New Center Boosts 

Intellectual Property Investigations 

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. 

El Dorado Task 

Force Investigation . . . . . 2 

Doleiro—The Black 

Market Foreign 

Exchange in Brazil . . . . . . 4 

Operation 

Living Large . . . . . . . . . . . 4 

Volume VI: No. 1 • January 2009 

The ICE-led National Intellectual 

Property Rights Coordination 

Center (IPR Center) is the U.S. government’s latest weapon in the fight 

against violations of intellectual 

property rights (IPR) laws. 

Located in Crystal City,Va., the 

multi-agency IPR Center is responsible for coordinating a unified U.S. 

government response regarding IPR 

enforcement issues, with participation from ICE and other federal 

agencies.The IPR Center serves as a 

fusion point for intelligence on IPR 

violations from other government 

agencies, industry, transportation 

providers and others. IPR Center 

partners employ a three-pronged 

approach of investigation, interdiction and outreach in the fight 

against IPR crime. 

ICE is committed to protecting U.S. 

financial systems by proactively 

addressing vulnerabilities that 

undermine our economic security. 

The growing threat to industry, 

the American public and our economy associated with IPR violations 

has been the catalyst for a partnership between government and 

industry. ICE encourages anyone 

with information regarding possible 

IPR violations to call (866) IPR2060 or go to www.ice.gov to 

submit a report electronically. $

Recent Outreach Events 

June 2008 ICE cohosted the Mid-Atlantic 

Anti-Money Laundering 

Conference in Crystal 

City, Va. More than 500 

people attended this 

event, including representatives from private 

industry and law 

enforcement. 

August 2008 Director 

Marcy M. Forman spoke 

at the International 

Association of Financial 

Crimes Investigators 

(IAFCI) annual training 

conference in Hollywood, Calif. Members of 

the Financial Programs/ 

Cornerstone Unit (FPCU) 

unveiled their new 

Director Marcy M. Forman 

with IAFCI International 

President Werner R. Raes. 

Cornerstone booth to 

more than 1,200 members of the IAFCI. 

August 2008 FPCU 

Program Manager Jason 

Gialanella attended 

the National Retail Federation Regional Conference in San Francisco 

to learn more about 

organized retail crime, 

and to explain to the 

retail industry how ICE 

can assist in combating 

this growing problem. 

September 2008 

FPCU Program Manager 

Kevin Tyrrell spoke at the 

California Department of 

Financial Institutions 

annual conference in 

Monterrey, Calif. to explain what ICE is doing to 

prevent the illegal movement of money across 

our nation’s borders. 

October 2008 FPCU 

Acting Unit Chief John 

Tobon presented at 

the 3rd annual forum 

on Anti-Money Laundering & Counter-Terrorist 

Financing regarding 

how ICE uses BSA 

filings when conducting 

investigations. 

October 2008 Director Marcy M. Forman 

spoke at the American 

Banker’s Association/ 

American Bar Association Money Laundering 

Enforcement Conference 

in Washington, D.C. The 

FPCU, as part of Cornerstone’s outreach initiative, worked alongside 

other exhibitors to talk 

with conference attendees about ICE and its 

various financial investigative programs. 
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El Dorado Task Force Investigation 

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January 2009 

n March 2006, Corner

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ICE agents from 

the Office of the 

Special Agent in 

Charge in New York 

assigned to the El 

Dorado Task Force initiated an 

investigation into possible IPR violations. In September 2007, this 

investigation resulted in 29 defendants being charged in three separate complaints with conspiracy to 

smuggle more than 950 shipments 

of merchandise, including counterfeit merchandise, into the United 

States, principally from China. 

The charges were the result of a 19-

month coordinated partnership by 

ICE agents and CBP officers. These 

shipments were smuggled through 

ports of entry at Newark, N.J., 

Houston,Texas, Long Beach, Calif., 

the New York Container Terminal in 

Staten Island, N.Y., and John F. 

Kennedy International Airport. 

Many of the suspects were also 

charged with conspiracy to traffic 

counterfeit goods. Additionally, four 

of the defendants were charged 

with money laundering. During the 

investigation, multiple Bank Secrecy 

Act (BSA) reports helped identify 

numerous bank accounts and business locations, greatly enhancing 

the investigation. 

The investigative techniques 

employed by ICE and CBP included 

the use of cooperating witnesses, 

undercover agents, and video and 

audio surveillance. During the 

course of their investigation, ICE 

agents and CBP officers seized 

counterfeit merchandise which, had 

it been authentic, ICE and CBP estimate would have been valued at 

approximately $700 million. 

