TheCorner stoneReport

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. 

ICE Cracks Boston, 

Dominican Money 

Laundering Scheme. . . . . 2 

Yemeni Currency 

Smuggling, Loan Shark 

Ring Targeted by ICE . . . . 3 

ICE Investigation Uncovers 

Drug Money 

Laundering Scheme. . . . . 4 

Volume V: No. 1 • April 2008 

Financial Crime Trends: 

ICE Identifies Bulk Euro Shipments 

New money laundering trends show euros being laundered through Colombia and the U.S. 

back to Europe. 

Billions of euros and U.S dollars 

entering the U.S. in 2006 and 

the first three quarters of 2007 were 

exported from Latin American and 

Caribbean-based countries. Information from the Federal Reserve and 

statistical analysis generated from 

ICE's specialized computer system 

called the Data Analysis & Research 

for Trade Transparency System 

(DARTTS) confirm that Colombian 

“casas de cambio” are being used to 

physically move bulk currency rather 

than through established bank-tobank transfers. DARTTS is an analytical software program that assists 

agents and analysts to detect and 

track potential money laundering, 

contraband smuggling and trade 

fraud by analyzing trade and other 

data in ways not previously available. 

Recent investigative analysis using 

DARTTS identified bulk shipments 

of euros moving from Colombia to 

the United Kingdom via the United 

States. From 2006-2007, Colombian 

casas de cambio shipped bulk currency valued at $4.8 billion to various U.S. ports of entry. Euros and 

U.S. dollars were manifested and 

shipped as cargo aboard U.S.-bound 

flights from Colombia. Upon arrival 

to the U.S., International Transportation of Currency or Monetary 

Instruments Reports are filed by 

armored car couriers who transport 

the currency from the U.S. airport 

to banks or secured storage facilities 

used by foreign exchange companies. If the currency is in U.S. dollars, it is deposited into U.S. bank 

accounts belonging to U.S.-based 

foreign currency establishments. 

Wires are then sent to the designated bank accounts of the Colombia-based casas de cambio, thereby 

converting dollars into pesos.This 

mechanism can allow for the placement, layering and integration of 

proceeds from known and 

unknown sources into U.S. and foreign financial sectors. When the 

currency is in euros, it is processed 

by the U.S.-based foreign exchange 

companies and ultimately sold to 

European currency dealers and 

shipped to Europe. 

Recent trends indicate that euros are 

originally smuggled from Europe to 

Colombia and other South American countries. Euros in Colombia 

and/or Peru are sold by Colombian 

or Peruvian-based casas de cambio 

to U.S.-based exchange houses and 

legitimately transported into the 

U.S. With the completion of the 

sale, funds are wired back to the 

seller. This kind of bank-to-bank 

transfer converts U.S. dollars into 

Colombian or Peruvian pesos. $
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ICE Cracks Boston, Dominican Money Laundering Scheme 

This licensed money services business in Boston was the target of an ICE money 

laundering investigation. 

Red Flag Indicators 

•Frequent wire transfer activity with little longterm investment in the account 

•Sudden increase in unexplained or extensive wire 

transfers 

•Frequent deposits of third-party checks and 

money orders 

•Reluctance to provide identification when 

making large deposits 

•Splitting or "smurfing" deposits in an attempt to 

avoid reporting requirements 

•Frequent deposits into and/or withdrawals from 

accounts that were opened in different areas of 

the country 

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Page 2 of 4 

Volume V: No. 1 

April 2008 

recent ICE Corner

r

investigation in 

the Boston area 

revealed how a 

licensed money 

services business 

was serving as a front for an international money laundering scheme 

tied to drug trafficking. 

ICE, in conjunction with several 

U.S. and international law enforcement agencies, investigated the 

money laundering activities of 

Santo Melo and Claudio Tejeda 

Andujar, who were doing business 

as Boston Envio de Valores, Inc. 

(Envio). The business operated 

as a licensed money service business and was sending in excess of 

$10 million per year to the 

Dominican Republic, the majority 

of which was alleged to have been 

narcotics proceeds. 

Between September 2004 and 

March 2006, Melo and Tejeda 

Andujar conspired to launder 

money that had been represented as 

drug proceeds. A two-year "sting" 

operation was conducted during 

which a cooperating witness 

brought cash to Envio, representing 

the funds to be drug trafficking 

proceeds, and requested that the 

money be wired to the Dominican 

Republic. 

