1. Part IV

2. MONEY SERVICE BUSINESSES Another Money Laundering Trend

3. MONEY SERVICE BUSINESSES Since the passing of the USA PATRIOT Act (October 2001), ICE has initiated 404 investigations of 18 USC 1960 (Prohibition of Unlicensed Money Transmitting Businesses) violations resulting in: Arrests: 201 Indictments: 194 Seizure of: over $50,000,000

4. ICE Financial Investigations Tools / Authorities Section 373 of the USA PATRIOT Act amended 18 USC 1960 by providing 3 ways an Illegal Money Service Business (MSB) can be prosecuted: 1)MSB operating without a state license* 2)MSB operating in violation of Treasury regulation requiring registration with FinCEN 3)MSB knowingly transfers money derived from a criminal offense, or transfers money intended to be used for unlawful purpose. Investigator does not need to trace the money * Knowledge requirement removed; not necessary to prove target knew license was required or operating without a license was a crime.

5. ACCESS INC. OF USA SAC Newark Unlicensed Money Service Business

6. ACCESS INC OF USA SAC Newark ICE SAC Newark conducted this investigation, in conjunction with the IRS, based upon the filing of 4 SARs on Access Inc. of USA, a licensed MSB operating in New Jersey Although Access Inc. of USA was a licensed MSB, the owners and operators of the MSB conspired with 4 unlicensed money remitters (couriers) operating out of New York to commit the criminal acts The 4 couriers brought large sums of cash to the MSB that were deposited into the MSBs bank accounts and then wired to the Middle East Overview

7. ACCESS INC OF USA SAC Newark Investigative findings: MSB not open to the general public MSB operated with a very limited number of clients, yet made over $100 million in cash deposits within 30 months MSB owners failed to file CTRs for cash deposits made by their clients MSB prepared fraudulent records to evade their CTR filing requirements

8. 6 arrest warrants, 4 search warrants, and 4 subsequent consensual searches Subjects charged with: 18 USC 1960 (Prohibition of Unlicensed Money Transmitting Business) 31 USC 5312, 5313, 5324 (Failure to File CTRs) 18 USC 371 (Conspiracy to Fail to File CTRs) 4 convicted of 18 USC 1960 / 18 USC 2 Approximately $200,000 seized ACCESS INC OF USA SAC Newark Results

9. ACCESS INC OF USA SAR HIGHLIGHTS Information included in SARs filed by institutions : CTRs were filed on MSBs cash deposits totaling $751,000 between January 2001 and March 2001 Amounts matching above deposits were immediately wired to Pakistan and the UAE An unidentified employee attempted to deposit over $10,000 cash Employee refused to provide identification when requested by bank official Bank contacted MSB owner and advised of BSA regulations and bank policy

10. ACCESS INC OF USA SAC Newark Frequent and large cash deposits Immediate wire transfers to personal accounts in countries of concern Attempts to structure cash deposits Customers refusal to show identification Red Flag Indicators (SARs)

11. MSBs appearance inconsistent with usual and customary business practices Located in upstairs apartment of converted house Access to business via unmarked rear door Door to business kept locked at all times Business name not displayed on building Non-published telephone number / Not advertised in yellow pages ACCESS INC OF USA SAC Newark Red Flag Indicators (Investigation)

12. ACCESS INC OF USA (front view)

13. ACCESS INC OF USA (back view)

14. ICE / Cornerstone Website www.ice.gov/cornerstone Cornerstone Report - an ICE quarterly publication that provides information on financial crimes and current trends identified by both law enforcement and the private sector. The Cornerstone Report can be accessed at www.ice.govwww.ice.gov To Contact the nearest ICE SAC office: Go to www.ice.gov - Investigations / Contact Informationwww.ice.gov A overview of the Financial and Trade Investigations Division, including; Cornerstone Initiative; Financial Crimes; Red Flag Indicators; Commercial Fraud; IPR Center; How You Can Help; and quarterly editions of the Cornerstone Report can all be found at:

15. Special Agent Name Contact Information Location Date