Operation Tokyo, the Tren de Aragua vs Banks and the UAF

The anti-money laundering and counter-terrorism financing systems and processes are not commensurate with the risks and the initiative demonstrated by organized crime.  

A week ago, we learned about what is known as the Operation Tokyo (the name of the nightclub in the Venezuelan prison of Tocorón), led by the Metropolitan Regional Prosecutor Héctor Barros, which reports on the money laundering activities of the Tren de Aragua amounting to approximately $75 billion between 2022 and 2025, with all funds already having left Chile.

Details are emerging gradually, but we already have enough to indicate that we have a serious failure in our anti-money laundering and counter-terrorism financing system, one that has as its main central element the Financial Analysis Unit (UAF) under the Ministry of Finance, which goes far beyond banking secrecy.

There are also indications that the financial system as a whole may not be measuring up in this regard, something that was disputed when my letter on the subject was published on Thursday, June 4, in El Mercurio, but where all evidence indicates that several banks are affected, and even two of them have their own personnel, or employees of companies providing them services, involved in the scheme set up to effectively launder such a large amount of money.

Banks will likely insist that they comply with everything the UAF requests regarding reports of suspicious activities (ROS) and reports of cash transactions (ROE). With my 20 years of experience in local banking, I can assure you that it is very possible that this is the case, but the problem lies not in what they report to the UAF and how frequently they do so, but in the fact that the two cases involving Santander (the Tokyo case and the Clan Chen case, the latter involving $200 million) along with the case of an external individual providing services to Banco Estado indicate weaknesses regarding infiltrations and the inability to detect them, as well as the fact that at least accounts in six different banks were used to move and launder assets. We will see what the CMF has to say regarding the health of the financial system and, in particular, of the banking sector in relation to what has occurred, something they view as more of the UAF’s responsibility than their own.

Clearly, in current times, complying with what the UAF requests is not sufficient, due to the fact that the anti-money laundering and counter-terrorism financing system and processes are not commensurate with the risks and the initiative demonstrated by organized crime in the most recent events that occurred in 2026. They may have been adequate when the UAF was created just under 23 years ago when Law 19,913 was published, which led to its inauguration on May 17, 2004. It is time to review what and how we do things, especially in a much more banked country.

To begin with, the UAF has an insufficient staff of only approximately 80 people and an annual budget of less than $6.7 million. It operates with a supervisory scheme that is more reactive than proactive. It is not an organization that actively seeks out money laundering as an intelligence service would. I suspect that, with the available budget, of which 70% is for salary payments, their hiring of cutting-edge technologies, specifically AI, is not something that is readily available to them.

The objective of the UAF is to prevent and impede the use of the financial system, and other sectors of the Chilean economy, for the commission of money laundering (LA) and terrorism financing (FT) crimes. It is based on the existence of 55 types of private sector companies and a significant portion of the public sector that are categorized as obligated subjects to report activities (ROS and ROE) because of their nature, which can be used to launder assets or finance terrorism.

The mission of the UAF is to prevent and detect LA/FT in Chile, through financial intelligence, risk-based supervision, dissemination of public information, and institutional cooperation (with public and private entities, both in Chile and abroad), in order to protect the country and its economy from the distortions generated by criminal activity.

The recent events should lead us to review whether financial intelligence activities are being carried out correctly, and also whether the assessment and sizing of risks are being executed properly. I say this because we need to know if the problem lies in planning or execution, or both. What is clear is that the system is not delivering the expected results. The Tokyo operation was revealed due to a mistake by the criminals in using WhatsApp networks to conduct their activities. A cell phone abandoned at the site of the murder of five people in Lampa in 2024 is what allowed the detection of the operational scheme, its technical characteristics, and the affected banks. It was not something that was uncovered by the UAF.

In the new intelligence law recently published, the UAF assumes the role of a cooperating institution within the national intelligence system. It is also expected that the National Intelligence Agency (ANI) will take on a role of direction and coordination, instructing the system as a whole regarding information gathering. The Public Prosecutor’s Office needs assistance in carrying out the criminal prosecution that is expected of it, but for this, intelligence related to organized crime, the main risk to national security, and particularly financial intelligence, are key and fundamental inputs. We can no longer pretend to go through life without intelligence, and even less by only acting reactively. If we know that organized crime operates, conducts illicit businesses, launders assets, kills people, captures territories, extorts, and kidnaps, what are we waiting for to act proactively and responsibly.

The purpose of this column is not to accuse the banks and the UAF, but to raise the alarm and the need to intervene in the anti-money laundering and counter-terrorism financing system. We do not need more examples to validate the necessity of doing so. Attacking and destroying money laundering is attacking organized crime where it hurts them the most. It is not something difficult to accomplish, but it requires intelligence, political will, and primarily, understanding how they operate to know where and when to hit them. They do not operate with rules, and ours will require flexibility.

Finally, I urge all those who are part of the anti-money laundering system to take precautions and not go through life carelessly. The drug trafficker is merciless when their pockets are touched. At the stage we are currently in, organized crime will begin to affect all those who stand in its way or who impede its illicit business.