Importation of Merchandise 

into the United States 

Shipments of merchandise arriving 

at United States ports must be 

cleared, or granted entry, by CBP 

prior to entering the commerce of 

the United States. The importer 

obtains clearance through the use of 

a customs broker, an individual or 

company licensed by CBP to file 

entry documents for commercial 

shipments. The importer presents 

the customs broker with documents 

describing the shipment, including 

bills of lading, invoices and packing 

lists. Based on this information, CBP 

may clear a particular shipment, 

after assessing a duty, without 

inspecting it. After a shipment is 

cleared, it may be removed from 

the port and delivered to the 

importer or its customer. Counterfeit merchandise will be denied 

clearance and is subject to seizure. 

Shipments of merchandise may also 

enter the United States temporarily, 

and without payment of duty, if they 

are to be delivered to another counImages of counterfeit merchandise seized 

during one of the search warrants that was 

executed as a result of this investigation. 

try. Such shipments require that only 

CBP-bonded trucks pick up the 

merchandise at the port and that the 

shipment be temporarily stored only 

at a CBP-bonded warehouse. 

Schemes Used by the 

Criminal Organization 

Scheme One: Permits to Transfer 

Permits to Transfer (PTT) allow 

shipments to be moved from the 

port of entry to a CBP-bonded facility, where they must be held until 

CBP grants entry of the merchandise. In an effort to conceal counterfeit imported merchandise, or to 

avoid paying full duty for authentic 

merchandise, this investigation 

revealed that: 

1) CBP-bonded warehouse owners 

and a CBP-bonded warehouse 

manager fraudulently obtained 

PTT to smuggle counterfeit and 

authentic merchandise into the 

United States.The defendants 

failed to deliver the merchandise to the bonded facilities and 

actually transported it to their 

own warehouses or the customers’ warehouses; and 

2) Managers of a CBP exam site—a 

CBP-bonded facility where CBP 

conducts commercial and 

enforcement examinations of 

containers—moved shipments 

of merchandise from ports of 

entry, prior to examination by 

CBP, to warehouses with noncounterfeit goods or authentic 

goods with a lower duty. 

Scheme 2: Diversion Scheme 

The in-bond system allows merchandise not intended for entry 

into U.S. commerce to transit the 
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El Dorado Task Force Investigation, continued 

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United States. In- Corner

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bond movements 

allowed under U.S. 

law are valuable to 

the trade community because they 

help alleviate port congestion and 

facilitate trade by making it possible 

for importers to move cargo more 

efficiently. This merchandise transits 

through the United States without 

duties or taxes being paid, because 

it is moving under a bond that provides for liquidated damages if the 

conditions of the bond are not met. 

In this scheme, merchandise distributors smuggled seven 40-foot 

containers with counterfeit goods 

valued, if authentic, at more than 

$9 million through the Port of Los 

Angeles/Long Beach without paying customs duties. Suspects accomplished this by paying ICE agents, 

acting in undercover capacities, to 

file paperwork falsely indicating that 

the containers were merely inbond, passing through the United 

States and destined for Mexico. The 

containers were actually delivered 

to several warehouses in the United 

States controlled by the suspects. 

Scheme 3: Pass-Through Scheme 

A “pass-through scheme” was also 

used by the conspirators. Suspects 

involved in this type of scheme 

attempt to pass goods through the 

port of entry without being targeted for inspection. In this case, 

suspects smuggled approximately 

22 containers with more than $25 

million of counterfeit merchandise 

into the United States. Suspects 

accomplished this by providing 

false information to CBP regarding 

the contents, value and consignees 

of the containers, as well as by paying undercover ICE agents to facilitate the release of the merchandise. 

Money Laundering Activity 

Evidence collected from one of 

the importer’s bank accounts 

revealed payments for smuggled 

counterfeit merchandise and the 

transfer of illicit proceeds to China 

in order to facilitate the smuggling 

scheme. One of the accounts 

revealed outgoing wire transfers 

of more than $60 million to various entities, including the shippers 

and manufacturers of the smuggled 

counterfeit merchandise. 

The defendants were charged with 

smuggling, trafficking in counterfeit 

goods, money laundering and wire 

fraud. Approximately 500 cartons 

of counterfeit goods were seized 

bearing the brand names of Louis 

Vuitton, Fendi, Gucci, Christian 

Dior, Fubu and Lacoste. A total 

Red Flag Indicators 

• Frequent transactions or purchase of negotiable 

instruments $10,000 or less in order to avoid 

filing a Currency Transaction Report (CTR). 