Investigative Results 

Melo, president of Envio, was 

charged in an indictment with 

conspiracy to commit money 

laundering and other charges. 

Tejeda Andujar was also charged 

with money laundering conspiracy, 

conspiracy to distribute cocaine 

and two counts of distribution 

of cocaine. 

Jose Garcia, a former employee of 

Envio, was indicted on 10 counts of 

failure to report a cash transaction 

exceeding $10,000. The charges 

against Garcia relate to 10 occasions 

when Garcia handled transactions of 

more than $10,000 in cash and 

failed to file required currency 

transaction reports. 

The investigation concluded with 

the simultaneous execution of 

numerous arrest, search and 

seizure warrants in Boston and 

the Dominican Republic. A total 

of $165,988 was seized during a 

search of the business and funds 

were seized from the business’s 

bank account in Boston. In the 

Dominican Republic, 11 individuals 

were arrested, several of whom 

were Tejeda Andujar's immediate 

family members. In addition, items 

seized included $42,000 in cash, 

three vehicles, four motorcycles 

and four firearms. $
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Corner

Yemeni Currency Smuggling, Loan Shark Ring Targeted by ICE The

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Page 3 of 4 

Volume V: No. 1 

April 2008 

n ICE investiga­ p

tion in New 

York illustrates how 

seemingly legitimate transactions 

were used to mask a 

massive currency smuggling 

scheme that illegally transported 

more than $5 million to the Middle 

Eastern nation of Yemen. 

This case was initiated as a result of 

several outbound courier mail 

inspections conducted at the mail 

facility at JFK International Airport 

that focused on parcels being 

shipped from New York to Yemen. 

One package contained checks 

drawn on the pension trust account 

of Neil S. Kramer, a New York attorney.These checks were consecutively written in the amount of 

$9,000 each and mailed from different addresses of businesses in the 

New York Yemeni community. 

Subsequent investigation revealed 

that Kramer, attorney Michael Weisberg, real estate broker Isadore 

Userowitz and other co-conspirators were involved in a scheme that 

involved a fraudulent pension trust 

fund, lawyer's escrow accounts and 

shell corporations to facilitate and 

conceal a major currency smuggling and "loan sharking" operation 

in the New York metropolitan area. 

ICE worked this investigation jointly 

with the New York offices of the Federal Bureau of Investigation (FBI) and 

the Internal Revenue Service (IRS). 

The investigation identified two separate schemes employed by the defendants. In the first scheme, Kramer, 

Userowitz and six other conspirators 

were charged with operating an unlicensed money transmitting business. 

Four of the co-conspirators, who are 

Yemeni expatriates, collected monies 

from other Yemeni expatriates in the 

United States for shipment to known 

money remitters in Yemen.These 

four defendants gave the cash to 

Kramer, Weisberg and Userowitz, 

who issued checks in corresponding 

amounts from their professional 

checking accounts. 

The conspirators then would 

arrange for couriers traveling to 

Yemen to smuggle the checks out 

of the United States without filing 

currency transaction reports with 

the U.S. government as required by 

law. Using this method, more than 

$5 million was smuggled to Yemen 

in a 16-month period. 

The second scheme operating during 

the same time period involved 

unlawful money lending or "loan 

sharking." Yemeni expatriates in need 

of cash were introduced to Kramer, 

who provided loans ranging in 

amounts from $5,000 to $100,000. 

In return, the borrowers were 

required to sign a "confession of 

judgment," wherein the debtor 

"confesses" an amount due to a 

creditor before any lawsuit is filed 

and the creditor can use it to obtain 

judgment if the debtor does not 

make restitution. A confession of 

judgment requires the debtor to 

waive important due process rights, 

such as the right to a trial by jury, 

and is not legally recognized in 

many states. In addition, the confession of judgment left blank the 

amount of the loan, the terms of the 

loan and the due date - all to be 

filled in at a later time by the defendants. In some instances, the debtors 

were required to surrender the leases 

to their businesses, as well as their 

travel and residency documents, such 

as U.S. Citizenship and Immigration 

Red Flag Indicators 

•Multiple third-party endorsed financial 

instruments 

•Structuring cash deposits 

•Multiple deposits of non-bearer instruments 

•Different handwriting between payee, endorser 

and/or amounts 

•Frequent visits to safe deposit boxes 

•Irregular credit to debit ratios 

•Multiple check endorsements 

•Multiple overseas check endorsements 

•Financial transactions split among multiple 

accounts 

•Unusually friendly relationships between 

customers and bank teller 

Service Permanent Resident Alien 

Cards ("green cards") and passports, 

until their debts were paid in full. 

