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. $

Financial Crime Trends: 

ICE Identifies Bulk Euro Shipments

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

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

back to Europe. 

 

 

Structuring Transactions – Criminals Continue to 

Attempt to Evade Reporting Requirements 

stoneReport

TheCorner

Rocco Fassacessia, the construction manager in charge of Manhattan for Con Edison, 

requested a bribe of four tickets to the Giants vs. Cowboys game from the president of Felix 

Industries. This photo depicts him at the game. 

Safeguarding America through 

Financial Investigations 

Toll-Free Tip Line: 1-866-DHS-2-ICE 

INSIDE THIS ISSUE 

Volume VIII: No. 1 • Summer 2011

Nathanial Ham and Consolidated 

Edison, Inc..................... 1 

HSI's Foreign Corruption Investigation 

Group Works Hard to Prevent 

Kleptocrats from Abusing U.S. Financial 

Institutions 

..................... 2 

Mario Faro: Director of Public 

Health Laboratory in Aruba 

........................... 2 

HSI Expands Organized Retail Crime 

Program.............................. 3 

Cornerstone is Homeland Security 

Investigations' (HSI's) comprehensive 

investigative initiative for fighting 

financial crime. 

The Cornerstone Report is a quarterly 

bulletin highlighting key issues related 

to HSI financial, narcotics and special 

operations investigations. 

www.ice.gov/cornerstone 

U.S. Immigration

and Customs 

Enforcement 

Nathanial Ham and 

Consolidated Edison, Inc. 

Homeland Security Investigations 

(HSI) recently concluded an 

investigation which was initiated 

in September 2005. HSI Office 

of the Special Agent in Charge, 

New York (HSI/NY) initiated an 

investigation into Nathanial Ham 

for structuring violations. Initial 

findings identified a pattern of 

suspicious financial transactions 

being conducted through Ham’s 

personal accounts maintained at 

a local credit union where he was 

serving as a member of the board 

of directors. Investigators discovered 

a large number of third-party 

check deposits from construction 

companies and subsequent 

structured withdrawals, which 

were inconsistent with Ham’s 

employment as a local government 

employee. 

From April 2000 through March 

2005, Ham, a U.S. citizen, provided 

money laundering services for 

his brother-in-law, a Consolidated 

Edison, Inc. (Con Edison) 

employee. Ham used his influence 

and knowledge of credit union 

procedures to negotiate more than 

$1.3 million worth of third-party 

checks and withdrew the proceeds, 

in amounts under the $10,000 

reporting threshold in violation of 

U.S. structuring laws. In December 

2004, pursuant to a National Credit 

Union Association audit, the credit 

union instituted internal reporting 

requirements on daily cash 

transactions conducted for amounts 

greater than $2,500. 

A Con Edison employee waiting to meet 

with a contractor to set up the “kick-back” 

payment schedule. 

From his position on the board, 

Ham knew of the new requirements 

and conducted withdrawals in the 

amount of $2,500. 
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. $

Financial Crime Trends: 

ICE Identifies Bulk Euro Shipments

Inside This Issue

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

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

back to Europe. 

 

 

 

 

 

 

 

 

 

 

Safeguarding America through

stoneReport

TheCorner

HSI's Foreign Corruption Investigations Group Works 

Hard to Prevent Kleptocrats from Abusing U.S. Financial 

Institutions. 

In May 2006, HSI/NY, in 

conjunction with the Port Authority 

of New York and New Jersey, 

Office of the Inspector General, 

and the Internal Revenue Service - 

Criminal Investigations, conducted 

several undercover meetings with 

Con Edison employees who were 

receiving “kick-back” payments in 

the form of checks and utilizing 

Ham to launder the proceeds. 

In March 2007, Ham and two 

Con Edison employees were 

arrested.The employees agreed to 

cooperate with the investigation 

and identified Felix Industries, one 

of New York’s largest contractors, 

as being involved in making “kickback” payments to Con Edison 

employees. In September 2008, 

after multiple undercover meetings, 

Felix Industries’ president was 

arrested for violation of 18 United 

States Code § 666 (theft or bribery 

concerning programs receiving 

federal funds). During the next four 

months, special agents conducted 

Seizure of approximately $6,800.00 from a 

the residence of a corrupt Con Edison 

employee. 

50 undercover meetings with Con 

Edison employees and construction 

employees who were involved in 

the illegal “kick-back” scheme. 

These employees regularly solicited 

cash bribes, cell phones, sunglasses 

and New York Giants football tickets. 

In January 2009, 12 Con Edison 

employees were arrested for 

Red Flag 

Indicators 

•	 Third-party checks deposited 

into an account with no legitimate 

business explanation. 

•	 Structured teller withdrawals and 

maximum dollar ATM withdrawals. 

•	 Occupation listed for subjects with 

suspicious financial activities is not 

commensurate with their banking 

activity. 

