Department of the Treasury 

Treasury Executive Office of 

Asset Forfeiture 

Congressional Budget 

Justification and Annual 

Performance Report and Plan 

FY 2022 
TEOAF – 2 

Table of Contents

Section I – Purpose........................................................................................................................ 3

A – Mission Statement ................................................................................................................ 3

B – Summary of the Request ...................................................................................................... 3

1.1 – Appropriations Detail Table .......................................................................................... 8

1.2 – Obligations Detail Table ............................................................................................... 9

1.3 – Object Classification (Schedule O) Obligations ........................................................... 9

E – Legislative Proposals ............................................................................................................ 9

Section II – Annual Performance Plan and Report ................................................................. 10

A – Strategic Alignment ........................................................................................................... 10

B – Budget and Performance by Budget Activity .................................................................... 10

2.1.1 Treasury Forfeiture Fund Resources and Measures ......................................................... 10

D– Evidence-Building Activity ................................................................................................ 11

Section III – Additional Information ........................................................................................ 11

A – Summary of Capital Investments ....................................................................................... 11
TEOAF – 3 

Section I – Purpose 

A – Mission Statement 

To affirmatively influence the consistent and strategic use of asset forfeiture by law enforcement 

bureaus that participate in the Treasury Forfeiture Fund (TFF or the Fund) to disrupt and 

dismantle criminal enterprises. 

B – Summary of the Request 

The Treasury Executive Office for Asset Forfeiture (TEOAF) administers the Fund, which is the 

receipt account for deposit of non-tax forfeitures made pursuant to laws enforced or administered 

by participating Treasury and Department of Homeland Security (DHS) bureaus. Principal 

revenue-producing bureaus include U.S. Customs and Border Protection (CBP), U.S. 

Immigration and Customs Enforcement (ICE), the Internal Revenue Service (IRS), the U.S. 

Secret Service (USSS), the U.S. Coast Guard (USCG), and Alcohol and Tobacco Tax and Trade 

Bureau (TTB), among others. The Fund is a special fund, defined as a Federal fund account for 

receipts earmarked for specific purposes and the expenditure of those receipts. The law (31 

U.S.C. 9705) allows TEOAF to use the funds for payment of all proper expenses of seizure or 

the proceedings of forfeiture and sale. 

Revenues deposited in the Fund can be allocated and used as the result of a permanent indefinite 

appropriation provided by Congress. A forfeiture process begins once currency or property is 

seized. Seized currency is deposited into a suspense account (holding account) until forfeited. At 

that time, the forfeited amount is transferred (deposited) to the Fund as revenue. Forfeited 

properties are usually sold, and the proceeds are also deposited into the Fund as revenue. This 

revenue represents budget authority for meeting obligations and expenses of the program. 

Expenses of the Fund are set in a relative priority so that operating costs are met first and may 

not exceed revenues. 

 Mandatory expenses represent operating costs of the Fund, including storing and 

maintaining seized and forfeited assets, valid liens and mortgages, investigative expenses 

incurred in pursuing a seizure, information and inventory systems, remissions, victim 

restoration, and certain costs of local police agencies incurred in joint law enforcement 

operations. Following seizure, equitable shares may be paid to state and local law 

enforcement agencies that contributed to the seizure activity at a level proportionate to their 

involvement. 

 Secretary’s Enforcement Fund (SEF) expenses are funded from revenue from equitable 

shares received from Department of Justice (DOJ) or U.S. Postal Service (USPS) forfeitures. 

These shares are proportionate to Treasury’s participation in the overall investigative effort 

that led to a DOJ or USPS forfeiture. SEF revenue is available for Federal law enforcementrelated purposes of any bureau participating in the Fund. 

 Strategic Support authority, established in 31 U.S.C. 9705(g)(4)(B), allows TEOAF to fund 

priority Federal law enforcement initiatives with remaining unobligated balances at the close 

of the fiscal year, after an amount is reserved for the next fiscal year’s operations. 

