Border Enforcement Security

Taskforces (BEST) 

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. 

Operation Sugar Crisp . . . 3 

Jury Convicts Olympic 

Medalist and Three Others 

in Massive Bank Fraud 

and Money Laundering 

Scheme . . . . . . . . . . . . . . . 4 

Volume V: No. 2 • June 2008 

(l to r) Rio Grand Valley BEST 

ammunition seizure; Tucson 

BEST marijuana; and Laredo 

BEST Seizure of hand 

grenades and Improvised 

Explosive Devices (IEDs). 

ment Administration (DEA), the 

Bureau of Alcohol,Tobacco, Firearms 

and Explosives (ATF), the Federal 

Bureau of Investigation (FBI), the 

U.S. Marshals Service, and U.S. Attorney’s Office, as well as key state and 

local law enforcement agencies. Also 

participating on the task force is 

Mexico’s Center for Investigation 

and National Security (CISEN). Each 

BEST focuses on combating crossborder criminal activity within its 

geographic region. 

The United States and Mexico work 

jointly under the Security and Prosperity Partnership (SPP) for North 

America (along with Canada). BEST 

is one of several working groups 

that was established or expanded to 

implement the SPP. 

The agencies listed above aid with 

the collection and analysis of 

intelligence and coordinate efforts 

to identify and disseminate information related to violent smuggling 

organizations. BEST has been highly 

successful in combating violence 

in the Laredo area, which served 

as an impetus for the expansion 

of the program along the entire 

southern border. 

continued 

Our nation’s Southern border 

has experienced a dramatic 

surge in cross-border crime and 

violence in recent years due to 

intense competition between Mexican drug cartels and criminal smuggling organizations that employ 

predatory tactics to maximize their 

profits.The drug cartels’ struggle 

for power was so marked in its use 

of violence, extortion and corruption, it resulted in destabilizing the 

city of Nuevo Laredo. In response to 

the crippling effects of the predatory and violent tactics on the city, 

ICE established the first Border 

Enforcement Security Taskforce 

(BEST) in Laredo,Texas. ICE partnered with Mexican law enforcement agencies and its federal, state, 

and local law enforcement counterparts in the United States to create 

multi-agency border security task 

forces or BEST team. The task forces 

are designed to increase information sharing and collaboration 

among the agencies combating the 

escalating criminal activity and violence on both sides of the border. 

BEST incorporates personnel from 

ICE, U.S. Customs and Border Protection (CBP), the Drug Enforce-
t

T

Border Enforcement Security Taskforces (BEST), continued 

he

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Page 2 of 4 

Volume V: No. 2 

June 2008 

There are now five Corner

r

BESTs in place 

along the U.S.-Mexico border.The task 

forces are located 

in the Texas border 

cities of Laredo, El Paso and Harlingen, as well as in Tucson, Ariz., 

and San Diego, Calif. With the 

implementation of the Rio Grande 

Valley BEST in March 2007, ICE 

completed the Southwest Border 

expansion plan that began in 

Laredo in 2005. The BEST teams 

(also located in, El Paso, Arizona 

and California) target the primary 

criminal activity or criminal threats 

identified in their respective areas 

of responsibilities. 

The BEST initiative has substantially 

enhanced the partnerships between 

U.S. and Mexican law enforcement 

along the border. In Texas, the 

heightened cooperation has resulted 

in the successful return of criminal 

fugitives being sought in both 

countries, including the removal to 

Mexico of Jorge Guevara-Perez, one 

of that nation’s Top Ten Most 

Wanted fugitives, wanted for kidnapping and murder, who was 

arrested in El Paso earlier this year. 

Border-related arms and ammunition smuggling investigations in 

Texas and Arizona have led to 

numerous criminal arrests and the 

seizure of thousands of rounds of 

ammunition and multiple firearms, 

including a cache of AK-47 assault 

rifles destined for Mexico that were 

intercepted last January. 

In 2007, San Diego BEST agents discovered two underground tunnels 

located along the international border near Otay Mesa, Calif. Both tunnels were under construction.To 

date, more than 30 cross-border 

tunnels have been discovered along 

the California-Mexico border where 

the San Diego BEST agents work 

joint tunnel investigations with 

their Mexican counterparts. 

The success of the BEST program 

along the Southwest Border has 

made it ideal for replication along 

the Northern Border. On February 

4, 2008, the first Northern Border 

BEST was opened in Blaine, Washington and a second BEST was initiated in Buffalo, New York in March 

2008. Additionally, in 2008, ICE is 

seeking to introduce the BEST concept to the seaport environment. 

ICE plans on establishing BESTs 

at the ports of Los Angeles/Long 

Beach, New York/Newark, and 

Miami. The planning for these 

new task forces will focus on all 

aspects of the enforcement process, 

from interdiction to prosecution 

and removal.The goal—to dismantle the leadership and supporting 

infrastructure of the criminal 

organizations responsible for perpetrating violence and illegal activity 

along our borders and in the 

nation’s interior. 