•	 Layering funds through multiple 

accounts maintained in the name of 

family members. 

their involvement in receiving illicit 

“kick-backs” from New York-based 

construction companies.To date, 

this investigation has resulted in 19 

arrests and 30 seizures, totaling 

approximately $1 million with 

more than $1 million in forfeitures 

pending.Those arrested include 

one bank officer, three construction 

company employees and 14 Con 

Edison employees. Of those arrested, 

16 have pleaded guilty and two have 

been convicted at trial. 

HSI’s Foreign Corruption 

Investigations Group Works Hard 

to Prevent Kleptocrats from 

Abusing U.S. Financial Institutions 

As civil unrest spreads across the 

Middle East and Africa, HSI is 

working hard to identify corrupt 

foreign political leaders who may be 

attempting to hide illicit proceeds 

in one of the most secure financial 

sectors throughout the world, the 

U.S. financial infrastructure. In 

2003, HSI established the Foreign 

Corruption Investigations Group 

(FCIG) to conduct investigations 

into the laundering of proceeds, 

emanating from foreign 

public corruption, bribery or 

embezzlement. The investigations 

are worked jointly with other 

U.S. federal law enforcement 

partners and representatives of the 

victimized foreign governments. 

The FCIG’s objectives are to 

prevent foreign-derived, ill-gotten 

gains from entering the U.S. 

financial infrastructure, to seize 

identified assets in the U.S., and to 

repatriate these funds to victimized 

governments. 

Mario Faro: Director of Public 

Health Laboratory in Aruba 

In January 2008, the HSI Attaché 

Caribbean, Miami, and the 

HSI Special Agent in Charge 

Miami FCIG initiated a financial 

investigation related to the 

alleged criminal activities of 

Mario M. Faro, the director of 

the public health laboratory in 

Aruba. Information received 

from the Aruban Special Police 

Task Force for the Netherlands, 

Faro served as former Director of National 

Laboratory in Aruba. He stole $9,000,000, 

was arrested, indicted and confessed to the 

theft. He died of heart attack in an Aruban jail 

before conviction. 

Netherlands Antilles and Aruba, 

alleged that Faro defrauded the 

Aruban government by diverting 

funds offshore into the U.S. for his 

2 Summer 2011 
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. $

Financial Crime Trends: 

ICE Identifies Bulk Euro Shipments

Inside This Issue

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

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

back to Europe. 

 

 

 

 

 

 

 

 

 

Safeguarding America through

 

 

stoneReport

TheCorner

The SEARCH Initiative (Seizing Earnings and Assets from 

Retail Crime Heists) 

own personal gain. Furthermore, 

Faro, under the auspices of his 

government position, maintained 

responsibility for the financial 

and credit departments of the 

public laboratory of Aruba. In this 

light, Faro was in the position 

to authorize, order and make 

payments for clinical supplies 

without scrutiny from government 

officials. Preliminary findings 

indicated money laundering and 

embezzlement of an estimated 

10 million guilders, which was 

the currency of the Netherlands 

before it was replaced by the Euro, 

equating to $6.7 million. 

In September 2007, the government 

lab began an internal investigation 

and audit of clinical lab purchases. 

During the investigation, officials 

learned that MediScientific and 

Labcare & Supplies corporations 

Mini Cooper seized by HSI that was purchased 

by Faro with illicit proceeds. 

were the initial two companies that 

received payments, but had not 

delivered any supplies to the Aruban 

Public Laboratory. Faro was 

determined to be an officer of 

these companies, both based in 

Miami, Fla. One of the laboratories 

was dissolved at the time the 

investigation into Faro’s illicit 

activity commenced. From 

2002 through 2005, the Public 

Health Laboratory in Aruba paid 

MediScientific approximately 5 

million florins, the Aruban currency, 

which equates to $2.8 million for 

Summer2011 

items that MediScientific never 

delivered. 

Once Faro’s scheme was discovered, 

he fled to Colombia. Documents 

seized during a search warrant by 

Dutch and Aruban law enforcement 

officials at Faro’s residence in Aruba 

resulted in the identification of wire 

transfers from Labcare to Faro’s 

personal bank account. In addition, 

copies of spreadsheets were located, 

which identified the entire scheme 

from the Aruban central accounts 

department to the invoices, 

payments, and payees Faro used 

to launder money in his official 

capacity. Additional suspects were 

also identified in the search warrant 

for their role in falsifying invoices. 

On February 29, 2008, Faro was 

arrested in Miami as the result of 

a mutual legal assistance treaty 

between the U.S. and the Kingdom 

of the Netherlands, which includes 

Aruba. Faro waived his extradition 

Red Flag 

Indicators 

•	 Government purchases for goods 

are never received by the purchasing 

government agency. 

•	 General accounting procedures 

for purchases of government 

equipment and use of government 

funds are not followed. 

•	 Accumulated financial wealth by 

government officials is inconsistent 

with that reported on mandatory 

financial disclosure forms for 

government officials. 

to Aruba on March 31, 2008. 

During the same time period, the 

FCIG identified bank accounts and 

personal property, which were later 

seized as a result of Faro’s arrest. 