FY 2020-2021 Case Highlights: The following case highlights are intended to provide examples 

of the types of investigative cases worked by the Fund’s law enforcement bureaus during 
TEOAF – 4 

FY 2020-2021 that resulted in the seizure and forfeiture of assets. Such cases as those profiled 

below are consistent with the strategic mission and vision of the Fund, which seeks to use highimpact asset forfeiture in investigative cases to disrupt and dismantle criminal enterprises. 

 Airbus Has Entered into a Three-year Deferred Prosecution Agreement (DPA) with 

DOJ Resulting in a $55 million Forfeiture in a Foreign Bribery and ITAR Case 

Airbus, a France based aerospace company, entered into a three year DPA with the U.S. 

Department of Justice. As part of the DPA, Airbus agreed to pay the U.S. Government $527 

million dollars for Foreign Corrupt Practice Act (FCPA) and International Traffic in Arms 

Regulation (ITAR) violations. They also agreed to a civil forfeiture of approximately $55 

million dollars for violations tied to ITAR related conduct. The DPA was a part of a $4 

billion-dollar global settlement with the US, France, and the UK to resolve charges that 

Airbus violated the anti-bribery provisions of the FCPA. Additionally, Airbus was charged 

with conspiracy to violate the Arms Export Control Act and the ITAR. The investigation was 

conducted by ICE’s Homeland Security Investigations (HSI). 

 HSBC pays penalty and forfeits $71.850 million after helping to hide over $1 billion in 

U.S. clients’ assets from the IRS 

HSBC Switzerland, a private bank headquartered in Geneva, entered into a DPA with the 

U.S. Department of Justice, admitting to conspiring with their U.S. accountholders to hide 

their assets abroad to evade U.S. taxes. According to the DPA, HSBC Switzerland agreed to 

pay $192.35 million in three parts. The first part was $60.6 million to the IRS as restitution 

for unpaid taxes on the undeclared assets. Secondly, the bank forfeited $71.850 million, 

which represented gross fees it charged clients, and finally, it agreed to pay a $59.9 million 

penalty. The investigation was conducted by IRS Criminal Investigations. 

 Border Patrol Bike Unit Arrests Two Men Smuggling 165 Pounds of Methamphetamine 

through Drainage Tunnel 

In January 2020, agents from the Nogales Border Patrol Bike Unit received intelligence that 

narcotics were being smuggled though storm drains that originate in Mexico and extend 

approximately 20 miles into the United States. Based off the intelligence, agents dropped into 

the tunnel and located two suspects floating 70 packages through the storm drain. Agents 

observed them pulling the packages through grates on the Mexico side into the United States 

and stuffing the packages into duffle bags. After apprehending the two men, agents 

determined through interviews that there was another individual waiting for the narcotics in a 

car, which they quickly located. 

COVID 19 Related Case Highlights 

 Homeland Security Investigations Operation Stolen Promise Targets Counterfeit 

Vaccines and Treatments for COVID-19 

Since April 2020, ICE’s HSI Cyber Crimes Center (C3) and Intellectual Property Rights 

(IPR) Center have been successfully targeting online fraud schemes and the sale of illicit 

COVID 19 vaccines and treatments using illicit websites and dark net marketplaces. As of 

March 1, 2021, using advanced analytical tools, attribution tools, cyber threat intelligence 

tools, and online undercover activities, ICE agents have initiated 123 criminal investigations, 

disrupted 378 COVID-19 fraud websites and 11 COVID-19 counterfeit vaccines and 

treatments websites. Case highlights include: 

 In December 2020, HSI New York and HSI Baltimore, with assistance from C3 and the 

IPR Center, executed seizure orders for websites GRASSEPHARM[.]COM, 
TEOAF – 5 

mordernatx.com and regeneronmedicals.com. These sites purported to belong to biotech 

companies developing treatments for COVID-19 virus but in reality, were spoof/ 

phishing sites designed to collect personal identifiable information (PII) of individuals 

visiting the site. Currently, the site visitors see a message informing them that these sites 

have been seized by the federal government; 

 In February 2021, HSI Baltimore agents arrested three subjects for violations of Wire 

Fraud in connection to the creation of spoof/fraudulent COVID-19 vaccine website and 

the illegal sale of a COVID-19 vaccine. They also seized Modernatx[.]shop, a 

spoof/fraudulent website offering the sale of COVID-19 vaccines. A search warrant was 

also executed at a residence of a subject who accepted payment for fraudulent COVID-19 

vaccines. The subject agreed to cooperate with HSI and identified other individuals who 

orchestrated the fraud;

 In March 2021, HSI Baltimore seized another spoof/ phishing website 

“remdesivirmx.com,” which purported to sell and distribute Remdesivir, an antiviral drug 

approved for COVID-19 treatment. 

