On September 12-13, 2007, ICE

sponsored the Mid-Atlantic

Anti-Money Laundering Conference

at the Doubletree Hotel in Crystal

City,VA. More than 250 attendees

from the financial industry as well

as from federal and state law

enforcement agencies attended the

conference. Highlights included

keynote speaker Frank Abagnale, a

well-known consultant on fraudulent schemes and identity theft, and

the subject of the 2002 Steven Spielberg film, “Catch Me If You Can.”

Marcy M. Forman, ICE Director 

of Investigations, opened the

conference by acknowledging 

the significance of the conference

being held the day after the sixth

anniversary of the September 11,

2001 attacks. Director Forman

noted that the Mid-Atlantic AntiMoney Laundering Conference 

has provided a forum for a productive partnership between law

enforcement and private industry.

She also showcased some of ICE’s

initiatives to combat money laundering, such as ICE’s bulk currency

smuggling initiative called Operation Firewall, which has resulted in

the seizure of more than $100 million; as well as ICE’s approach to

trade-based money laundering

through Trade Transparency Units;

and Cornerstone, a comprehensive

initiative that partners ICE with the

financial industry.

Other highlights from the MidAtlantic Anti-Money Laundering

Conference included additional case

presentations from ICE, as well as

presentations by conference partners, including the Federal Bureau

of Investigation, the Internal Revenue Service Criminal Investigation,

and the Drug Enforcement Administration. KPMG LLC spoke about the

Foreign Corrupt Practices Act along

with the law firm of Miller &

Chevalier Chartered. ICE looks forward to sponsoring next year’s conference and will publicize details

when final. $

ICE Sponsors Second Annual Mid-Atlantic

Anti-Money Laundering Conference

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.

Case: Venord Multiple 

Services, Philadelphia . . . . . . 2

ICE Indicts Maryland Restaurant

Owners on Charges of Money

Laundering and Harboring 

Illegal Aliens . . . . . . . . . . . . . . 3

Case: Racketeering Charged 

in Internet Pharmacy 

Investigation . . . . . . . . . . . . . . 4

Volume IV: No. 3 • December 2007

ICE Deputy Assistant Director Matthew C. Allen speaking to attendees of the Mid-Atlantic 

Anti-Money Laundering Conference in Crystal City, Va.
Case: Venord Multiple Services, Philadelphia

The Special

Agent in

Charge Office (SAC)

in Philadelphia

began an investigation into Seide

Venord, the owner and in-house

anti-money laundering compliance

officer for Venord Multiple Services,

a money service business located at

4922 North 5th Street, in Philadelphia, PA. In this position,Venord

was a licensed money transmitter

for Western Union,Vigo Remittance

and Girosol Corporation, all Pennsylvania licensed money transmittal

businesses. SAC/Philadelphia

received information that Venord

was willing to accept and transmit

funds that were proceeds from

illicit activity.

Scheme

As part of the investigation,Venord

was approached by a cooperating

witness to conduct financial transactions that were represented to

him as proceeds of drug trafficking.

Venord arranged for the international transfers of money, and

exchanged blank money orders 

for cash. Specifically,Venord structured these transactions to evade 

the federal currency transaction

requirements and permitted the 

use of false identification and fictitious names to prevent discovery 

of the money sender’s true identity.

Venord also used more than 20 

fictitious identifications (fake 

resident alien or “green” cards,

expired driver’s licenses, etc.) all 

of which had photos of various

female and male persons.

Investigative Results

On December 13, 2004, SAC/

Philadelphia executed a search 

warrant on Venord Multiple Services, seizing $4,600 in cash as 

well as documentary evidence of

Venord’s money laundering and

illegal money transmitting activities.

Venord was interviewed and

acknowledged his familiarity with

Bank Secrecy Act and Patriot Act

requirements from the anti-money

laundering materials provided by

the money remittance corporations

for which he was an agent.

Venord was indicted by a federal

grand jury on April 19, 2005, on

43 counts of money laundering

under 18 USC 1956 (a)(3).

Venord was convicted in January

2006 on all 43 counts for his role

in laundering approximately

$267,195 in funds that he believed

to be drug proceeds through his

Philadelphia money transmittal

business to the Dominican Republic. In May 2006,Venord was sentenced to 30 months federal

incarceration, ordered to make

restitution of $25,140, ordered to

forfeit $4,660 in cash, and ordered

to pay $1,000 in court fines at 

sentencing before U.S. District Judge

John R. Padova, in the Eastern District of Pennsylvania. $

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Volume IV: No. 3

December 2007

•Reluctance to provide customers’ identification

to parent money service business company

•Using false identification and fictitious names 

for customers

•Frequent transactions or purchase of negotiable

instruments under $10,000 in order to avoid

filing a Currency Transaction Report (CTR)

Red Flag Indicators

Photos from search warrant executed at the offices of Venord Multiple Services
I

CE SAC/Baltimore reviewed a

BSA report from a

financial institution

that indicated a restaurant, located

in the Washington, D.C., metropolitan area, appeared to be structuring

their cash deposits.The information

in the Bank Secrecy Act report disclosed that the owners of the restaurant were depositing cash in $8,000

increments.The cash deposited was

in denominations of $10 and $20,

and deposited on consecutive business days. Based on this information, SAC/Baltimore special agents

began an investigation.

