I

n 2003,

as part of 

an effort to 

assist foreign 

nations to 

locate and 

seize profits 

from public 

corruption,

ICE 

established 

the first 

dedicated 

Foreign 

Corruption 

Investigations Group (FCIG) in the

nation. Kleptocracy, or large-scale

corruption by senior foreign political figures, can adversely affect a

nation’s economy and development.

These senior foreign political figures,

commonly referred to as politically

exposed persons (PEPs) have or had

positions of public trust that were

misused for personal enrichment.

The mission of the FCIG is 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

the victimized governments.The

FCIG conducts investigations into

the laundering of proceeds emanating from foreign public corruption,

bribery or embezzlement. FCIG

investigations are worked jointly

with representatives of the victimized foreign government.

ICE plays an integral role in the effort

to identify, investigate and arrest the

perpetrators of foreign corruption.

Additionally, ICE has the ability to

seize, forfeit and repatriate the funds

to its rightful owners—the citizens of

the victimized foreign governments.

Investigative results are shared with

the appropriate domestic and international ICE offices as well as with

law enforcement partners worldwide

to assist in ongoing investigations. $

Combating Foreign Corruption

ICE’s Role in Combating Foreign Corruption

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 Examples from 

the ICE Files:

ICE Investigates 

Birk Hillman, et al. . . . 2

ICE Investigates 

Jose Aleman, et al. . . . 4

Volume V: No. 3 • October 2008

General Foreign Corruption 

Politically exposed persons (PEPs) have or had

positions of public trust within a country such as

government officials, senior executives of

government corporations, politicians or

important political party officials. This term also

includes the political figure’s immediate family

members and close associates, to include

advisors, attorneys, accountants and members

of their entourage or any other person who

asserts influence over the official. Financial

activity related to foreign corruption may include:

• accumulation of assets that greatly exceeds

the legitimate or publicly stated income of a

public official;

•the use of a nation’s central bank or government

owned bank to make personal purchases, such as

residential property, automobiles or luxury items;

• attempts by an individual to mask the true

beneficial ownership of an account;

• high-dollar transactions involving corporations

with limited or no public information available

(shell corporations);

• outgoing wire transfers to haven countries

and/or shell companies from official accounts

or sub accounts; and

• layering transactions by transferring funds from

a foreign account to a U.S. bank and almost

immediately transferring the same funds out 

to another bank. 

Red Flag Indicators
ICE Investigates

Birk Hillman, 

et al.

Between 2002 and

2004, ICE and the

government of Trinidad and Tobago

(GTT) conducted independent

investigations that revealed a complex bid rigging and bank loan

fraud scheme involving foreign

government corruption, a sophisticated conspiracy to win multi-million dollar construction contracts,

in addition to a bank loan kiting

scheme.The individuals involved in

these transactions used a number of

U.S. and off-shore bank accounts to

launder the proceeds from these

illicit activities.

ICE learned in May 2004 that the

GTT was involved in an approximately two-year-old investigation

aimed at identifying high-level 

corruption associated with the 

construction of the new Piarco

International Airport (PIA) in

Trinidad.The scheme involved a 

bid rigging conspiracy

aimed at winning a multimillion dollar contract to

oversee construction of the

PIA.The GTT investigation

focused on several political

figures and prominent

businessmen, including

Steve Ferguson and Ishwar

Galbaransingh, who were

major contributors to the

campaign of former Prime

Minister Basdeo Panday.

Ferguson and Galbaransingh

utilized their influence in

order to ensure that Birk

Hillman Consultants (BHC),

a company operating out of

Miami, Fla., was awarded

the Project Manager/Architectural

contract to oversee the construction

of PIA in Trinidad. It was determined

that Ferguson received a substantial

“kickback” from BHC owners

Ronald Birk and Eduardo Hillman.

Birk, Hillman and Ferguson agreed

to conspire to engage in fraud in

order to ensure that a Miami-based

construction company, Calmaquip

(owned by Raul Gutierrez), be

awarded the lucrative contract for 

construction and to supply specialty

equipment for the PIA project. BHC

and Calmaquip had worked together

in the past on other international

construction projects.

Part of the fraud scheme included

submitting inflated bids to the GTT.

A Calmaquip corporate officer was

listed as the owner of S.D.C., a company related to Calmaquip. Both of

these companies shared continued

Case Examples from the ICE Files

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October 2008

Property belonging to an owner of Birk 

Hillman Consultants—valued at $900,000;

forfeiture pending.

Property belonging to Calmaquip CEO—

valued at $4.9 million; forfeiture pending.
corporate officers

and a physical location in the same

building in Miami,

Fla.The conspirators

submitted an

inflated and fraudulent bid in the

name of S.D.C. to give the appearance that Calmaquip’s bid was reasonable by comparison. Once the

contract was paid, the proceeds

were divided among the conspirators and laundered via a series of

transfers through shell corporation

accounts at banks in the Bahamas,

Lichtenstein, Panama and the U.S.

Once Calmaquip was awarded the

PIA construction contract, the company obtained loans and lines of

credit at various U.S. banks, for the

alleged purpose of financing the

construction. However, Calmaquip’s

directors utilized these loans to run

a kiting scheme, paying one loan

with another and skimming proceeds for personal use, thereby

committing bank fraud.These proceeds were then laundered through

offshore bank accounts.