 USSS San Antonio obtains $5.250 million in a COVID-19 fraud investigation 

In April 2020, USSS San Antonio Field Office initiated an investigation involving the $5.25 

million deposit related to the purchase of 3M N95 Masks by a medical supply company Med 

Tech LLC. The agents have determined that the suspect supplier was not a verified 

distributor of N95 masks and had no association with 3M. After receiving the $5.25 million 

deposit, subjects of the investigation transferred out $520,000 to an account that supposedly 

belonged to a “mask supplier”; but in reality, belonged to another suspect recruited online to 

convert these funds into Bitcoins. Additional investigation revealed that the targets used 

various counterfeit certificates to portray themselves as legitimate suppliers. The 

$5.250million was forfeited for violations of Title 18 USC 1342, Wire Fraud. A Petition for 

Remission or Mitigation of Forfeiture for the loss has been submitted by the defrauded party, 

Med Tech, LLC. 

Priorities: In FY 2022, TEOAF will continue to support the investigations and activities of the 

participating law enforcement bureaus. The bulk of TEOAF expenses include supporting 

seizures and forfeitures and funds are expended for seizure, storage, maintenance, disposition, 

and destruction and all costs associated with those activities. 

TEOAF focuses on supporting cases and investigations that meet the mission of disrupting and 

dismantling criminal enterprises. To this end, TEOAF prioritizes major case1

 initiatives when 

allocating funding to member agencies, including the purchase of evidence and information, joint 

operations expenses, investigative expenses leading to seizure as well as software tools used for 

computer forensics and analysis of financial data. Major case initiatives are aligned directly to 

the National Money Laundering and Southwest Border strategies. 

Often, the assets identified in these investigations are proceeds of fraud schemes with multiple 

victims. TEOAF allocates significant resources to ensure that such investigations are adequately 

1

 A major case refers to a case where the forfeiture results in a deposit greater than $5 million, or a case that disrupts, dismantles, or interrupts 

money laundering networks or other financial activities that threaten the financial stability, financial system, or financial interests of the United 

States. 
TEOAF – 6 

funded to yield successful prosecutions and forfeitures. The resulting forfeiture deposits are used 

to compensate the victims defrauded by the violators. 

One of TEOAF’s highest immediate priorities now is supporting TFF participating law 

enforcement agencies’ response to COVID-19 related crimes. Our agencies are facing 

formidable challenges dealing with massive COVID-19 related fraud schemes such the use of PII 

obtained via network intrusion or phishing schemes or the sales of counterfeit vaccines and 

COVID treatments online and via Darknet marketplaces. Many of these investigations require 

analytical and cyber-investigative tools and services that are currently not available or 

insufficient. From the start of the pandemic, TEOAF has made it a priority to support our 

agencies’ efforts aimed at intercepting, disrupting and dismantling multi-million-dollar COVID 

fraud schemes and returning the money to the victims. It will remain a TEOAF high priority in 

FY 2021-2022, as the number of COVID-19 crimes is still growing, and the new financial 

assistance programs on federal and state levels will likely generate a significant number of fraud 

cases. 

The most notable financial investigations conducted by the TFF agencies involve professional 

money launderers who utilize highly sophisticated money laundering methods, global trade and 

finance, and emerging technologies such as cryptocurrencies. They launder illicit funds derived 

from many criminal violations, including drug trafficking, human smuggling and COVID-19 

fraud. This type of investigation requires extraordinary law enforcement efforts, manpower, and 

resources. TEOAF prioritizes the support of such investigations, including their ongoing 

operation’s needs and cutting-edge technology capabilities required for big data analytics, dark 

net investigations, block chain analysis, and mobile forensics necessary for these operations. 

