Department of the Treasury

Treasury Executive Office of 

Asset Forfeiture

Congressional Budget 

Justification and Annual 

Performance Report and Plan

FY 2021
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Table of Contents

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

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

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

1.1 – Appropriations Detail Table............................................................................................... 7

1.2 – Obligations Detail Table .................................................................................................... 8

1.3 – Operating Levels Table...................................................................................................... 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

C – Changes in Performance Measures.................................................................................... 11

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

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

A – Summary of Capital Investments....................................................................................... 11
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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 by Congress 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.
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FY 2019 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 FY 2019

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 is to use high-impact asset 

forfeiture in investigative cases to disrupt and dismantle criminal enterprises.

• Swiss bank forfeits $29.7 million for hiding U.S. taxpayers’ assets

Swiss-based Basler Kantonalbank (BKB) has admitted in the Deferred Prosecution Agreement 

(DPA) that between 2002 and 2012 it conspired with its employees, external asset managers, and 

clients to defraud the United States with respect to taxes, commit tax evasion, and file false 

federal tax returns. According to the terms of the DPA, BKB agreed to cooperate with the 

Internal Revenue Service (IRS) and other U.S. authorities and pay a penalty of $60.4 million 

consisting of $17.2 million in restitution to the IRS for unpaid taxes, $29.7 million forfeiture and 

$13.5 million dollar fine. The investigation was conducted by IRS Criminal Investigation (CI).

• Mobile Telesystems PJSC (MTS), Russian telecommunication company, has agreed to 

pay $850 million in penalties, including $40 million in criminal forfeiture, in a large 

Foreign Corrupt Practices Act (FCPA) case.

Gulnara Karimova, a former Uzbek government official, was charged in an indictment filed 

in the Southern District of New York with one count of conspiracy to commit money 

laundering related to a bribery scheme. Bekhzod Akhmedov, the former CEO of MTS, the 

largest telecommunication company in Russia, was charged in the same indictment with one 

count of conspiracy to violated the TCPA, two counts of violating the FCPA, and one count 

of conspiracy to commit money laundering. Akhmedov has facilitated the payment of bribes 

to Karimova to obtain lucrative business in the Uzbek telecommunications market. A 

substantial portion of the illicit funds were transmitted through financial institutions in the 

Southern District of New York before they were deposited into bank accounts controlled by 

Karimova in various countries. MTS has agreed to the imposition of an independent 

compliance monitor for three years, implementation of rigorous internal controls, and a 

criminal penalty of $850 million including $40 million in criminal forfeiture.

The investigation was conducted jointly by Homeland Security Investigation and IRS-CI 

under the auspices of the GIFT taskforce in DC supported by TEOAF funding.

• U.S. Secret Service recovers over $1.6 million in a business email compromise scam

The USSS Miami Electronic Crimes Task Force was contacted regarding a suspected 

business email compromise perpetrated against Precision Pipeline LLC. The investigation 

determined that the perpetrators sent an email to the accounting manager at Precision 

impersonating one of the company’s vendors, and under false pretenses caused her to transfer 

$1.6 million to a fraudulent company. The investigation has revealed that the business email 

compromise was a part of a larger international scheme targeting U.S. businesses. The 

operation targeting the scheme was a collaborative effort of the USSS, the FBI, and the U.S.

Postal Inspection Service, and led to 29 arrests in Nigeria and 23 in South Florida, as well as 

the forfeiture of over $1.6 million.

• Coast Guard boards narco-sub carrying 17,000 lbs of cocaine

On June 18, 2019, in the East Pacific Ocean, the Coast Guard initially detected the semisubmersible with an aircraft and relayed that information to two guard boats which then 
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intercepted the vessel. After ordering the vessel to stop, the Coast Guard members boarded 

the semi-submersible while it was still in motion. 17,000 pounds of cocaine worth over $569 

million dollars was retrieved from the semi-submersible. 

Priorities: In FY 2021, 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 to protect the health and safety of U.S. citizens and the commercial 

interests of U.S. businesses from pernicious criminal activity. 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 times, 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 funded to yield successful prosecutions and forfeitures. The resulting forfeiture 

deposits are used to compensate the victims defrauded by the violators.

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. These sophisticated financial 

crimes present a serious threat to our Nation’s financial system, and targeting them requires 

extraordinary law enforcement efforts, manpower and resources. TEOAF prioritizes the support 

of such investigations, including not just their ongoing operation’s needs, but also cutting edge 

technology capabilities required for big data analytics, dark net investigations, block chain 

analysis, and mobile forensics. 

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

(AML/CFT) strategy of the Departments of Homeland Security and the Treasury. 