(Top) Laredo BEST weapons seizure. (Above) 

Money seized from search warrant at one of 

the gas stations. 

In fiscal year (FY) 2007, the BESTs 

were responsible for 519 criminal 

arrests, 1,145 administrative arrests, 

283 indictments, and 155 convictions and has seized 2,066.79 

pounds of cocaine, 52,518.54 

pounds of marijuana, 231.53 

pounds of methamphetamine, 18.87 

pounds of crystal methamphetamine, 215.79 pounds of heroin, discovered two tunnels, seized 237 

weapons, 12 improvised explosive 

devices, 178 vehicles, and approximately $2.9 million in U.S. currency 

and monetary instruments. $
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ort

The

Re stone

Page 3 of 4 

Volume V: No. 2 

June 2008 

p

Operation Sugar Crisp 

I

n October 2003, 

the Special Agent 

in Charge Office 

(SAC) in Atlanta 

began an investigation into Sugar Bear, 

Inc. (Sugar Bear), a Georgia company that operated multiple gas stations and convenience stores in the 

metro Atlanta area. Sugar Bear was 

allegedly involved in a complex 

money laundering scheme that 

involved the hiring and harboring 

of illegal aliens and tax evasion. 

During the course of the investigation, special agents learned that 

Sugar Bear was owned and operated 

by the Karimi family, with the two 

corporate owners being Malik 

Karimi and Mansoor Karimi. Sugar 

Bear owned and operated 13 gas 

stations/convenience stores in the 

metro Atlanta area. Another Karimi 

family member, Ramzan Ali Karimi, 

also owned five gas stations/convenience stores under the corporate 

name of M2Z2 Com. Inc, and GA 

C-Store, Inc. All of the gas stations/ 

convenience stores were involved in 

the money laundering scheme. 

The Karimi organization and its 

lessees employed 50–150 undocumented alien workers per year since 

approximately 1994. Employment 

of undocumented alien workers 

maximized profits through nonpayment of overtime compensation 

rate, employer-share taxes and 

employee benefits. U.S. Department 

of Labor (USDOL) estimates labor 

cost savings at $6,000 to $8,000 

per employee per year.The defendants invested the criminal proceeds 

in real estate ventures. 

Analysis of Currency Transaction 

Reports (CTR) associated with the 

defendants and their corporate entities identified bank accounts 

involved in the criminal scheme, 

additional corporate names and 

aliases, and a significant amount of 

money being deposited into the 

bank accounts. Grand Jury subpoena 

responses were used to establish the 

financial network between the principal defendants and their co-conspirators.The information obtained 

from the CTRs also helped to establish the conspiracy and identify the 

co-conspirators. SAC/Atlanta contracted with a third party forensic 

accountant team to provide analysis 

of the impact that the defendants’ 

use of undocumented alien workers 

had on profitability, unfair market 

share and other factors related to 

quantifying criminal proceeds.This 

analysis demonstrated the economic 

motive of the criminal conspiracy 

and established additional evidence 

related to the presence of an organized criminal conspiracy. 

On November 3, 2004, the United 

States Attorney’s Office in the Northern District of Georgia, indicted the 

investigative targets of Operation 

Sugar Crisp on felony counts of 

Conspiracy and Alien Smuggling. On 

November 9, 2004, special agents 

from the SAC/Atlanta executed 19 

arrest warrants, 32 Search Warrants, 

28 Lis Pendens against real properties, and 60 Seizure Warrants against 

bank accounts and other financial 

holdings. During the execution of 

the warrants, 19 individuals were 

located and arrested, 13 material 

witnesses were taken into administrative custody, approximately $4.1 

million in financial assets were 

seized, and approximately $20 million in real properties were encumbered through Lis Pendens. 

Red Flag Indicators 

•Cash-heavy transactions; employees are paid 

largely in cash. 

•References to third-party lease agreements for 

business locations; this creates a “corporate veil,” 

which obscures the party that can be held responsible for criminal acts related to the business (and 

potentially for financial liabilities related to the 

operation of the business—which would be of 

particular interest to the banking industry). 

•References to employer-share taxes and other 

corporate expenses that appear inconsistent 

with the number of employees that should be 

required to run the business; illegal employees 

in a labor-racketeering scenario will not be 

reported/claimed by the employer (e.g. 

reference to only three employees for a 24-hour 

gas station/convenience store are likely to be an 

instance of underreporting of employees). 

At the present date, the four indicted 

defendants, Ramzan Karimi, Allauddin Karimi, Air Merchant, and 

Ameen Hakani, have pled guilty to 

misdemeanor charges of Alien 

Smuggling, 8 USC 1324a(f)(1).The 

negotiated pleas generated sentences 

to probation and asset forfeiture of 

approximately $750,000. 