These investments buttress the anti-money laundering and countering the financing of terrorism 

(AML/CFT) strategy of DHS and Treasury and uncertainty about future funding for 

investigations and forfeitures 

Challenges: Large rescissions enacted in prior years have resulted in inconsistent Strategic 

Support allocations and have led to uncertainty about future funding for financial investigations 

and forfeitures. 

The table below reflects forfeiture revenue from all sources including direct revenue, reverse 

asset sharing, and interest earned. 
TEOAF – 7 

*FY 2015 data does not include the BNP Paribas S.A. forfeiture in the amount of $3,839 million. Of that amount, $3,800 million was 

permanently rescinded and transferred by Congress under the Consolidated Appropriations Act of 2016, Pub. L. 114-113, Div. O, Tit. IV, §404(e) 

and §405(b). The remainder was returned to the General Fund in FY 2018. 

For operational support of TFF agencies’ investigations, both Mandatory and SEF are critical 

funding sources. The Mandatory funding supports investigative expenses only for seizure cases, 

but the vast majority of seizure cases do not t initially start as financial cases. They grow out of 

other cases pursuing specified unlawful activities such as drug trafficking, human smuggling, or 

cybercrime, which are all dependent on SEF funding for operational support. The nature of 

revenue and expenses for both Mandatory and SEF funding is equally dynamic, requiring 

adjustments during the fiscal year. 

In addition, TEOAF tracks future remission payments to third parties as contingent liabilities. 

However, these amounts are not recorded as Fund obligations until the Department of Justice 

grants the petition for remission. The third parties are predominantly victims of crimes that 

triggered the forfeiture (e.g., Ponzi scheme or kleptocracy victims). Amounts recorded are 

significant because remission payments from multiple years are recorded and carried forward. 

The amounts change constantly as payments are made and amounts for new remission cases are 

added. TEOAF considers the amounts recorded as contingent liabilities as unavailable and 

consideration of contingent liabilities provides a more accurate representation of the Fund’s 

financial position. 

 

$579 $556

$1,143

$931

$524

$1,715

$785 $795 $884

$516

$1,279

$876

$513

$0

$200

$400

$600

$800

$1,000

$1,200

$1,400

$1,600

$1,800

$2,000

Millions

FORFEITURE REVENUE FROM ALL SOURCES
TEOAF – 8 

1.1 – Appropriations Detail Table 

Dollars in Thousands 

Treasury Forfeiture Fund FY 2020 FY 2021 FY 2022 FY 2021 to FY 2022 

Budgetary Resources Actual Estimated Estimated $ Change % Change 

 FTE 1 AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT 

Revenue/Offsetting 

Collections 

Interest $18,565 $25,000 $25,000 $0 NA 0% 

Restored Prior Year 

Sequestration Reduction $54,340 $30,294 $32,609 $2,315 NA 8% 

Forfeited Revenue $494,893 $547,096 $547,096 $0 NA 0% 

Recovery from Prior Years $32,358 $12,000 $12,000 $0 NA 0% 

Unobligated Balances 

from Prior Years $609,632 $691,453 $717,902 $26,449 NA 4% 

Total Revenue/Offsetting 

Collections $1,209,788 $1,305,843 $1,334,607 0 $28,764 NA 2% 

Expenses/Obligations 

Mandatory Obligations 27 ($465,205) 27 ($445,332) 27 ($445,332) $0 0.00% 0% 

Secretary's Enforcement ($22,836) ($35,000) ($35,700) ($700) NA 2% 

Strategic Support 2 $0 TBD TBD NA NA NA 

Total Expenses/Obligations 27 ($488,041) 27 ($480,332) 27 ($481,032) 0 ($700) 0.00% 0% 

Rescissions/Cancellations 

Sequestration Reduction 0 ($30,294) ($32,609) ($32,609) NA NA NA 

Permanent Cancellation 0 $0 ($75,000) $0 $75,000 NA -100% 

Total 

Rescission/Cancellations ($30,294) ($107,609) ($32,609) $75,000 NA -70% 

Net Results 27 $691,453 27 $717,902 27 $820,966 0 $103,064 0.00% 14% 

 

Contingent Liabilities ($512,764) ($465,000) ($465,000) $0 NA 0% 

1/ The Treasury Forfeiture Fund is staffed by Departmental Offices employees and positions are funded via reimbursable agreement. The FTE 

are shown here for clarity but are also reflected in the Departmental Offices chapter in the reimbursable FTE total. 