Investigative Results 

The investigation resulted in 12 

criminal arrests as well as the seizure 

of $2.2 million from the defendants' 

bank accounts and an additional $1 

million in cash from a defendant's 

safety deposit box. In addition, two 

vehicles were seized and numerous 

lis pendens (forfeiture liens) were 

filed against properties with a net 

market value of $20 million. 

Kramer pleaded guilty to conspiring 

with others to operate an unlicensed money transmitting business 

and agreed to forfeit approximately 

$1.2 million seized at the time of 

his arrest. 

On December 7, 2007, charges were 

brought against 11 defendants, 

including eight previously arrested 

subjects and three new subjects with 

charges that included conspiracy; 

operating an unlicensed money 

transmitting business; failure to 

declare international transportation 

of U.S. currency; and structuring 

transactions to avoid filing Currency 

and Monetary Instrument Reports. $
ICE Investigation Uncovers Drug Money 

Laundering Scheme oneReport

TheCorner

Page 4 of 4 I

Volume V: No. 1 

April 2008 

n August 2003, st

ICE initiated 

Operation Rainmaker, a long-term 

multinational, multi-agency investigation into a money laundering and 

drug trafficking organization.This 

organization allegedly laundered 

drug proceeds through the Black 

Market Peso Exchange (BMPE), a 

large-scale international money 

laundering system used by South 

American drug lords to convert 

dollars into pesos. 

The investigation identified a 

traditional BMPE scheme being 

employed to launder drug money 

to Colombia. Drug trafficking 

proceeds in the U.S. were used to 

purchase textiles from 

U.S. companies.These textiles were 

then exported to companies in 

Colombia and sold, with the proceeds ultimately paid to Colombian 

drug trafficking organizations. 

ICE initiated an undercover operation that infiltrated the criminal 

organization and identified over 65 

people involved in the BMPE 

scheme.The investigation eventually 

grew to include ICE offices in New 

York, Philadelphia, Boston, Miami, 

Puerto Rico, Mexico, Colombia and 

Panama.The investigation was 

worked in conjunction with the 

Internal Revenue Service (IRS) 

Criminal Investigation office in 

Atlanta and ICE attaché offices in 

Mexico, Colombia and Panama. 

The organization arranged for drug 

proceeds in the form of U.S. dollars 

to be collected by undercover agents 

for ultimate placement in financial 

institutions in numerous locations, 

ICE’s Operation Rainmaker led to the seizure of more than $8.5 million in alleged 

drug proceeds. 

including New York; Brockton, 

Mass.; Atlanta; Philadelphia; and 

Puerto Rico.Then, an equivalent 

amount of Colombian pesos was 

delivered to the organization in 

Colombia. In some instances, following the collection and placement 

of the currency, the U.S. dollars, less 

a commission, were wire transferred 

into bank accounts in the United 

States and elsewhere, as instructed 

by the organization. 

During the course of the investigation more than $8.5 million in 

alleged drug proceeds were seized. 

In addition, 26 kilograms of 

cocaine and more than two kilograms of heroin were also seized. 

For this case: 

•Increase in unexplained cash activity in a 

bank account 

•Deposits of sequentially numbered money orders 

•Money is wired into an account and subsequently 

wired out of the account in the same (or close 

to the same) amount 

For BMPE in general: 

•Payments to business in cash by unrelated third 

parties 

•Payments to business through wire transfer 

from unrelated third parties 

•Payments for goods through checks, bank drafts 

and postal money orders 

Red Flag Indicators 

In April 2006, 30 individuals were 

indicted by a federal grand jury in 

Atlanta as a result of the investigation. Twenty-five of those subjects 

have been arrested and five remain 

fugitives at large. Nineteen individuals have since pled guilty, with the 

most recent plea coming in December 2007. The majority of the individuals pled guilty to a conspiracy 

to launder drug proceeds; they face 

prison sentences ranging from 24 

months to 108 months. $