The investigation revealed that the

volume of bank deposit activity was

not commensurate with the business—a Peruvian rotisserie chicken

eatery charging $3.90 for a quarter

of a chicken.The investigators also

identified numerous undocumented

aliens employed at this business and

residing in a residence owned by

the restaurant business owner.

A background check of the business

owners revealed previous BSA

reports filed on the restaurant, for

structuring deposits in $9,000

increments. Previously, in 2003,

ICE’s Washington, D.C., office

participated in a seizure of more

than $500,000 from the restaurant’s bank accounts based on the

structuring violations.The restaurant civilly forfeited $300,000 

of the money seized and then

changed banks.

Investigative Results

On July 12, 2007, SAC/Baltimore

executed search warrants that

resulted in the following:

criminal arrests of the

four business owners;

seizure of $3.7 million

in cash (hidden in

kitchen cabinets and residential safes); seizure of

seven brokerage accounts

worth more than $1.5

million; seizure of five

bank accounts worth

$163,747; seizure of one

insurance policy in the

amount of $120,000; seizure of

jewelry and gold coins; and the

seizure of three vehicles.

Eight lis pendens were also filed for

seven properties in the Washington

D.C. metropolitan area. A 10-count

indictment was subsequently issued

against the four owners of the

restaurant for money laundering

(18 USC 1956 [h] and 1957),

structuring (31 USC 5324[a][3]),

alien harboring and inducing aliens

to reside in the U.S. (8 USC 1324),

and unlawful employment of aliens

(8 USC 1324). $

ICE Indicts Maryland Restaurant Owners on Charges

of Money Laundering and Harboring Illegal Aliens stoneReport

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Page 3 of 4

Volume IV: No. 3

December 2007 

Money found in safe during search warrant.

Lis pendens filed on this house in Maryland.

•Cash deposits are not commensurate with type

of business

•Structuring of cash deposits

•Large deposits on consecutive business days 

•Deposits of cash in $10 and $20 denominations

Red Flag Indicators
I

n October 2005,

an ICE-led task

force in San Diego

initiated this twoyear multi-agency investigation

against Affpower, an online pharmaceutical distribution network.The

investigation was based on information received from a cooperating

witness, who alleged that Affpower

sold controlled and non-controlled

prescription drugs through numerous affiliated Web sites to customers

without an authorized prescription.

The task force consisted of members from the FDA, IRS, FBI, USPIS,

and DEA.

The Affpower Web site was in operation from August 2004 through

June 2006. During this time,

numerous undercover purchases of

prescription drugs were made.

Additionally, Affpower allegedly

received more than one million

Internet orders for controlled and

non-controlled prescription pharmaceuticals from the United States.

On July 27, 2007, a federal grand

jury in San Diego indicted 18

individuals on 313 counts of racketeering, conspiracy to distribute

controlled substances and conspiracy to commit money laundering,

for allegedly operating an Internet

business that generated more than

$126 million in gross revenue 

from the illegal sale of prescription

pharmaceuticals to customers in 

all 50 states.

Affpower paid licensed doctors

from different states and Puerto

Rico to review health questionnaires

completed by online customers and

to issue prescriptions solely on the

basis of those answers. In some

instances, Affpower issued prescriptions for pharmaceuticals even

when a customer’s answers to the

health questionnaire suggested that

the drugs could pose a danger to

the customer, or the customer’s

medical condition did not appear to

need treatment.

The defendants included physicians,

pharmacists, a credit card processor,

and affiliate Web site operators.

Since the indictment, six of the

defendants have pled guilty to conspiracy to distribute controlled substances (18 USC 846) and

conspiracy to commit money laundering (18 USC 1956 [h]), and

some have surrendered funds as

part of a forfeiture agreement.

In an attempt to evade federal law

enforcement, Affpower’s headquarters was in Costa Rica and its computer servers were in Cyprus.The

company also relied on foreignbased agencies, including RX Payments Ltd. of Tel Aviv, Israel, to

process credit card payments.

The company is also alleged to have

used various bank accounts and 

an accounting firm in Nicosia,

Cyprus, to distribute proceeds for

Affpower while attempting to conceal and protect the illicit proceeds

from U.S. authorities.The accounting firm set up shell companies in

overseas locations with associated

shell bank accounts, putting only a

limited amount of money in each

account.The accounting firm reasoned that if U.S. law enforcement

officials were to seize one bank

account, the other accounts would

be safe.

Bank Secrecy Act reports were used

in this investigation to help identify

bank accounts that were the focus

of the asset removal portion of the

investigation. More than $9 million

has been repatriated from overseas

accounts and seized by ICE as part

of the forfeiture proceedings. $

Case: Racketeering Charged in Internet 

Pharmacy Investigation stoneReport

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Volume IV: No. 3

December 2007

•Large wire transfers from countries known as

havens for money laundering

•Nature of business is high risk for fraudulent

activity

•Credit card processing handled in a third 

country when it is not the industry norm to 

use a non-U.S. based processor

Red Flag Indicators