The Pennsylvania (Pa.) Office of Attorney General’s Asset Forfeiture and Money
Laundering Section conducted proactive targeting research on SARs that initiated a Pa. State Grand Jury Money Laundering investigation on two suspects.
FinCEN’s Gateway Program was utilized by the Pa. Attorney General’s Office, Bureau of Narcotics Investigation to conduct research in the Currency and Banking Retrieval System (CBRS) for additional BSA reports related to the two suspects. Those reports included 147 CTRs, 11 Currency Transaction Reports by Casinos (CTRCs), six Report of Foreign Bank and Financial Accounts (FBARs), four Report of International Transportation of Currency or Monetary Instruments (CMIRs), and seven SARs. The investigator stated they had the suspicious activity, but had no specified unlawful activity.
Subsequently, as a result of the Gateway Alert Program, a case match with the Immigration and Naturalization Service (INS), Philadelphia Office, was found. These two investigations eventually became one with federal prosecution. The PA Attorney General’s Office performed the money laundering investigation, and the INS performed the specified unlawful activity investigation, which was Harboring, Transporting, Encouraging Illegal Aliens to Reside in the United States. This activity was in violation of Title 8, USC, Section 1324 and 1324(a). The subjects were also charged under Title 8, USC, Section 1324(a), Unlawful Employment of Aliens, and Title 18 USC, Section 1961 (1), Racketeering Activity, sub-section (F) any act which is indictable under the Immigration and Nationality Act, Section 274 (relating to bringing in and harboring certain aliens).
The first phase of the investigation culminated on April 10, 2002 with the execution of ten search warrants in five states, and court orders freezing 36 bank accounts, and lis pendens placed on two pieces of real estate. The liquid assets amounted to $3.9 million, and the real estate amounted to $4.8 million. The total amount of assets seized is $8.7 million to date. This case is presently ongoing.
(Source: Pennsylvania Attorney General’s Office)