The criminal threats of the 21st

century are virtually unlimited

in their scope. With the expansion

of information technology and 

the ease of travel, criminals and 

terrorists are newly empowered in

their schemes.

That’s why ICE has led the way in

building partnerships with foreign

law enforcement agencies and private sector players around the world,

in order to share information and

build a united front against today’s

globalized criminal threats. ICE’s

Cornerstone initiative is the vehicle

for this partnership between law

enforcement and private industry.

Through Cornerstone, ICE shares

information, methodologies and

security technology gleaned from

financial investigations with the

front-line players in the industry—

the people who manage the very

systems terrorists and other criminal organizations seek to exploit.

This partnership allows ICE to provide timely information and feedback to businesses and industries so

that they can take precautions to

protect themselves.

In return, ICE receives information,

tips and insights from the businesses and industries that are often first

to encounter suspicious activity,

“red flags,” in the course of their

normal business.

ICE has partnered with the International Association of Financial

Crimes Investigators (IAFCI) and is

a permanent member on the board

of directors. ICE is also an active

member of the Financial Action Task

Force (FATF), a leading interagency

investigative task force, and ICE officials offer presentations at industry

conferences worldwide.

ICE also works closely with international law enforcement agencies 

and has provided training to investigators from around the world—

including Australia, China, the Middle East, Japan, India, Italy 

and Bulgaria—on anti-money 

laundering and anti-terrorist financing initiatives.

continued on page 2

U.S., U.K, Canadian and Australian investigators coordinate efforts through the Virtual Global

Task Force, which targets online child exploitation.

Beyond the Borders: 

ICE Partnerships Go Global

stoneReport

TheCorner

Inside This Issue

Safeguarding America through

Financial Investigations

www.ice.gov/cornerstone

Toll-Free Tip Line: 

1-866-DHS-2-ICE

Cornerstone is U.S. Immigration 

and Customs Enforcement’s (ICE)

comprehensive investigative initiative

for fighting financial crime.

The Cornerstone Report is a quarterly

bulletin highlighting key issues

related to ICE financial, narcotics and

public safety investigations.

Beyond the Borders: 

ICE Partnerships 

Go Global . . . . . . . . . . . . . . . . . 1

Operation Firewall: 

An International 

Partnership Success . . . . . . . . 3

ICE Uncovers Immigration

Violations, Money 

Laundering at Maryland 

Seafood Supplier . . . . . . . . . . 4

Volume IV: No. 1 • March 2007 Canadian telemarketing schemes that defraud American investors of their savings.

Sexual predators on the Internet preying on children in other countries.

Drug dealers attempting to transport millions in cash across borders.
Continued from page 1

Project COLT

An example of ICE’s

partnership with

international law

enforcement is Project COLT (Center

of Operations Linked to Telemarketing), the oldest interagency law

enforcement partnership in Canada.

Project COLT was launched in April

1998 to identify, disrupt and dismantle illegal telemarketing operations and to return seized funds to

telemarketing victims.

Comprised of representatives from

ICE, the FBI, the U.S. Postal Service,

the Federal Trade Commission, the

Royal Canadian Mounted Police

(RCMP), the Surete du Quebec

(Quebec Provincial Police), the Montreal City Police and the Canadian

Competition Bureau, Project COLT is

a model for effective international

law enforcement cooperation.

To date, Project COLT investigations

have led to the recovery and return 

of $15 million to scam victims,

along with 1,215 indictments (413

in the U.S.) and 23 individuals

extradited to the U.S. on telemarketing fraud charges.

Politically Exposed Persons

(PEP) Program

Part of the battle against political

corruption and money laundering,

the ICE Politically Exposed Persons

(PEP) investigative program was

established in 2003.

ICE established the original Foreign

Corruption Task Force, also known as

the PEP Task Force, in Miami based

on requests from Central and South

American and Caribbean governments seeking assistance in developing evidence against and locating the

assets of corrupt government officials and prominent citizens involved

in the theft or embezzlement of government and private funds.

The most successful investigation of

this type to date involved former

Nicaraguan President ALEMAN

who, along with other government

officials, were accused of the money

laundering, fraud and theft of government property, embezzlement of

public funds, and public corruption

offenses in Nicaragua.The

Nicaraguan Prosecutor’s Office filed

an official request for U.S. assistance

in identifying and recovering assets

in the U.S. after their investigative

efforts revealed that funds obtained

by these illegal activities were funneled through bank accounts in

Panama and used to purchase high

value assets in the U.S. Ultimately,

the ensuing investigation led to the

seizure of approximately $6 million

in assets in the U.S. ICE has forfeited

and repatriated approximately $2.7

million to Nicaragua.

