Basic Money Laundering Schemes 241
Straits Bank was also documented, though harder to nd
among First Pacic’s records.
One interesting aspect to this case was the fact that
although several CTRs were led in connection with transac-
tions conducted by Lee and his associates, none of these were
linked to the operation until after the fact. When investiga-
tors went looking for information about known Lee associ-
ates, they discovered the CTRs and some Suspicious Activity
Reports as well.
This should be a caution for nancial investigators. Criminals
aren’t always stupid, and once they’ve discovered that the
reports are being submitted, they may change their M.O. to
avoid those lings. Thus, your subject may have only one