TRIPWIRE is published by the 

U.S. Department of Homeland Security,

Bureau of Immigration and Customs

Enforcement (ICE).

It is distributed to the public 

free of charge to support ICE's 

law enforcement mission.

Tripwire is not affiliated with 

any private, commercial,or 

non-governmental entity.

F o reign Political Corruption Task Forc e

ICE IN CARIBBEAN ISLANDS, SOUTH

AND NORTH AMERICA

On March 20, former Nicaraguan President

Arnoldo Aleman was imprisoned after being

convicted for his role in diverting nearly $100

million in public funds from his nation’s bank

accounts. ICE investigators, working with their

Nicaraguan counterparts, discovered that

Aleman had stashed at least $5.5 million in the

United States, with real estate investments in

Florida and hundreds of thousands of dollars in

certificates of deposit at U.S. banks. 

In a world of globalized financial markets,

bribery, fraud, and embezzlement cannot go

unchecked. Frequently, as in the Aleman case,

corrupt foreign leaders will channel illicit

funds to U.S. financial institutions for laundering or investment. 

While there are numerous indicators that could

signal a corruption case, “red flags” for investigators might include irregularities like the

following:

• High-ranking government officials establishing offshore companies and bank

accounts. 

• O fficials writing checks for non-existent

goods and services to companies owned

by a politician, his associates, or family

members.

• Wire transfers to bank accounts in the

United States or elsewhere. 

• Government officials purchasing significant

assets or investing in high-end real estate in

the United States or other countries. 

• Officials accumulating unexplained financial wealth, often inconsistent with information provided on public disclosure forms. 

• Disregard of general accounting procedures

for purchases of government equipment and

use of government funds. 

• Government checks issued to individuals

with no justification listed on the books and

cashed at exchange houses. 

In recent years, the U.S. government has

assisted governments in Central America,

South America, and the Caribbean region to

build cases against government officials and

prominent citizens who accept bribes and

embezzle funds. To this end, ICE has established a pilot program – the Foreign Political

Corruption Task Force Unit (FPCTF) – to

address these crimes. This Miami-based task

force draws upon the combined resources of

ICE, the U.S. Attorney’s Office, and the

Bureau of Alcohol, Tobacco, and Firearms to

identify, investigate, and, where possible, help

prosecute cases of public corruption and

money laundering. 

The FPCTF brings to bear all of our resources

in the fight against foreign public corruption.

ICE Special Agents offer critical assistance to

foreign governments in sensitive embezzlement and bribery investigations. Furthermore,

ICE attaches in U.S. embassies throughout the

Caribbean and Latin American region have

been tasked with providing lists of potentially

corrupt officials to be denied visas to ensure

they can’t flee to the United States. The 2001

USA Patriot Act included several anti-money

laundering provisions that will serve as a critical tool in this battle, allowing us to pursue

civil forfeiture of proceeds and property related

to foreign offenses. 

In the past, numerous retired officials from

Latin America and the Caribbean have purchased fashionable homes in the United

States—living off the proceeds of bribes,

fraud, and embezzlement. The FPCTF will

ensure that these criminals face the full force

of the law. The United States will not be a safe

haven for corrupt foreign officials.

Inside TRIPWIRE

Following the Money 2

New IRS Team Pro v i d e s 3

Education to Combat 

Money Laundering

Project COLT: 3

Telemarketing Fraud

Financial Tidbits 4

Cornerstone Launches 4

Expansion of 

Partnerships

Calendar of Events 5

www.ice.gov

Toll-Free Tip Line: 

1-866-DHS-2ICE

Around the World

Volume I: No. 2 April 2004

$
One clear lesson our nation learned after

September 11, 2001, was that we could

not afford to take homeland security for

granted. With the creation of the

Department of Homeland Security

(DHS), our government took a major step

toward better addressing threats to our

nation and our way of life. 

But an effective homeland security effort

also requires the cooperation of the private sector. After all, a terrorist attack of

any kind would have major consequences

for business—undermining confidence,

shaking markets, and spreading ripples

throughout the economy. We all remember the effects of shutting down the aviation system for three days in September

2001; more recently, the March 11 railway bombings in Spain illustrated how a

terrorist strike could rattle consumer confidence around the globe. A terrorist

attack that systematically targeted a particular economic sector—through cyberattacks or bioterror, for example—could

have equally serious consequences. 

Clearly, the business community has a

real stake in our nation’s security. That’s

why business leaders at every level—

from large industry to independently

owned businesses—should work in partnership with local, state, and federal governments to develop effective security

strategies. 