Challenges: Large rescissions enacted in prior years have had a severe negative impact on the 

participating member agencies’ investigations. Insufficient and inconsistent funding support, 

uncertainty about future funding, investigations disrupted by cash flow problems, and inability to 

obtain necessary technology/infrastructure all undermine both current and future financial 

investigations and forfeitures. Participating agencies are seeing reluctance in the field to 

undertake complex major investigations due to the lack of assurance that their efforts would 

receive continuous support.

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

sharing, and interest earned.

*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 to the newly-created U.S. Victims of State Sponsored Terrorism Fund (USVSST) as directed by Congress 

under the Consolidated Appropriations Act of 2016, Pub. L. 114-113, Div. O, Tit. IV, §404(e) and §405(b). The remainder has been returned to 

the General Fund in FY 2018.

The absence or, in the best case scenario, uncertainty of Strategic Support funding is especially 

harmful for the most meaningful, high-impact investigations that target financial networks of 

major criminal enterprises. The Strategic Support is critical as a strategic investment in the 

agencies’ operational capabilities and infrastructure supporting major cases. It allows the law 

enforcement agencies to meet in real time unanticipated critical needs, such as those driven by 

new technology advancements or emerging criminal threats. It often serves as seed funding for 

innovations that need to be tested and refined in a pilot setting prior to full-scale implementation.

Undermining major financial investigations will directly impact the ability of Treasury and DHS 

to respond to priority threats and to protect the integrity of the U.S. financial system.

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 vast majority of seizure cases don’t initially start as financial cases. They grow out of other 

cases pursuing specified unlawful activities (SUAs) such as drug trafficking, human smuggling 

or cybercrime, which are all dependent on SEF funding for operational support.

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

However, these amounts are not recorded as obligations from the Fund 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 

believes that consideration of contingent liabilities provides a more accurate representation of the 

financial position of the Fund.

$579 $556 

$1,143 

$931 

$524 

$1,715 

$785 $795 $884 

$516 

$1,279 

$876 

FY 2008 FY 2009 FY 2010 FY 2011 FY 2012 FY 2013 FY 2014 FY 2015* FY 2016 FY 2017 FY 2018 FY 2019

$0

$500

$1,000

$1,500

$2,000

Millions

FORFEITURE REVENUE FROM ALL SOURCES
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1.1 – Appropriations Detail Table

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 2020 and FY 2021, 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.

3/ Treasury will compute the FY 2021 sequestration reduction once the OMB Report to Congress on the Joint Committee Sequestration for Fiscal 

Year 2021 is released.

Dollars in Thousands

Treasury Forfeiture Fund

Budgetary Resources

Revenue/Offsetting Collections FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT

Interest 0 $70,395 0 $50,000 0 $50,000 NA 0%

Restored Prior Year Sequestration 

Reduction 0 $84,405 0 $54,340 0 $35,229 NA -35%

Restored Prior Year Sequestration of 

Restored Rescission 0 $65,208 0 $0 0 $0 NA NA

Forfeited Revenue 0 $806,049 0 $547,096 0 $547,096 NA 0%

Recovery from Prior Years Obligation 0 $35,427 0 $15,000 0 $15,000 NA 0%

Unobligated Balances from Prior Years 0 $825,172 0 $609,632 0 $769,239 NA 26%

Total Revenue/Offsetting 

Collections $1,886,656 $1,276,068 $1,416,564 NA 11%

Expenses/Obligations

Mandatory Obligations 1 27 $394,628 27 $436,600 27 $445,332 0% 2%

Secretary's Enforcement 0 $24,614 0 $35,000 0 $35,700 NA 2%

Strategic Support 2 0 $603,442 0 TBD 0 TBD NA NA

Total Expenses/Obligations 27 $1,022,684 27 $471,600 27 $481,032 0% 2%

Rescissions/Cancellations

Sequestration Reduction 3 0 ($54,340) ($35,229) TBD NA NA

Permanent Cancellation 0 ($200,000) $0 $0 NA NA

Total Rescission/Cancellations ($254,340) ($35,229) $0 NA -100%

Net Results $609,632 $769,239 $935,532 NA 22%

Contingent Liabilities $473,316 $385,000 $385,000 NA 0%

FY 2019 FY 2020 FY 2021 FY 2020 to FY 2021

Actual Estimated Estimated % Change
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1.2 – Obligations Detail Table

