section 371 is a fine, imprisonment for up to five years or both.

Money laundering is covered by 18 U.S.C. § 1956(a)(3)(C), which makes it a crime for a person to conduct a financial transaction involving money represented to be the proceeds of specified unlawful activity with the intent to avoid a transaction reporting requirement. The specified unlawful activity in question is narcotics trafficking.^[4] The punishment for a violation of section 1956(a)(3) is a fine, imprisonment for up to 20 years, or both.

Finally, evasion of currency reporting requirements is covered by 31 U.S.C. § 5324(c)(3), which makes it a crime for a person to structure the exportation of monetary instruments for the purpose of evading the reporting requirements of 31 U.S.C. § 5316. These reporting requirements state that a person must file a report with the Secretary of the Treasury when that person knowingly transports monetary instruments of more than $10,000 at one time from a place in the United States to a place outside the United States.^[5] The penalty for violating section 5324(c) is a fine, imprisonment for up to 5 years, or both.

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[1] US Attorney’s Office, Press Release: Three Former Logan Ticket Agents Arrested for Currency Smuggling and Laundering, Dec. 2, 2005.
[2] Id.
[3] Id.
[4] 18 U.S.C. § 1956(c)(7)(A) (incorporating an offense found in 18 U.S.C. § 1961(1)).
[5] 31 U.S.C. § 5316(a)(1)(A).