Another goal of the task force is to

raise awareness of foreign corruption in ICE field offices and to

deliver training to foreign governments in identifying patterns of

public corruption and how the

related proceeds can be laundered

through U.S. financial institutions.

The Miami PEP Task Force has

already delivered extensive training

to law enforcement agencies in

Central and South America.

Virtual Global Task Force

Created in 2003, the Virtual Global

Task (VGT) Force is a law enforcement network comprised of ICE, the

Australian High-Tech Crime Centre,

the United Kingdom’s National

Crime Squad, Canada’s RCMP and

Interpol. Under the 24/7-watch system, one nation’s member agency

on the task force essentially serves as

the on-call Internet police officer for

part of each day.

The watch rotation system has

already produced early success. In

one case, information provided in

an Internet chat room and reported

to authorities in the U.S. indicated

that a man in England planned to

molest his children within the next

few hours.

Investigators in both countries

sprang into action, working

through a team comprised of ICE

and the U.S. Postal Inspection Service in the U.S. and the Child

Exploitation and Online Protection

(CEOP) Centre and the local police

in the United Kingdom. Within two

hours of the first report, local police

officers were at his door.Their

resulting investigation uncovered

images of child pornography and

mitigated possible risks posed by

him to other children. $

Beyond the Borders: ICE Partnerships Go Global, continued

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Volume IV: No. 1

March 2007

• Supported the International Law Enforcement Academy (ILEA) program by supplying instructors for their programs in

Botswana and Thailand.

• Provided bulk currency smuggling investigation training in support of the Asian

Pacific Group in Brunei.

• Provided continuous support of the Organization of American States (OAS) as the

only U.S. law enforcement agency invited

to participate in the training of mid-level

law enforcement officers from Central

and South American countries.

• Supported the first ILEA Latin America

class held in El Salvador.

• Offered training, technical assistance and

instruction on conducting international

money laundering and financial crimes

investigations to foreign police and judicial officials. This training was performed

in support of the International Monetary

Fund (IMF), IAFCI and ILEA programs.

Selected ICE Foreign Outreach Highlights
The smuggling

of bulk currency out of the United States has become a preferred

method for drug dealers and other

criminals to move illicit proceeds

across our borders. In response,

Congress criminalized the act of

smuggling large amounts of cash

into or out of the United States in

the USA PATRIOT Act.

Specifically,Title 31 U.S.C. 5332—

Bulk Cash Smuggling makes it a

crime to smuggle or attempt to

smuggle over $10,000 in currency

or monetary instruments into or

out of the United States, with the

specific intent to evade the U.S. currency-reporting requirements codified in 31 U.S.C. 5316.

ICE has taken a leading role in combating bulk cash smuggling, teaming in August 2005 with U.S. Customs and Border Protection (CBP)

and our state, local and foreign law

enforcement partners in Operation

Firewall, a comprehensive law

enforcement operation focused on

the smuggling of large quantities of

U.S. currency around the world.

Through Firewall, ICE and CBP are

working side by side to combat

cash smuggling at various U.S.

ports-of-entry. In the interior United States, ICE works with state and

local partners to identify and intercept bulk cash shipments being

transported along domestic interstate highways en route to be smuggled out of the United States.

ICE’s enforcement of the bulk cash

smuggling law extends beyond our

nation’s borders. ICE and CBP are

also conducting various Firewall

training operations with our foreign

law enforcement partners, including

training exercises with Mexican law

enforcement targeting the smuggling of U.S. currency through Mexico to Central and South America.

Throughout operations in Mexico,

Panama, Colombia and Ecuador,

ICE special agents and CBP officers

provide hands-on training to our

law enforcement partners on passenger analysis and other investigative techniques that have proven

effective in the United States. Operations in Mexico and Panama also

include training on the use of

mobile x-ray units provided to the

Mexican government by the U.S.

Department of State.

Operation Firewall has focused on

the full panoply of methods that 

are used to smuggle bulk cash,

including commercial and private

passenger vehicles, commercial 

airline shipments, commercial 

airline passengers and pedestrians

transiting to Mexico along the

southern border and Canada on 

the northern border.