To this end, U.S. Immigration and

Customs Enforcement (ICE), the investigative arm of DHS, has developed

“Cornerstone,” a comprehensive program

to safeguard and strengthen our economic

and financial systems. “Cornerstone”

directs ICE’s investigative and enforcement tools toward tracking the money and

methods that terrorists and criminal networks use to fund their activities and

shutting down vulnerabilities in our financial systems. ICE investigates and prosecutes a wide variety of economic crimes

that affect virtually every sector, including money laundering, commercial fraud,

intellectual property rights violations, and

smuggling and trafficking. 

“Cornerstone” also offers an exchange

through which business and government

can share information about potential economic and financial vulnerabilities. To

facilitate that exchange, ICE will staff

“Cornerstone” agents as full-time industry

liaisons in each of the agency’s 27 regional offices. These agents will serve as

resources for business while helping to

educate the public about the importance

of economic security. By working together with the business community, ICE

hopes to: 

• Ensure that businesses are not vulnerable to exploitation by terrorists, criminal organizations, or money launderers; 

• Help business owners avoid getting

caught in a legal situation as a result of

not knowing the law; 

• Build two-way information-sharing

partnerships through which

“Cornerstone” can identify and shut

down threats to homeland security in

our financial system. 

Homeland security isn’t just a federal

strategy or a government initiative—it’s a

shared mission for all Americans, including the business community. ICE and the

Department of Homeland Security understand that success in this mission will

require cooperation, coordination, and

communication with the private sector.

NFIB looks forward to collaborating with

ICE in the “Cornerstone” partnership—

because the security, stability, and

integrity of our markets and financial

systems are integral to continued growth

and prosperity.

A key fact of law enforcement in the 21st

century is that financial investigations

will be critical in the fight against criminal and terrorist organizations. In the

Department of Homeland Security, U.S.

Immigration and Customs Enforcement

(ICE) aims to be the investigative leader

by applying a systems-based approach to

attacking financial crimes. 

ICE’s financial investigators and analysts

build on the legacy we inherited from the

U.S. Customs Service, which was

empowered under the Bank Secrecy Act

and Money Laundering Control Acts to

investigate and interdict the illegal movement of currency in and out of the United

States. High-profile Customs investigations of the past, such as the Bank of

Credit and Commerce International

(BCCI) case, illustrated how our financial

system could be corrupted and exploited

to facilitate the laundering of criminal

proceeds. 

As a result, law enforcement agencies in

the 1990s developed greater knowledge

of the extent to which money laundering

had compromised our financial system’s

integrity. To counter the threat, investigators moved to employ new techniques,

such as infiltrating money-laundering networks with undercover agents, to identify

targets and dismantle criminal organizations. In turn, the information and knowledge gathered in each investigation

helped spur new leads, allowing investigators and agents to pursue criminal

activity more vigorously.

I C E ’s Financial Investigations division

builds on this legacy by seeking out creative and innovative avenues for investigating these crimes. One of our top

ICE Financial Investigations, Money Laundering Coordination Center Follows the Money

Following the Money

The Business Community and ICE’s“Cornerstone” Program

Building Partnerships To Ensure Economic Security

$

(continued on page 3)
priorities has been to attack the alternative financial systems and secondary

markets that have flourished to meet the

demand for money laundering, such as

the Black Market Peso Exchange

(BMPE). The BMPE shows how legitimate systems can be exploited to facilitate the laundering of drug proceeds. To

combat this type of exploitation, ICE

developed a systems-based approach to

financial investigations. 

One of our critical tools in this approach

is the Money Laundering Coordination

Center (MLCC). The MLCC was created

in 1996 to serve as the clearing-house and

principal supporter of ICE’s financial

investigations, including those targeting

domestic and international money laundering organizations and systems. The

MLCC gathers information on laundering

targets, money brokers, bank accounts

and trade data to identify systems and

patterns for exploitation by ICE field

offices. 

Another key tool in ICE’s financial investigation is the Numerically Integrated

Profiling System (NIPS), software developed in 1990 to analyze import and

export trade data, financial information

made available by the Bank Secrecy Act,

and law enforcement databases. NIPS

allows ICE investigators to integrate

information in the drive to develop

smarter, more aggressive approaches to

combating financial crime. Today, our

agents use NIPS to determine trends,

anomalies, and suspicious activities in the

arena of international commerce. In addition, NIPS is a valuable weapon against

alternative systems of moving illicit funds

out of the United States, such as networks

that support illegal trade in commodities

like gold.

These are just two examples of how ICE

is integrating existing investigative assets

into its new systems-based approach to

fighting financial crime. We’ll continue

looking for fresh ways to address the

ever-changing threats to the integrity and

security of the U.S. and international economic systems.

New IRS Team Provides Education to Combat Money Laundering

The International Monetary Fund estimates that money laundering, the process

of moving funds generated from illicit

activities to disguise their ownership or

origin, is approximately a 3 trillion dollar

industry worldwide. People launder

money to conceal their involvement in

criminal activity such as terrorism, drug

trafficking, or illegal tax avoidance. 