Dollars in Thousands

Treasury Forfeiture Fund 

Obligations

FY 2019 

Actual

FY 2020 

Estimate

FY 2021 

Estimate

% Change FY 

2020 to FY 2021

Mandatory

 CBP $45,551 $41,284 $42,110 2.0%

 ICE $107,218 $120,780 $123,195 2.0%

 IRS $80,099 $122,043 $124,484 2.0%

 USSS $50,080 $42,969 $43,829 2.0%

 USCG $875 $1,400 $1,428 2.0%

 TEOAF $91,003 $89,393 $91,180 2.0%

 TTB $569 $1,037 $1,058 2.0%

 DOJ $19,233 $17,694 $18,048 2.0%

Total Mandatory $394,628 $436,600 $445,332 

SEF

 CBP $4,000 $4,400 $4,488 2.0%

 ICE $7,885 $12,123 $12,365 2.0%

 IRS $7,339 $12,001 $12,241 2.0%

 USSS $4,790 $6,126 $6,249 2.0%

 TTB $600 $350 $357 2.0%

Total SEF $24,614 $35,000 $35,700 

Strategic Support

 CBP $601,000 TBD TBD NA

 IRS 1 $2,442 TBD TBD NA

Total Strategic Support $603,442 $0 $0 

Total Expenses/Obligations $1,022,684 $471,600 $481,032 2.0%

1/ The $2.4M Strategic Support for IRS was approved late in FY18, therefore was extended in FY19. The actual amount of Strategic 

Support that was requested and approved in FY19 was $601M.
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1.3 – Operating Levels Table

E – Legislative Proposals

TEOAF has no legislative proposals.

Dollars in Thousands

Treasury Forfeiture Fund FY 2019 FY 2020 FY 2021

Object Classification Actual Estimated Estimated

25.2 - Other services 68,598 45,961 47,003

25.3 - Other purchases of goods & serv frm Govt accts 166,475 139,866 140,994

26.0 - Supplies and materials 15 15 15

41.0 - Grants, subsidies, and contributions 71,252 110,907 114,008

43.0 - Interest and dividends 50 50 50

44.0 - Refunds 88,238 139,831 142,960

94.0 - Financial Transfers 628,056 34,970 36,002

Total Non-Personnel 1,022,684 471,600 481,032

New Budgetary Resources $1,022,684 $471,600 $481,032

Budget Activities:

 Asset Forfeiture Fund $1,022,684 $471,600 $481,032

FTE 27 27 27
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Section II – Annual Performance Plan and Report

A – Strategic Alignment

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. TEOAF supports the following

Department of the Treasury strategic goal and associated objectives:

• Goal 3: Enhance National Security:

o 3.1 Strategic Threat Disruption

o 3.2 AML/CFT Framework

B – Budget and Performance by Budget Activity

2.1.1 Treasury Forfeiture Fund Resources and Measures

The FY 2015 - FY 2019 columns represent realized resources for full-time equivalents, reimbursables, and user fees.

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 the ones that pursue major criminal targets and their financial 

networks, and therefore are central to the mission of 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% or more) share of major forfeiture year after year demonstrates 

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.

Dollars in Thousands

FY 2015 FY 2016 FY 2017 FY 2018 FY 2019 FY 2020 FY 2021

Actual Actual Actual Actual Actual Estimated Estimated

Expenses/Obligations $4,323,908 $508,746 $526,228 $1,007,426 $1,022,684 $471,600 $481,032

$4,323,908 $508,746 $526,228 $1,007,426 $1,022,684 $471,600 $481,032

25 25 25 26 27 27 27

FY 2015 FY 2016 FY 2017 FY 2018 FY 2019 FY 2020 FY 2021

Actual Actual Actual Actual Actual Target Target

89.09 81.79 80 94.19 90.8 80 80

Measure

Budget Activity Total

Treasury Forfeiture Fund Budget 

Activity Resource Level

FTE

Percent of Forfeited Cash Proceeds Resulting 

from High-Impact Cases
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For FY 2020 and FY 2021, 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.

C – Changes in Performance Measures

TEOAF has no proposed changes to its performance measures. 

D – Evidence-Building Activity

In FY 2019, TEOAF has conducted various analyses related to the TFF member agencies’ 

investigative capabilities, resource needs and funding requests for the purpose of determining the 

most effective ways to allocate TEOAF’s funds. 

During the budget formulation process, TEOAF has reviewed and analyzed a large number of 

TFF agencies’ funding requests. Following the in-depth discussions with the agencies regarding 

the specific requests and the overall priorities, TEOAF has formulated the FY2020 Financial 

Plan designed to meet the needs of the TFF agencies’ Forfeiture program as well as advance their 

priority law enforcement efforts. TEOAF also have been actively analyzing over 100 cases 

designated for TEOAF’s support thought the Third Party Money Laundering Program. This 

included 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’ leadership in the field 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.

In FY 2020 and FY 2021, TEOAF will continue performing in-depth review and analyses of 

funding requests from the TFF agencies. TEOAF is also planning to continue analyzing the 

agencies’ investigative needs and exploring avenues to meet them using the TFF funds. One of 

the new efforts that has been recently launched is the upgrade of technology for scanning and 

analysis of financial records, to be 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/budget-performance/Pages/summary-of-capitalinvestments.aspx.