As of February 2007, more than

$75.7 million in U.S. currency 

and negotiable instruments have

been seized as a result of Operation Firewall.There have been a

total of 660 seizures, resulting in

195 arrests (154 in the United

States and 41 outside the United

States).The ICE Mexico Money

Laundering Vetted Unit has accounted for more than $36 million in

seizures of currency and negotiable

financial instruments. $

Operation Firewall: 

An International Partnership Success

These deep fryers (to the left) concealed

$4.4 million dollars in smuggled cash

(shown in bundles above). Other money was

concealed in voltage regulators and rotisserie ovens. The total amount of the seizure

was $7.8 million dollars, the largest seizure

in Mexico’s history.

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Volume IV: No. 1

March 2007
A2005 ICE

investigation 

of human smuggling, illegal immigration and

money laundering in Maryland

underscores the international aspect

of criminal activity in the 21st century—and how a seemingly legitimate business can become a vehicle

for money laundering, smuggling

and other crimes.

The Baltimore ICE Special Agent in

Charge led the investigation into a

large-scale alien smuggling and

money laundering operation at

Chang Jiang Seafood, Inc., a wholesale seafood supply company.

Chang Jiang Seafood was a wholesale seafood supplier that employed

and harbored illegal aliens and used

the business to launder illicit funds

derived from immigration violations. Chang Jiang Seafood was

owned and operated by Bao Wang

and his wife Trang Lu. Wang and Lu

were also partners in similar seafood

businesses operating in various locations throughout the United States.

The investigation identified monthly

cash deposits averaging over $1.8

million made into Chang Jiang

Seafood accounts during

2003–2004. Wang and Lu knowingly employed illegal Chinese aliens,

whom they recruited through the

local Chinese community.

Wang and Lu harbored the illegal

aliens, providing them with food,

living quarters and basic necessities,

and used these illegal employees to

help recruit other illegal aliens.

Employees were generally paid in

cash, their income was untaxed and

they were provided with no record

of payment.

Wang and Lu converted part of

their warehouse in Baltimore to

house illegal alien employees and

rented two apartments in close

vicinity to the business for housing

additional illegal workers. Later,

Wang and Lu purchased a small

house in Baltimore for housing illegal employees. In all cases, the living conditions provided for the

aliens were crowded, unsanitary

and a fire hazard.

Records showed that Wang and Lu

wire transferred millions of dollars

from their bank account to a

seafood supply company in China,

but received only a fraction of the

value of their “purchases” in

seafood in exchange. Financial

analysis of the business accounts

and extensive work with various

banks revealed cash deposits in

excess of $1.8 million per month.

The largest single cash deposit was

over $1 million. Approximately 75

percent of Chang Jiang Seafood’s

deposits were in cash.

According to legitimate seafood

distributors, a reasonable cash intake

is 25 percent or less. Lu made the

majority of all cash deposits. Her

cavalier attitude when bringing in as

much as $1 million in cash raised a

red flag to bank employees, who filed

several Bank Secrecy Act (BSA)

reports concerning the activity.

Results

At the conclusion of the investigation, ICE seized approximately 

$2.6 million in cash and property

from Chang Jiang Seafood’s business operations. Fourteen individuals were arrested as a result of this

investigation.The two main targets,

Wang and Lu, pleaded guilty to

charges of employing and harboring illegal aliens.

On June 13, 2005,Wang and Lu, as

part of a plea agreement, were sentenced in U.S. District Court in Maryland to one year of home detention

and one year of probation and were

each fined $10,000.Wang and Lu

agreed to forfeit claim to the $2.6

million in cash and property. On September 30, 2005, an order of final

forfeiture was executed for the $2.6

million in cash and property seized

in relation to this investigation. $

Living conditions for Chang Jiang employees.

ICE Uncovers Immigration Violations, Money

Laundering at Maryland Seafood Supplier stoneReport

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Volume IV: No. 1

March 2007

•Numerous BSA filings by multiple financial 

institutions.

•Large and numerous cash deposits inconsistent

with business type (wholesale supply company).

•Physical appearance of business inconsistent

with high level of financial activity.

•Large payments to foreign companies that are

inconsistent with the amount of product received

from these companies.

•Unusual withdrawal, deposit or wire activity

inconsistent with normal business practices, 

or dramatic and unexplained change in 

account activity.

•Sudden change in customer’s normal business

practices, i.e., dramatic increase in deposits,

withdrawals or wealth.

Red Flag Indicators