2/ For FY 2021 and FY 2022, Treasury will revise Strategic Support based on enacted appropriations and may submit a plan to Congress if 

funding is available, once more is known about collections and expenses. 

 
TEOAF – 9 

1.2 – Obligations Detail Table 

Dollars in Thousands 

Treasury Forfeiture Fund Obligations 

FY 2020 

Actual 

FY 2021 

Estimated 

FY 2022 

Estimated 

% Change FY 2021 

to FY 2022 

Mandatory 

 CBP $41,687 $42,110 $42,110 0.0% 

 ICE $162,302 $123,195 $123,195 0.0% 

 IRS $98,569 $124,484 $124,484 0.0% 

 USSS $49,258 $43,829 $43,829 0.0% 

 USCG $1,124 $1,428 $1,428 0.0% 

 TEOAF $81,799 $91,180 $91,180 0.0% 

 TTB $774 $1,058 $1,058 0.0% 

 DOJ $29,692 $18,048 $18,048 0.0% 

Total Mandatory $465,205 $445,332 $445,332 

SEF 

 CBP $4,370 $4,400 $4,488 2.0% 

 ICE $7,034 $12,123 $12,365 2.0% 

 IRS $6,734 $12,001 $12,241 2.0% 

 USSS $4,348 $6,126 $6,249 2.0% 

 TTB $350 $350 $357 2.0% 

Total SEF $22,836 $35,000 $35,700 

Strategic Support 

Total Strategic Support $0 TBD TBD NA 

Total Expenses/Obligations $488,041 $480,332 $481,032 0.1% 

1.3 – Object Classification (Schedule O) Obligations 

Dollars in Thousands 

 FY 2020 FY 2021 FY 2022 

Object Classification Actual Estimated Estimated 

25.2 - Other services from non-Federal sources 12,412 46,532 46,532 

25.3 - Other goods and services from Federal sources 246,657 140,546 140,546 

26.0 - Supplies and materials 1 1 1 

41.0 - Grants, subsidies, and contributions 131,218 115,502 115,502 

43.0 - Interest and dividends 170 19 20 

44.0 - Refunds 73,133 142,032 142,731 

94.0 - Financial Transfers 24,450 35,700 35,700 

Total Non-Personnel $488,041 $480,332 $481,032 

Total Budgetary Resources $488,041 $480,332 $481,032 

 

FTE 1 27 27 27 

1/ The Treasury Forfeiture Fund is staffed by Departmental Offices employees and positions are funded via reimbursable 

agreement. The FTE are shown here for clarity but are also reflected in the Departmental Offices chapter in the reimbursable 

FTE total. 

E – Legislative Proposals 

TEOAF has no legislative proposals. 
TEOAF – 10 

Section II – Annual Performance Plan and Report 

A – Strategic Alignment 

In accordance with the Government Performance and Results Act Modernization Act (GPRAMA)

of 2010, the Department of the Treasury is currently developing the FY 2022 – 2026 

Departmental Strategic Plan. The Strategic Plan is scheduled for publication in 2022. The 

Annual Performance Plan will be updated in the FY 2023 President’s Budget to reflect new 

departmental strategic goals and objectives. 

The purpose of the Fund is to ensure resources are managed to cover the costs of an effective 

asset seizure and forfeiture program, including the costs of seizure or the proceedings of 

forfeiture and sale, including the expenses of detention, inventory, security, maintenance, 

advertisement, or disposal of the property. Additionally, the Fund is used to support law 

enforcement priorities, financial investigative capabilities, and the seizure of physical and 

financial resources to disrupt and dismantle criminal enterprises. 

