Black Market Peso Exchange (BMPE)

Traffickers earn dollars in the United States but need pesos at home. A peso broker in the home country buys those dollars at a discount, paying the traffickers in pesos. The broker then sells the dollars to local importers who need foreign currency to buy goods such as electronics or appliances. Agents in the United States place the cash into banks, often in small sums, and pay American suppliers for the goods on the importers’ behalf. The goods are shipped and sold, and importers repay the broker in pesos. Money crosses the border without any direct wire from the traffickers. Cases show structured deposits, third-party payments for goods and payers with no link to the buyer. Similar systems exist for other currencies. Compliance staff study it as the textbook case of laundering that hides inside ordinary trade payments.

A US exporter of electronics receives payments from several unrelated companies and individuals for orders shipped to a South American importer. The payers have no visible link to the buyer, and the deposits were in cash amounts just below the reporting limit. The exporter’s bank notices the mismatch and files a suspicious activity report. Investigators later trace the cash to a peso broker.