One of the worst child support cases I know about is Janet O. v. James O., slip op. 51985 (Sup. Ct. N.Y. County, October 17, 2006). The ex-husband in Janet O had not made any child or spousal maintenance support payments for 30 years. By moving from New York and living offshore in Barbados, the Dominican Republic and Mexico, the ex-husband evaded enforcement proceedings on behalf of his ex-wife & their 3 sons. Consequently, the ex-wife and their 3 sons were relegated to poverty and public assistance.

Meanwhile, the ex-husband remarried and adopted his new wife’s 2 daughters.  Ultimately, the New York court referred the Janet O matter to federal prosecutors. When a parent moves offshore to evade child support, federal prosecutors may bring a criminal case pursuant to the Child Support Recovery Act at 18 U.S.C.§ 228 et. seq. A parent criminally charged with violating 18 U.S.C.§ 228 hopefully has an additional incentive to pay child support.

Elements of A Case Under 18 U.S.C. § 228 (a)(2)

18 U.S.C. § 228 (a)(2) covers a parent who crosses state lines or leaves the country in order to evade child support. A violation of 18 U.S.C. § 228 (a)(2) is punishable by up to two years imprisonment and by a fine up to $250,000. To show a defendant violated 18 U.S.C. § 228 (a)(2), a federal prosecutor would prove these elements at trial:

  • the defendant traveled in interstate or foreign commerce with the intent of evading child support obligations;
  • the defendant had a past due child support obligation exceeding $5000;
  • and the obligation is unpaid for more than a year.

Additionally, a prosecutor may use Federal Rule of Evidence 404 (b) to supply evidence at trial about the defendant’s: motive; opportunity; intent; plan; etc. For example, pursuant to Rule 404 (b) a prosecutor might show the jury the defendant’s tax returns to prove the defendant could have paid the child support obligation.

U.S.A. v. Juelle-Albello

Like the ex-husband in Janet O, Mr Juelle-Albello was accused of moving offshore to evade child support. In U.S.A. v. Juelle-Albello, federal prosecutors indicted Mr. Juelle-Albello for his suspected violation of 18 U.S.C. § 228 (a)(2).  Mr. Juelle-Albello married Diana Umpierre in Puerto Rico on 11/8/1991. On 6/26/2007 Mr. Juelle-Albello and Ms. Diana Umpierre were divorced.  Among other things, Mr. Juelle-Albello was suppose to pay $13,893.81 a month for child support through the Puerto Rico Child Support Administration (“ASUME”). As of June 2018 Mr. Juelle-Albello’s outstanding debt to ASUME reportedly was $1,868,012.50.

According to federal prosecutors, Mr. Juelle-Albello made no payments to ASUME from July 2013 to June 2018. Instead of making the payments, Mr. Juelle-Albello moved to Florida in 2011 where he lived with his new wife and new daughter. Then during 2014, Mr. Juelle-Albello left the U.S. for Mexico. However, in July 2018 Mexican authorities placed Mr. Juelle-Albello in U.S. custody by deporting him pursuant to an arrest warrant in U.S.A v. Juelle-Albello. The list of evidence prosecutors intended to use at Mr. Juelle-Albello’s trial included: Mr. Juelle-Albello’s record of payments to ASUME; court orders from the Court in Bayamon, Puerto Rico; Snapchat photos; etc. On 8/12/2019 Mr. Juelle-Albello pleaded guilty to violating 18 U.S.C. § 228 (a)(2). Mr. Juelle-Albello’s sentencing is now set down for 7/21/2020.

Copyright 2020 Fred L. Abrams

This 42nd post in my Divorce & Hidden Money series mentions a divorcing wife, (Person “A”), believed to have hidden her ownership of a farm equipment company (Company “A”). This post is also about Mr. Dusko Bruer of Palm Beach County, Florida who had supposedly gifted Company “A” to Person “A”. Meanwhile, in USA v. Bruer prosecutors filed their January 30, 2020 criminal information accusing Mr. Bruer of hiding money from the IRS in secret offshore bank accounts and otherwise.


Mr. Bruer employed Person “A” as his personal assistant and as a bookkeeper for Company “A”. To possibly hide assets from the IRS, Mr. Bruer gifted his Company “A” to Person “A” in or about September 2009. At that time, Person “A” was embroiled in a contentious divorce case. During the divorce, Person “A” hid her supposed ownership of Company “A” from her husband. Person “A” did this by using her relative, (Person “B”), as the straw owner of Company “A”. At corporate records for Company “A,” Person “A” &/or Person “B” indicated Person “B” was the owner. However, Person “B” lacked the authority to run daily operations at Company “A”; and Person “A” and/or Mr. Bruer are believed to have been the true beneficial owner[s] of Company “A.”