The Taxpayer Education and

Communication (TEC) Unit of the Small

Business and Self-Employed Operation

Division of Internal Revenue Service has

assembled a team of Anti-Money

Laundering (AML) Specialists. This new

team will provide education on the registration, reporting, and record keeping provisions of the Bank Secrecy Act (BSA).

The BSA requirements may apply to you,

your members and/or clients. A money

services business includes any person

conducting business as a currency dealer

or exchanger; check cashier; issuer of

traveler’s checks or money orders; seller

or redeemer of traveler’s checks or

money orders; or money transmitter.

These businesses must register with the

Department of the Treasury and file

Suspicious Activity Reports and certain

other reports with the Department of

Treasury.

Other types of businesses with cash transactions over $10,000 must also report

those transactions to the Department of

the Treasury.

In addition, if you own a bank account, a

brokerage account, a mutual fund

account, an interest in a unit trust, or

other type of financial account in a foreign country and the value of the

accounts exceed $10,000, you may be

required to report the account yearly to

the Department of Treasury.

If you are a money services business, deal

with suspicious or large cash transactions,

have a foreign bank account, or would

like more information about the Bank

Secrecy Act or Internal Revenue Code

section 6050I, please call the TEC AML

Specialist in your area (not toll-free).

AML Specialists may provide seminars

free of charge, if the requestor meets certain requirements.

Alex Basden, (212) 719-6764 — M E ,

NH, V T, MA, CT, RI, NY, PA, NJ, DE, MD

Susan Vega, (954) 423-7777 —VA, NC,

SC, GA, FL, AL, MS, TN, AR, Puerto Rico

Theresa McGill, (630) 493-5190 —WV,

OH, KY, MI, IN, IL, MN, WI , IA, MO

F. Kim Buggs, (281) 721-8034 —ND,

SD, NE, KS, OK, TX, LA

Ulla Scott, (213) 576-3865 —L o s

Angeles, So. CA, NM, AZ, NV, UT, CO

David Vicente, (510) 637-2199 —

No. CA, WY, MT, ID, WA, OR, AK, HI 

You can find additional information about

money laundering at these web sites: 

http://www.fincen.gov or

http://www.msb.gov. $

Following the Money

(continued from page 2)

$
Financial Ti d b i t s

P H I S H I N G

Phishing (pronounced “fishing”) refers to an e-mail scam under

which the sender poses as an established, legitimate enterprise in

an attempt to fool the receiver into surrendering private information, which is subsequently used for identity theft. “Phishing” is

also referred to as “brand spoofing” or “carding.” 

A typical phishing e-mail directs the receiver to visit a counterfeit web site, where he or she is asked to update personal information such as passwords and credit card, social security, and

bank account numbers. The counterfeit web site is set up only to

steal the user’s information, which is then used to order goods

and services or to obtain credit. 

For example, in 2003, a number of e-mail users received notifications that appeared to come from the Federal Deposit

Insurance Corp (FDIC). The e-mail claimed that the receiver’s

bank account was under investigation and would be suspended

unless the receiver clicked on a provided link and updated his or

her credit information. The link led to a phony website designed

to look like an official bank site. (It is relatively easy to construct a web site to look like a legitimate organization’s site). By

spamming large groups of people, the “phisher” counts on the email reaching a small percentage of people who actually have

accounts with the financial institution. With the low costs associated with mass e-mailing, a small number of responses can make

the enterprise profitable. 

Suspicious e-mails and suspected scams should be reported to

the Federal Trade Commission (FTC). The FTC Identity Theft

website (www.ftc.gov/idtheft) has more information on minimizing the risk of damage from identity theft. In addition, Microsoft

has made security software available to combat the threat of

fraudulent “phishing” schemes. 

ICE’S CORNERSTONE PREPARES TO EXPA N D

I N D U S T RY PA RT N E R S H I P S

Industry Liaisons To Be Placed In 

ICE Regional Offices

A key link between ICE’s Cornerstone program and the private

financial sector will be our special financial investigations liaison agents serving in each of ICE’s 27 Special Agent in Charge

(SAC) offices. Beginning this spring, each SAC office will

include a Senior Special Agent serving as a designated

Cornerstone point of contact – working with industry to pinpoint

vulnerabilities in the financial system, sharing new information

on the program, and soliciting feedback from industry. In the

near future, these Cornerstone liaisons will be contacting private

sector representatives to expand longstanding partnerships with

the financial and trade sectors. For more information on the

Cornerstone liaison program, contact your local SAC office. 

$

ICE and Project C O LT: Fighting Telemarketing Fraud

On March 27, 2004, a Montreal man pled

guilty to a number of fraud and conspiracy charges for his role in a telemarketing

scheme that defrauded over 80 senior citizens in the U.S. of hundreds of thousands

of dollars. 

