A Crisis that is Anything but Synthetic

The Problems Caused by Fentanyl and Other Synthetic Opioids, and What the AML Community Can Do to Help

In the early nineteenth century, opium addiction was such a problem in China that the government threatened the death penalty for anyone caught smuggling the drug. The British Empire – which produced vast quantities of opium in their colony India and were hooked on the revenue from Chinese consumers – declared war on China¹. After nearly three years of fighting, China ceded Hong Kong to the Brits, the repercussions of which are still being felt today.

Opium, a drug produced from the juice of the opium poppy, is a natural substance. This explains how it reached widespread consumption before the discovery of germs and advancements in chemistry led to modern pharmacology. It’s also how Elaine Benes, the fictional character played by Julia Louis-Dreyfus, failed a workplace drug screen because of her overindulgence in poppy seed muffins in an episode of Seinfeld. Natural opium is an antecedent to morphine, a common painkiller prescribed in hospitals, and the street drug heroin.

In recent decades, research scientists have begun the development and manufacture of synthetic opioids. Doctors prescribe these drugs (which include oxycodone, fentanyl, and morphine, among others) for chronic pain management. Between 2006 and 2014, more than 100 billion doses of oxycodone and hydrocodone were shipped in the United States alone². In the 2010s, one particular synthetic opioid began wreaking havoc throughout the country. It has killed fathers, mothers, celebrities such as Prince, Tom Petty, and Mac Miller, as well as unwitting teenagers³. Many of its victims are unaware they are using it, as it is often laced into other drugs. Its name is fentanyl.

The majority of illegal fentanyl in the United States (as opposed to its legitimate uses as a controlled painkiller and anesthetic) is smuggled into the country from China and Mexico, according to the DEA’s 2018 National Drug Threat Assessment⁴. Fentanyl related substances (FRS) – those that are similar to fentanyl but have minor chemical differences – are increasingly being used as an alternative or substitute for fentanyl. The true effects of these drugs are difficult to measure, as most of them are not approved for use in humans. In AML RightSource’s home state of Ohio, a 2017 spike in cocaine deaths was found to be due to the appearance of carfentanil (an FRS that is significantly more potent than fentanyl and was originally developed as an elephant tranquilizer) in the local illegal cocaine supply⁵.

Since most illegal synthetic opioids in the US are imported from China and Mexico, they present unique challenges for the AML community. Synthetic opioids were among the first major class of illegal drugs to enter the public consciousness after the rise of the Internet. According to Neil Walsh, chief of the United Nations Office on Drugs and Crime’s cyber-crime and anti-money laundering units, the Internet (both the traditional open internet as well as the dark web) connects large-scale dealers with fentanyl laboratories⁶.

In response to the rise of synthetic opioids, FinCEN released an advisory in August 2019 addressing illicit fentanyl schemes and money laundering methods related to the trafficking of synthetic opioids⁷. In the report, they offered a list of 20 common red flags for financial intelligence units to consider. They include:

• A money transfer beneficiary lists a phone number or email address associated with a pharmaceutical company or chemical sales website

• Account owners or third parties structure cash deposits at bank branches nationwide into the same account, which funds outgoing transactions on the southwest border region of the U.S., including cash withdrawals or wire transfers to Mexico

• Direct or indirect transactions with Darknet marketplaces or convertible virtual currencies mixing services

• Customer discussing drug purchases in the transaction notes field available on the exchange, including referencing drugs or weight measurements (e.g., “1 gram fent”). Customers may reference informal slang names or actual chemical names.

Despite the challenges that synthetic opioids present every day, AML professionals can make a difference by reviewing the FinCEN red flags, integrating them into surveillance processes and alerting law enforcement to any suspicious activity that may help curb the growth of this deadly trade.

References:

1. Lovell, Julia, The Opium War: Drugs, Dreams, and the Making of Modern China. 2011. The Overlook Press, Peter Mayer Publishers, Inc.
2. https://www.washingtonpost.com/investigations/more-than-100-billion-pain-pills-saturated-the-nation-over-nine-years/2020/01/14/fde320ba-db13-11e9-a688-303693fb4b0b_story.html
3. https://people.com/music/fentanyl-drug-that-killed-prince-has-long-history-of-abuse/
4. https://www.dea.gov/sites/default/files/2018-11/DIR-032-18%202018%20NDTA%20final%20low%20resolution.pdf
5. https://www.harmreductionohio.org/study-carfentanil-in-cocaine-caused-big-spike-in-overdose-deaths-in-dayton/
6. https://www.theatlantic.com/technology/archive/2019/10/what-dark-web-can-teach-us-about-opioid-crisis/600352/
7. https://www.fincen.gov/sites/default/files/advisory/2019-05-10/FinCEN%20Advisory%20CVC%20FINAL%20508.pdf