B – Budget and Performance by Budget Activity 

2.1.1 Treasury Forfeiture Fund Resources and Measures 

Dollars in Thousands 

 FY 2016 FY 2017 FY 2018 FY 2019 FY 2020 FY 2021 FY 2022 

Resource Level Actual Actual Actual Actual Actual Estimated Estimated 

Expenses/Obligations $508,746 $526,228 $1,007,426 $1,022,684 $488,041 $480,332 $481,032 

Budget Activity Total $508,746 $526,228 $1,007,426 $1,022,684 $488,041 $480,332 $481,032 

FTE 25 25 25 26 27 27 27 

 FY 2016 FY 2017 FY 2018 FY 2019 FY 2020 FY 2020 FY 2021 FY 2022 

Measure Actual Actual Actual Actual Target Actual Target Target 

Percent of Forfeited Cash 

Proceeds Resulting from 

High-Impact Cases 

81.79 80 94.19 90.8 80 82.87 80 80 

Treasury Forfeiture Fund Budget and Performance 

($481,032,000 in obligations from revenue/offsetting collections): 

The Fund continues to measure the performance of the participating law enforcement bureaus 

through the “percent of forfeited cash proceeds resulting from high-impact cases, “which are 

cases that yield a cash forfeiture deposit equal to or greater than $100,000.” 

The high-impact cases are cases that pursue major criminal targets and their financial networks, 

and therefore, central to disrupting and dismantling criminal enterprises. At the same time, these 

cases are heavily dependent on TEOAF’s funding due to their high operational costs and reliance 

on sophisticated technologies and analytical tools that are not adequately covered by the 

appropriated funds. The dominant share of high-impact forfeitures reflects TEOAF’s 

effectiveness in supporting such major investigations. 

While the specific numbers shown in the chart fluctuate due to the unusually big forfeitures, the 

consistently dominant (80 percent or more) share of major forfeiture year after year demonstrates 
TEOAF – 11 

TEOAF’s consistent commitment to supporting high-impact cases. Member law enforcement 

bureaus participating in the Fund have met or exceeded the performance target since FY 2014. 

For FY 2021 and FY 2022, the target will remain at 80 percent. The Fund maintains a target of 

80 percent because some cases may be important to pursue, even if they are not high-impact 

cases and result in deposits of less than $100,000. 

D– Evidence-Building Activity 

In FY 2020 TEOAF has conducted various analyses related to the TFF member agencies’ 

investigative capabilities, resource needs and funding requests to determine the most effective 

ways to allocate TEOAF’s funds. 

For example, TEOAF also have been actively analyzing over 100 cases designated for TEOAF’s 

support through the Third-Party Money Laundering (3PML) Program. The 3PML Program is a 

TEOAF-led collaborative effort with the TFF member agencies. It is focused on identifying and 

supporting TFF agencies’ most important and complex cases targeting professional money 

launderers (individuals or entities), and performing analyses of the associated money laundering 

typologies, emerging trends and investigative needs. This includes analysis of deficiencies and 

emerging needs related to the TFF agencies’ investigative capabilities and infrastructure, and 

possible ways to use TFF funds to facilitate improvements. For instance, TEOAF has identified a 

growing need for IT tools to support analyses of large volumes of email data in foreign 

languages, and with agency assistance formulated a plan to fund and build the required solutions. 

Additionally, TEOAF has been conducting outreach and exploratory discussions with TFF 

agencies about the creation/enhancement of joint financial taskforces aimed at increasing the 

efficiency of TFF funding support through the shared use of TEOAF-funded resources. 

TEOAF plans to continue its high-impact work in FY 2021 and 2022. For example, a newly 

launched effort is the upgrade of technology for member agencies for scanning and analysis of 

financial records funded by TEOAF and utilized jointly by TFF agencies. 

Section III – Additional Information 

 

A – Summary of Capital Investments 

A summary of capital investments, including major information technology and non-technology 

investments, can be accessed at: https://www.treasury.gov/about/budgetperformance/Pages/summary-of-capitalinvestments.aspx.