This telemarketing scheme began in early

2000, taking a common form for such

scams. Callers contacted senior citizens

and told them they had won large cash

prizes as part of a Canadian lottery. The

callers went on to explain that the prizes

couldn’t be released until the victims prepaid taxes, duties, and fees on the winnings. In this case, the victims sent

checks ranging from $20,000 to $240,000

to a Canadian address, where the money

was subsequently laundered and sent to

banks in the Middle East. 

Telemarketing schemes have emerged as

a multi-billion dollar growth industry.

Worse, the perpetrators prey on lonely or

vulnerable seniors, in many cases

defrauding them of their entire life savings. In some instances, they hit their victims with a second round of calls, posing

as law enforcement officials who will

help them to recover their losses, only to

solicit further funds. Once the victims

realize they have been defrauded, they are

often too embarrassed or reluctant to

report the fraud to the authorities, which

leaves the perpetrators free to continue

their schemes. 

The good news is that ICE is working to

fight telemarketing fraud. Project COLT

is a joint law enforcement initiative to

combat telemarketing fraud through

aggressive investigation and prosecution. In Project COLT, ICE works in

partnership with the Federal Bureau of

Investigation (FBI), the U.S. Postal

Service, and our allied law enforcement

agencies in Canada to intercept funds,

track suspicious wire transfers, uncover

telemarketing fraud, and, when possible,

to recover defrauded money and return

it to the victim. We’ve had outstanding

cooperation from wire transmitters, who

d o n ’t want to see their legitimate businesses abused by fraudulent schemes.

With Project COLT, ICE’s investigators

are working to shut these schemes down

and to protect seniors from financial

loss. $
TRIPWIRE

The official newsletter of Cornerstone

Secretary of Homeland Security:

Tom Ridge

Assistant Secretary, ICE:

Michael Garcia

Director of Operations, ICE:

Michael Dougherty

Director, Office of Investigations, ICE:

John Clark

Deputy Assistant Director, Financial

Investigations Division, Office of

Investigations, ICE:

Marcy Forman

Editor, Financial Investigations

Division, ICE:

Michael Kuhn

Associate Editor Financial

Investigations Division:

David Denton

The Secretary of Homeland Security

has determined that the publication of

this newsletter is necessary in the

transaction of business required by law

of U.S. Immigration and Customs

Enforcement (ICE).

ICE Web site: http://www. i c e . g o v

Address correspondence and news

contributions to:

Tripwire

Financial Investigations Division

U.S. Immigration 

and Customs Enforcement

1300 Pennsylvania Avenue, NW

Room 6.3C

Washington, DC 20229

Fax: 202-927-6476

Voice: 202-927-0840

E-mail: Tripwire@dhs.gov

MANUSCRIPT SUBMISSION GUIDELINES

Tripwire covers a broad range of topics

related to financial investigations and vulnerabilities in the financial and trade sectors. Tripwire strives to present clear

thinking by knowledgeable observers on

important issues, that can be read with

ease and pleasure by both professionals

and a general audience.

We publish pieces approximately 1,000

words long that make a single, provocative point or highlight an interesting financial investigation. Articles submitted for

publication should be no more than 3,000

words and may be edited for space and

style if selected. Tripwire does not offer

any financial compensation for any articles are images submitted and all submissions become the property of Tripwire.

We welcome unsolicited article proposals.

The way to submit material is through Email at Tripwire@dhs.gov. Accompanying

images should be submitted with the article.

The best guide to what we are looking for,

in terms of both substance and style, is

what we have already published, so

prospective authors should start by carefully examining current and recent issues

of the magazine. All submissions should

be accompanied by a brief note describing

the author's current and past positions,

recent publications, and relevant experience. We do not have fact checkers, and

rely on authors to ensure the veracity of

their statements. Although we try to avoid,

using footnotes in print, authors should be

able to provide, if asked, appropriate citations for any facts or quotations their

pieces contain.

We accept submissions on a rolling basis.

The following deadlines, however, are

worth keeping in mind in order for a piece

to be considered for a particular issue: for

the December issue, November 14; for the

March issue, February 17; for the June

issue, May 17; for the September issue,

August 16.

Any questions on these or related editorial

issues should be directed to the Tripwire

Editor at Tripwire@dhs.gov.

Invitation for Tripwire Article Submissions

$

Calendar of Events

Future Cornerstone Conferences and Training 

Cornerstone is planning and scheduling future conferences and training seminars. In

addition, as part of its outreach program, Cornerstone will offer individualized training

seminars to financial and industry sector businesses around the country. Cornerstone

subject matter experts will conduct these conferences and seminars. $

The next issue of Tripwire will feature a new name, look,

style and improved format. Tripwire is currently being

enhanced to include articles from other ICE investigative

areas that impact the U.S. economy.