In November 2004, following an

ICE Cornerstone outreach to a financial institution, ICE received Bank

Secrecy Act (BSA) reports filed by a

brokerage firm detailing numerous

banking transactions by individuals

linked to BHC.The ICE Miami Cornerstone group conducted a detailed

analysis of the roughly 100 U.S. and

off-shore bank accounts associated

with the reports.This analysis

revealed that BHC and their co-conspirators utilized a complex web of

shell corporations, front companies

and off-shore accounts to launder

roughly $38 million in profits netted as a result of their bank fraud

schemes. Ultimately, the proceeds

from the frauds were used to fund

lavish lifestyles, including purchases

of real estate, fine jewelry, art works

and vacations.

On November 28, 2005, an 18

count indictment charging wire

fraud, money laundering and conspiracy was filed in the U.S. against

eight individuals and two corporations. In March 2006, a superseding

indictment was returned, adding

additional counts of bank fraud and

money laundering connected to the

defrauding of $23 million from

U.S. banks in the South Florida area.

As a result of the indictment, Hillman was arrested in the U.S. on

money laundering and wire fraud

charges. He was sentenced to 37

months imprisonment and was

ordered to pay $2,000,000 in restitution. Hillman was also charged by

the GTT who subsequently requested

his extradition, marking the first

time that the GTT has evoked their

extradition treaty with the U.S.

Additionally, Ferguson and Galbaransingh were arrested in

Trinidad based upon provisional

arrest warrants issued on behalf of

the U.S., they are awaiting extradition. Raul Gutierrez, owner of Calmaquip, was sentenced to 72

months imprisonment and ordered

to pay over $22 million in restitution. Calmaquip and four additional

co-conspirators were convicted of

charges related to bank and/or wire

fraud. Sentences ranged from probation to 37 months in prison.

Case Examples from the ICE Files, continued

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October 2008

• Incomplete or vague credit applications that rely

on a company’s prior reputation or experience

with that financial institution to obtain

unsecured loans and lines of credit.

• Commonalities between complicit

corporations—for example, common addresses

and telephone numbers for companies that

purport to be independent entities.

• Use of accounts to conduct financial

transactions outside of the stated business.

• Multiple loans requested from different financial

institutions around the same time.

• Structured deposits and/or withdrawals, many

of which were checks with odd notations in the

memo line.

• Third-party payments for good and services

through unrelated entities. For example, art being

paid for by a duty free shop in the Bahamas and

being delivered to a Miami, Fla., address.

Red Flag Indicators
ICE Investigates

Jose Aleman, 

et al.

In May 2002, the

ICE Miami Foreign

Corruption Investigations Group

(FCIG) received a request from the

government of Nicaragua (GON) to

identify and recover assets in the

U.S. that were linked to former GON

officials.These former officials were

accused by the GON of a myriad of

criminal offenses to included money

laundering and public corruption.

The GON had conducted a public

corruption investigation that

resulted in the discovery of largescale public corruption, embezzlement and money laundering.The

two primary suspects of their investigation were Byron Rodolfo Jerez

Solis, former general revenues director for Nicaragua, and Jose Arnoldo

Aleman Lacayo (Aleman), who

served as president of the Republic

of Nicaragua from January 1997 to

December 2001. Aleman was also

the leader of Nicaragua’s National

Assembly in 2002 when his presidential term finished, a post which

guaranteed him immunity from

prosecution. However, when state

auditors from Nicaragua found millions of dollars of stolen state assets

in bank accounts around the world,

a wave of public revulsion led to the

parliament lifting his immunity.

The Nicaraguan investigation

revealed that between 1999 and

2002, Aleman and Solis embezzled

and laundered an estimated $100

million from the Nicaraguan 

treasury. Aleman and others laundered these funds through shell

corporations and fraudulent investment accounts which they established in Panama and the U.S.

The shell corporations were established to appear as legitimate companies doing business with the

Nicaraguan government.

The ensuing ICE Miami FCIG investigation found that the fraudulent

shell corporations and investment

accounts were used to purchase

high-value assets in the U.S., including real estate, certificates of deposit

and a helicopter.The helicopter 

was leased back to the Nicaraguan

government for Aleman’s personal

use and for profit.The accounts

were also periodically used to disperse embezzled funds to Aleman’s

family members.

In the course of the investigation,

ICE identified and seized U.S.-based

assets totaling approximately $4.7

million, of which approximately

$3.3 million was repatriated. In

addition, the government of

Panama froze approximately $10

million. Assets identified and seized

by the ICE Miami FCIG included

seven certificates of deposit valued

at $700,000, proceeds of the sale

of a helicopter worth $671,000, a

cabana at the Key Biscayne Ocean

Club valued at $300,000, an investment account in Coral Gables, Fla.,

valued at $204,099, and a

$150,000 deposit for the purchase

of a Key Biscayne, Fla., condo.

In December 2003, Aleman was

sentenced in Nicaragua to 20 

years imprisonment after being

convicted of money laundering 

and embezzlement. Solis was convicted of corruption related criminal offenses in Nicaragua and

sentenced to eight years in prison.

Several of the remaining suspects

fled Nicaragua and are currently

fugitives from justice. $

ICE Returns $2.7 million to Nicaragua that

had been embezzled by former president

and tax commissioner.

Byron Rodolfo Jerez Solis (top left), former 

general revenues director for Nicaragua. 

Jose Arnoldo Aleman Lacayo (top right)

served as president of the Republic of

Nicaragua from January 1997 to December

2001. Aleman’s personal helicopter (above). 

Case Examples from the ICE Files, continued

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October 2008

• Subjects’ accumulated wealth inconsistent with

amount reported on mandatory financial

disclosure forms required of government officials.

• Individuals used the same bank accounts for

conducting government business and disbursing

funds to family members.

• Senior government officials directly involved 

in establishing offshore government investment accounts.

• Subjects’ attempted to utilize their political

influence and stature to persuade banking

officials not to follow their internal anti-money

laundering policies.

Red Flag Indicators