This included $167,000 discovered 

in U.S. bank accounts established 

by Faro. On June 26, 2009, Faro 

passed away in an Aruban jail while 

awaiting his trial for corruption 

and embezzlement. It is anticipated 

that the U.S. forfeited monies and 

personal property will be returned 

to the Aruban government in the 

near future. 

HSI Expands Organized Retail 

Crime Program / The SEARCH 

Initiative (Seizing Earnings and 

Assets from Retail Crime Heists) 

Partnerships with retail industry seen 

as key to ongoing success 

Homeland Security Investigations 

(HSI) announced the expansion 

of its Organized Retail Crime Pilot 

Program into an ongoing, national 

initiative, now known as the 

SEARCH Initiative. 

Organized retail crimes are the 

orchestration of schemes to convert 

stolen goods to cash, and involve 

individuals who serve as boosters 

within organized criminal networks. 

The challenge of combating these 

networks is best accomplished 

through federal anti-money 

laundering statutes, which may 

result in severe penalties. 

“This type of organized, criminal 

activity is commonly looked at as a 

local problem,” said James Dinkins, 

executive associate director, ICE 

HSI. “The lack of visibility outside 

a jurisdiction can contribute to the 

appearance that it is a local problem, 

but federal investigations have 

proven the level and sophistication 

of criminal enterprises involved in 

ORC is often times much greater.” 

3 
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. $

Financial Crime Trends: 

ICE Identifies Bulk Euro Shipments

Inside This Issue

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

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

back to Europe. 

 

 

 

 

 

Safeguarding America through

 

 

 

 

 

 

 

 

 

 

stoneReport

TheCorner

The SEARCH Initiative (Seizing Earnings and Assets from 

Retail Crime Heists) 

The Organized Retail Crime Pilot 

Program (ORCP), which launched 

on July 6, 2009, in Houston, Los 

Angeles, Miami and New York, 

focused on building partnerships 

with the retail industry and 

developing a series of tools to 

assist law enforcement in threat 

assessments, case tracking, and most 

significantly, an in-depth analysis 

of how organized crime rings are 

exploiting systemic vulnerabilities 

in the banking system to launder 

their profits. 

The SEARCH Initiative will 

incorporate all aspects of the ORCP 

and expand upon HSI’s productive 

partnerships with private industry 

from the key cities identified 

through the pilot program to other 

cities across the nation. HSI pursues 

these public/private partnerships 

in accordance with the guiding 

principle within the Department 

of Homeland Security’s Strategic 

Plan of building trust through 

collaboration. 

As of February 2011, more than 

83 HSI criminal investigations have 

been linked to the ORCP. These 

investigations have resulted in 38 

criminal arrests, 29 indictments, 

14 convictions, 237 seizures, the 

execution of 18 search warrants, 

and 15 administrative arrests. These 

investigations have also led to the 

seizure of nearly $4.9 million 

in cash, property, and monetary 

instruments. HSI’s partnerships with 

private industry, the National Retail 

Federation and the Retail Industry 

Leaders Association have been 

significant to the success of 

the coordinated effort to combat 

organized retail crime. 

In 2006, the Organized Retail Theft 

Bill was passed in response 

to an estimated $30 billion in 

merchandise losses from retail 

stores each year. Losses resulting 

from ORC rings represent a distinct 

risk to our nation’s economic 

infrastructure and this legislation 

provides an avenue for law 

enforcement to partner with the 

private sector in an effort to identify 

and track organized retail theft. 

HSI is involved in a myriad of 

investigations that target a wide 

range of criminal activity, including 

money laundering, narcotics 

trafficking, illegal imports and 

exports, intellectual property 

rights, human smuggling and 

trafficking, gang enforcement, 

and human rights violations. 

Broad immigration and customs 

authorities enable HSI to pursue 

complex banking and financial 

misconduct cases to identify, 

dismantle and disrupt the financial 

criminal enterprises that threaten 

our nation’s economy and 

homeland security. 

Red Flag 

Indicators 

•	 Business checks written to individuals 

as opposed to legitimate suppliers. 

•	 Business checks cashed at the 

banks where the checks originated 

from instead of being deposited into 

another business’ bank account. 

•	 Business checks written to cash on a 

regular basis in amounts that exceed a 

business’ petty cash requirement. 

•	 Multiple checks written on 

the same day in amounts less than 

$10,000, possibly to avoid reporting 

requirements, despite the fact that 

checks would not normally generate 

currency transaction reports. 

•	 Multiple checks written on the same 

day to cash, to ensure the amount of 

each check does not exceed $10,000. 

•	 Multiple money orders in increments 

of $500 or less deposited into 

bank accounts where the remitter 

of the money order is the same as 

the authorized signers on the bank 

accounts for which the checks 

are being deposited. 

•	 Subjects of questionable financial 

transactions all maintain the same 

address. 

•	 Occupations listed for the subjects of 

questionable financial activities are not 

commensurate to the volume and type 

of the financial activities. 

•	 Checks drawn from the questionable 

financial activities are negotiated in 

foreign countries. 

•	 Cash deposits related to the 

questionable financial activities 

involved currency in $100 

denominations. 

4 Summer 2011