On November 29, 2007, Malik 

Karimi, pled guilty to misdemeanor 

charges of Alien Smuggling, 8 USC 

1324a (f)(1), for which he received 

three year’s probation and agreed to 

forfeit $1,000,000. The corporate 

entity, Sugar Bear pleaded guilty to 

felony violations of 8 USC 1324, 

encouraging and inducing aliens to 

enter and/or remain in the United 

States.The corporation was sentenced to five-year probation and 

ordered to pay a $15,000 fine. 

The ICE SAC/Atlanta office obtained 

significant assistance from the Postal 

Inspection Service, the Office of the 

Inspector General, U.S. Department 

of Labor, and the Office of the 

Inspector General, U.S. Social Security Administration. $
Jury Convicts Olympic Medalist and Three Others in 

Massive Bank Fraud and Money Laundering Scheme oneReport

TheCorner

Page 4 of 4 I

Volume V: No. 2 

June 2008 

n April 2005, the st

ICE Office of 

Investigations, SAC 

New York, El Dorado 

Task Force (a multi-agency financial 

crimes task force), received information from a financial institution that 

a $775,000 check was deposited 

into one of their customer’s investment accounts and the funds were 

subsequently withdrawn before the 

check was reported as stolen. It was 

later determined that the $775,000 

check was stolen from the mail and 

given to Toybe Bennett, a principal 

conspirator in the organization. Bennett engaged the assistance of Douglas Shyne to launder the proceeds 

of the stolen check. 

Shyne, with assistance from his girlfriend and others, created fictitious 

incorporation and identification 

documents and rented mail drops 

in the name of the check’s payee. 

Bennett, acting as the company’s 

president, duped a financial institution into opening an investment 

account with this check. Over a 

two-month period, the co-conspirators exhausted the funds by laundering over $250,000 through shell 

companies and through other coconspirator’s personal and business 

accounts. With the balance, they 

purchased high-end vehicles, cosmetic surgery and jewelry. 

Shyne and his girlfriend jointly 

owned two businesses that were 

used to cover widespread check 

fraud. Stolen checks were cashed 

and laundered by co-mingling them 

and depositing them with other 

funds collected by the “legitimate” 

businesses. Additionally, Shyne and 

his co-conspirators altered checks 

(Left) Residence in New Jersey bought with unlawful proceeds and seized by ICE. (Right) Ferrari bought with proceeds of crime and seized by ICE. 

that they had legitimately received 

by listing a different payee’s name 

and a different payment amount. 

By August 2005, ICE agents 

obtained arrest warrants and two 

search warrants based on charges of 

money laundering, bank fraud, and, 

identity theft.The search warrants 

resulted in the seizure of a home, 

cash, jewelry, high-end electronics, 

a Maserati and a Ferrari. 

The agents continued to pursue 

additional targets of this conspiracy 

that included Timothy Montgomery, 

a former Olympic gold medal athlete. ICE agents determined that 

Montgomery along with other individuals were responsible for depositing at least seven fraudulent checks 

obtained from Shyne and others, 

totaling approximately $2.5 million. 

In May 2005, Montgomery 

deposited a counterfeit check for 

$200,000 into a business account he 

jointly controlled with Marion Jones, 

another Olympic gold medalist. 

Jones had also deposited a $25,000 

check into her personal account, 

which was determined to be the 

proceeds of a counterfeit check. 

ICE agents interviewed Jones in 

August and September 2006 concerning her involvement with the 

check fraud and money laundering 

scheme. During the interviews, Jones 

•Frequent deposits into an account by other than 

authorized individuals. 

•Deposit of checks drawn off the account of a 

business that does not coincide with the type 

of business or activity in which customer is 

normally engaged. 

•Transfer of funds to a commercial account with 

no logical relationship or connection to the 

sender (shell account). 

•A down payment on a leased vehicle that 

is far greater than the required cost cap 

reduction (to conceal proceeds and shield 

vehicle from seizure). 

Red Flag Indicators 

repeatedly lied about her involvement and her knowledge. In April 

2007, while preparing for her testimony in the trial of Montgomery 

and others, Jones confessed to her 

role in the scheme. On the eve of 

trial, Montgomery pleaded to bank 

fraud and money laundering counts. 

Montgomery and Jones’ sports 

agent, Charles Wells, also pleaded 

guilty to bank fraud charges. In January 2008, Jones was sentenced to 6 

months in jail for making false statements in this investigation. 

In total, 29 targets of this investigation were arrested, all resulting in 

conviction through plea agreements 

or guilty verdicts following a trial. 

Agents were also able to forfeit a 

portion of the proceeds of the 

fraud, thereby mitigating some of 

the losses incurred by the involved 

financial institutions. $