UNCLAS SECTION 01 OF 02 ASUNCION 000423

SIPDIS

STATE FOR WHA/BSC, WHA/EPSC, S/CT, EB/ESC/TFS, INL/C/CP
STATE PASS TO USTR FOR SCRONIN, LYANG
USAID FOR AA/LAC ADOLFO FRANCO
TREASURY FOR OSIA MAUREEN WAFER
COMMERCE ITA SARAH COOK
NSC FOR MIKE DEMPSEY
SOUTHCOM FOR POLAD
US SOUTHERN COMMAND MIAMI, FLORIDA

SENSITIVE

E.O. 12958: N/A
TAGS: ECON EFIN ETRD KIPR KMCA KCRM KTFN PTER PA
SUBJECT: PARAGUAY: POST SUPPORTS ICE PROPOSAL FOR A TRADE
TRANSPARENCY MODULE TO FIGHT MONEY LAUNDERING


SENSITIVE BUT UNCLASSIFIED - ENTIRE TEXT.


1. (SBU) Summary and Action Request: USG Immigration and
Customs Enforcement agents have proposed the creation of a
Trade Transparency Module (TTM) in Paraguay, identified as
the second highest priority country after Colombia. A TTM
involves the use of sophisticated data mining software to
analyze container-level trade data on both imports and
exports between the US and partner countries. The software
can be used to identify global trends, improve risk
management, identify specific cases of trade-based money
laundering, and target corrupt officials. Establishing a
TTM in Paraguay, which would be incorporated in a vetted
unit already in the process of being created, would cost
approximately $200,000. Post strongly supports this ICE
initiative for the major impact it could have in combating
money laundering, terrorism finance, and IPR violations, as
well as its importance as a tool for fighting corruption and
improving GOP revenue collection. Post requests Department
provide funding or seek interagency support for this
project. End Summary.


2. (SBU) In late February, three Special Agents from US
Immigration and Customs Enforcement (ICE), a component of
the Department of Homeland Security, visited Asuncion
accompanied by ICE's attach based in Montevideo. The
purpose of the trip was to introduce post and the GOP,
specifically the Customs Administration and the Attorney
General, to ICE's Trade Transparency Program, a powerful new
technological tool in the fight against money laundering,
terrorism finance, and tax evasion.

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TTM - A Powerful Tool
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3. (SBU) The ICE agents proposed the creation of a Trade
Transparency Module (TTM) in Paraguay, which is the second
priority country identified by ICE after Colombia, where the
first TTM has been established. A TTM consists of a vetted
unit equipped with several computer workstations running
special data mining software analyzing transaction level
trade data to identify anomalies that can point to trade-
based money laundering, tax evasion and official corruption.


4. (SBU) ICE already has access to a database, updated
frequently to stay about two months behind the current date,
that includes container level data on both US imports and
exports. Inputs come from the Automated Manifest System
(AMS), Shippers Export Declarations (SED) and from Form 7501
entry summaries. The data includes the type and value of
merchandize as well as name, address and other identifying
information for the shipper and recipient. The ICE team was
able to determine that GOP customs data could be formatted
to be compatible with the software.


5. (SBU) The software can review multiple databases, such
as Cash and Monetary Instrument Reports (CMIRs), which
record cross-border shipments of currency over $10,000, or
other money transfer databases available in a particular
country. The software can crosscheck names, addresses,
passport numbers, or other search criteria to identify money
and merchandise movements by persons or entities of
interest.


6. (SBU) The analysts of the TTM would be able to do broad,
product-level analyses to identify risky products, countries
of origin, or firms to better target inspection efforts.
Shipment level crosschecks can identify under- or over-
valuation by traders and allow for the identification of
corrupt customs officials facilitating such deception. In
short, the TTM makes it very difficult for money launderers,
tax evaders and corrupt officials to hide.

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Vetted Unit a Must
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7. (SBU) The capabilities of a TTM and the information it
would generate would be valuable and subject to misuse by
corrupt officials. The TTM would have to be managed by a
vetted unit within Customs to be effective in the long run.
Post's Resident Enforcement Advisor from Treasury's Office
of Technical Assistance had previously begun discussions
with the Customs Director about the creation of such a unit
(for general investigations, before the TTM had been
proposed), and has enlisted the support of an intermittent
OTA advisor. A leader for the unit has been identified, and
the Customs Director is in the process of recruiting members
of the unit. This unit would also staff the TTM, if one
were created.


8. (SBU) According to the ICE proposal, establishing a TTM
in Paraguay would cost approximately $200,000. The costs
include seven computers, each with a copy of the data mining
software, the data, and travel expenses associated with
installation and training. A Customs Mutual Assistance
Agreement between the US and Paraguay already exists, which
would facilitate the exchange of data. The US would receive
the Paraguayan data as well, allowing ICE to undertake
analyses in the US of suspicious movements between the US
and Colombia, the US and Paraguay, and between Colombia and
Paraguay.

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Comment and Action Request - Worth the Price
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9. (SBU) Post believes that the creation of a TTM in
Paraguay would advance several important mission goals,
namely combating money laundering and terrorism financing,
reducing official corruption, and supporting economic
development through improved revenue collection. The Hijazi
case (ongoing money laundering and terrorism finance
investigation) provides a snapshot of the volumes of money
generated illicitly in the tri-border region, some of which
goes directly to the Middle East. Lax customs enforcement
is the fertile soil from which much of Paraguay's informal
and illicit economy grows. Providing such a powerful tool
to a government still focused on reform can make a big
difference. The timing is especially good given Brazil's
renewed commitment to fight contraband and money laundering
in the tri-border area. Post strongly urges Washington
agencies to identify funding to support a Trade Transparency
Module in Paraguay.

KEANE