• Customer making cash deposits $10,000 or 

less at multiple locations, or cash deposits 

made to one account at the same location by 

multiple individuals. 

• Splitting large currency deposits among several 

accounts during a single transaction. 

• Using multiple accounts to collect funds that are 

then transferred to the same foreign beneficiaries. 

• Issuing sequentially numbered checks, money 

orders, or other financial instruments to the 

same person or business, or to a person or 

business with a similar name. 

of $749,250 in bulk cash and 

money orders was seized during 

the course of the arrest and search 

warrants. Additionally, as a result of 

an investigation by the SAC New 

York Asset Identification and 

Removal Group (AIRG), $1,000,472 

was seized from 12 bank accounts 

attributed to the charged defendants. Five real properties worth 

approximately $4 million dollars 

were also seized. $

Images of the five real properties, which include two single family homes, one condo and one duplex. These properties have a combined 

value of approximately $4 million. 
Doleiro—The Black Market Foreign Exchange in Brazil 

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Volume VI: No. 1 

January 2009 

he Brazilian 

doleiro market 

is the parallel, or 

black market for 

the exchange of 

Brazilian reais 

into other currencies, principally 

the U.S. dollar. 

Corner

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The market operates through a 

large underground network of 

enterprises in Brazil.These enterprises sometimes have no fixed 

place of business and operate only 

through cell phones. In many cases, 

they operate in the shadows and are 

presumed to have lax or no money 

laundering controls. 

The doleiro provides the services of 

an illegal money remitting business, 

offering both sides of the monetary 

transaction. In Brazil, it provides 

money transfer services to citizens 

and companies who are looking to 

move reais out of Brazil. In the 

United States and other countries 

around the world, the doleiro offers 

remittance payment services to 

remittance companies seeking to 

have payments made in Brazil. 

Doleiros maintain scores of bank 

accounts in Brazil as well as abroad, 

including accounts in the U.S. 

One example of ICE successfully 

shutting down a doleiro operation 

is Operation Living Large. $

Operation Living Large 

I

n October 2000, ICE agents in 

New Jersey opened a money 

laundering investigation after learning that possible drug proceeds 

were being laundered through a 

local bank. Working in partnership 

with law enforcement agencies in 

New York and Brazil, ICE targeted 

companies that were using U.S. 

bank accounts as conduits into the 

U.S. financial system for funds laundered through Brazilian doleiros. 

Bank Secrecy Act reports filed by 

U.S. financial institutions assisted 

this investigation by identifying 

additional bank accounts that were 

used by the doleiros. 

The doleiros established U.S. bank 

accounts where they would receive 

and send wire transfers, with one of 

these accounts opened at Merchants 

Bank of New York, a division of Valley National Bank of New Jersey. 

Incoming and outgoing wire transfers were credited to the doleiro’s 

accounts from different entities, 

including businesses and individuals in the United States, Brazil and 

elsewhere, for payments in Brazil 

and the United States. 

ICE learned that a bank employee, 

Maria Carolina Nolasco, a U.S. citizen 

originally from Portugal, was facilitating these wire transfers. In return 

for kickbacks from the doleiro organization, she used dozens of bank 

accounts under her control to transmit money on behalf of currency 

exchange houses and money transmitting businesses in Brazil. From 

May to December 2001, more than a 

half-billion dollars passed through 26 

of these bank accounts. 

ICE agents arrested Nolasco, and she 

was charged in an eight-count criminal complaint for conducting an 

illegal money transmitting business. 

ICE ultimately seized 39 accounts 

worth over $21 million connected 

to the doleiro organization. Nolasco 

has since been convicted in the District of New Jersey for violations of 

operating an unlicensed money 

Red Flag Indicators 

• Large amounts of wire transfers sent and received 

from different business entities. 

• Large amounts of currency were sent and received 

into the target account, but the company was a 

shell company and nonexistent. Know-yourcustomer rules should help determine if a 

company has a physical location and is actively 

engaged in its stated business purpose. 

• The companies were incorporated offshore, but 

the individuals and contact information were 

located in Brazil. 

• A heavy volume of wire transfer activity with little 

or no corresponding cash deposits into any of the 

related accounts. 

• Even though a company has business accounts at 

a financial institution, personal accounts are 

being used for business purposes. 

service business and tax evasion, and 

is currently awaiting sentencing. 

During the course of the investigation, Brazilian authorities developed 

additional information concerning 

these doleiros, which led to more 

than100 individuals being charged 

in Brazil for money laundering and 

other related crimes. 

In August 2006, indictments were 

brought in this case against 16 corporate entities and 34 individuals 

for operating a money transmitting 

business without a license. $