This 40th post in my Divorce & Hidden Money series mentions Mr. Vardan Keshishyan, who reportedly hid money from his divorcing wife by smurfing (a.k.a structuring ).  In the context of money laundering, a smurf makes cash deposits below a bank’s threshold for reporting cash deposits to the government. By doing this the smurf hopes to fly under the government’s radar. There is even a variation of smurfing called “cuckoo smurfing.”

While Mr. Keshishyan was a U.S. ICE deportation officer, he was arrested on September 25, 2019 for suspected smurfing in violation of 31 U.S.C. § 5324(a)(3). On or about November 7, 2014, Mr. Keshishyan’s then-wife filed for divorce in Los Angeles Superior Court, Case No. BD611140. During the divorce, Mr. Keshishyan and his then-wife sold their marital residence.  Mr. Keshishyan’s share from the sale was about $96,369.22.  Based on the allegations at Mr. Keshishyan’s indictment, Mr. Keshishyan is believed to have lied about what had happened to this money. At a June 2015 hearing in the divorce, Mr. Keshishyan reportedly testified he lost $95,000 of the $96,369.22 he received from the sale of the marital residence. This supposedly partly happened because Mr. Keshishyan had made a bad investment.

Instead of losing the $95,000, Mr. Keshishyan apparently transferred it to his bank accounts along with other money totaling $99,000.  Mr. Keshishyan reportedly split the $99,000 into eleven cash deposits made to his bank accounts. Mr. Keshishyan is believed to have smurfed because each of his alleged eleven cash deposits were below the $10,000 threshold for banks to report the deposits to the government. Although not a divorce & hidden money case, the fact pattern below shows how a traffic stop by police officers led to a smurfing investigation.

Local Municipality Case Example (Drugs and Money Laundering) courtesy of US Treasury’s FinCEN.

Copyright 2020 Fred L. Abrams