Table 1 partly shows that 2 shell companies were allegedly used by Congressman Henry Cuellar and / or his wife Imelda Cuellar, to wash $360,000 in suspected bribe payments.1

On 4/30/24 Congressman Henry Cuellar and his wife Imelda were indicted in USA v. Cuellar. According to their indictment, the two supposedly laundered $600,000

If you are in a high net worth divorce, your spouse might hide community property from you by misusing:

These are just three of the common money laundering methods. Although not a high net worth divorce case, filings in Brooklyn Federal Court in USA v. Ahmad reveal

Hunter Biden allegedly used shell companies & the diamond at this chart, in a supposed corruption scheme.*

As was widely reported, The U.S. House Committee on Oversight and Accountability, (“the Committee”), published its August 9th memo about Hunter Biden and some other Biden family members. On the one hand, House Republicans on the Committee allege

This chart shows how dentist Glenn E. Lockwood allegedly hid assets by structuring cash withdrawals.¹

The First Scheme To Hide Assets

Prosecutors in U.S.A. v. Lockwood, allege Alaska dentist Glenn Lockwood hid assets twice from the IRS.  During Mr. Lockwood’s first scheme, Mr. Lockwood supposedly hid $575,000 in federal income

We all know that compared to money hidden at domestic bank accounts, money hidden in offshore accounts is harder to detect and interdict. This explains why offshore bank accounts are perhaps the most widely used method to hide vast sums of money. Individuals ranging from high-net-worth divorcing spouses to narco-traffickers and terrorist financiers can use

There ain't that many smurfs in the world.

If you are trying to detect hidden money you should look for asset search red flags like “smurfing¹.” Smurfing is a form of structuring cash deposits into bank accounts. It is one of the ways to secretly place cash into a money laundering circuit. When a bank customer in the U.S. deposits or withdraws $10,000 or more in cash, the bank must file a Currency Transaction Report (“CTR”). The bank files CTRs with FinCen which is a financial intelligence unit. To prevent the bank from filing a CTR, a smurf would make several cash deposits under $10,000. By structuring the cash deposits this way, the smurf hopes to fly under the radar.

ALLEGED SMURFING IN USA v. BAHADORIFAR, ET. AL.

Count Five of the 7/13/21 superseding indictment in USA v. Bahadorifar, et. al., 21 Cr. 00430(RA), highlights an alleged smurfing scheme. The smurfing scheme was supposedly carried out by California resident and department store employee, Ms. Niloufar Bahadorifar. Page 34 ¶¶ 41-42 of the 7/13/21superseding indictment at Count Five says:

[B]etween at least approximately April 2019 and May 2021, BAHADORIFAR structured cash deposits totaling at least approximately $505,822 at a financial institution in individual deposits of less than $10,000 each.

Additionally, page 9 ¶ 12 of the 7/13/21 superseding indictment claims that since July 2020, Ms. Bahadorifar made about $472,000 in unexplained cash deposits into her bank account. This allegedly included 98 cash deposits totaling approximately  $444,000 that were each less than $10,000. Ms. Bahadorifar is also thought to have tried to secretly transfer money by using debit &/or credit cards.

THE SUSPECTED IRANIAN TERRORIST NETWORK

Meanwhile, an Iranian terrorist network, (“the Network”), may be the true beneficial owner of Ms. Bahadorifar’s alleged $472,000 in unexplained cash deposits. The Network is comprised of Iranian intelligence officers and/or their intelligence assets. It is reportedly tasked with kidnapping exiled Iranian dissidents for rendition to Iran. Once the kidnapped victims are back in Iran, they face imprisonment &/or execution. According to the 7/13/21 superseding indictment, the Network planned to kidnap Iranian journalist Masih Alinejad, who lives in exile in Brooklyn, NY.  The Network apparently set its sights on Ms. Alinejad because she is vocal about the Government of Iran’s human rights abuses.

MISUSE OF PRIVATE INVESTIGATORS

During the alleged scheme to kidnap Ms. Alinejad for rendition to Iran, the Network allegedly hired licensed private investigators to place Ms. Alinejad under surveillance in Brooklyn, N.Y. The Network through its intelligence officers &/or intelligence assets hired the private investigators under the pretext of recovering money Ms. Alinejad supposedly stolen &/or supposedly owed to a foreign creditor. The Network is thought to have even hired a Manhattan-based private investigator to place a vehicle with a hidden camera in front of Ms. Alinejad’s Brooklyn home. This could provide the Network with live video monitoring of the home.

THE DECISION TO INITIATE OR DECLINE PROSECUTION 

Even though the Network hired private investigators to surveil Ms. Alinejad, prosecutors declined prosecution of the private investigators.The prosecutors might have believed the Network duped the private investigators into surveilling Ms. Alinejad. Prosecutors similarly declined prosecution of Ms. Bahadorifar for a conspiracy to kidnap Ms. Alinejad.  Prosecutors declined this prosecution although Page 9 ¶ 12 of the 7/13/21 superseding indictment alleges Ms. Bahadorifar “caused a payment to a private investigator for surveillance of [Ms. Alinejad]…”Continue Reading Asset Search Red Flags, Smurfing, Private Investigators & A Kidnap Plot

Everybody knows there can be hidden community property in ultra-high-net-worth divorces.  Meanwhile, the ultra-high-net-worth divorce between Mr. Bill Gates and his wife Melinda does not now appear to involve hidden community property.  Their divorce does however, give us a glimpse of the kinds of community property the Court often divides in ultra-high-net worth divorces.

A Financial Intelligence Unit (“FIU”) tracks hidden assets by “following the money.”  There is always a money trail when assets are hidden and money is laundered. One way FIUs follow a money trail is by collecting suspicious activity reports from banks about bank customers. FIUs can follow a bank customer’s money trail