Although Mr. Bruer purported to gift Company “A” to Person “A” in or about September 2009, Mr. Bruer apparently retained control over bank accounts belonging to Company “A”. After 2009, Mr. Bruer reportedly used these bank accounts:

  • to pay hundreds of thousands of dollars for his personal expenses, make investments offshore, and transfer money to his relatives and an employee;
  • in or about 2010 to purchase a 54-foot yacht called “Hawk’s Nest” for $235,000;
  • between 2010 to 2014 to pay about $135,000 for the service; registration; and docking of Hawk’s Nest and another yacht;
  • between 2012 and 2013 to pay a relative’s condo fees in NYC amounting to about $21,000;
  • between 2011 and 2014 to transfer approximately $540,000 to another company Mr. Bruer owned.

Continue Reading Divorce & Hidden Money: A Farm Equipment Company & Tax Fraud

Today’s post shows how Mr. Farkhad Akhmedov may have hidden money from his now ex-wife Tatiana Akhmedova. It describes how Mr. Akhmedov could have placed money out of Ms. Akhmedova’s reach by: using nominees (i.e. intermediaries) ; parking assets offshore; transferring assets to a Bermudian trust & Liechtenstein entities. This post is the 41st post in my Divorce & Hidden Money series.

In 2016 a UK court awarded Tatiana Akhmedova a £453 million judgment against her now ex-husband Farkhad Akhmedov.  This could be the largest UK divorce award to date.  The £453 million was 41.5 percent of Mr. Akhmedov’s wealth. To collect the £453 million from Mr. Akhmedova, Ms. Akhmedova brought legal proceedings in England; Dubai; the Marshall Islands; Liechtenstein and New York. In New York, Ms. Akhmedova filed a motion seeking a court order recognizing her foreign UK judgment(s) in NY. Despite Ms. Akhmedova’s worldwide efforts, Ms. Akhmedova reportedly recovered only 1% of the £453 million.

According to Ms. Akhmedova, Mr. Akhmedov hid assets through nominees or alter egos. Ms. Akmedova also alleged Mr. Akhmedova used their 26-year-old son Temur to hide substantial sums of money. By using nominees, Mr. Akhmedov might have hidden his: bank accounts; art collection; real estate; yacht and aircraft. For example, one way to hide a yacht or aircraft is to form a Delaware shell company and then use a nominee director to register the yacht or aircraft with anonymity.

Furthermore, court filings assert Mr. Akhmedov placed assets in a Bermudian trust associated with business entities in Panama, Cyprus and the Isle of Man. However, Mr. Akhmedov reportedly transferred the Bermudian trust assets to Liechtenstein entities.  The UK court’s decision and the flowchart reproduced below, mention the Bermudian trust which Mr. Akhmedov apparently used to hide assets.Diagram of Farkhed Akhmedov's suspected assets. all

“Better Call Saul” & “Breaking Bad” remind us to look during asset searches for lawyers hiding money. In these fictional cable TV series, criminal defense lawyer Saul Goodman laundered money for meth maker Walter White & his co-conspirator Jesse Pinkman. At Breaking Bad’s Season 3, Episode 11 for example, Saul Goodman recommended washing illicit drug monies by investing them in a laser tag business. As set forth below, we should always look during asset searches for lawyers hiding money.

A) Hiding Assets Via A Sham Corporation

Moreover, Ohio criminal defense lawyer Matthew J. King was the subject of the article “Lawyer who suggested ‘Breaking Bad’ method to launder cash has conviction upheld by appeals court.”  Mr. King allegedly offered to hide/launder illicit drug monies through a sham corporation. Mr. King learned how to do this by watching Breaking Bad’s Saul Goodman on TV. Mr. King also allegedly offered to wash illicit drug monies by placing them in his attorney escrow account. On October 14, 2014 Mr. King was indicted on three counts of money laundering. On August 30, 2016 Mr. King was convicted and was sentenced to 44 months in prison on each count (to be served concurrently).

B) Some Other Concealment Methods

The case against Maryland criminal defense lawyer Kenneth Wendell Ravenell also reads like a script from Breaking Bad or Better Call Saul. Mr. Ravenell’s September 18, 2019 indictment charged him with a racketeering conspiracy, drug conspiracy and money laundering conspiracy.  Mr. Ravenell’s indictment claimed he helped his drug-trafficking client launder illicit drug monies.  The indictment basically alleged Mr. Ravenell could have hidden money or washed it in these ways:

  • placing illicit drug monies into law firm bank accounts;
  • commingling illicit drug monies with monies in a personal bank account;
  • disguising illicit drug monies as client funds then using the monies to pay other lawyers;
  • telling drug dealers how to engage in bulk-cash smuggling (& transport illicit drugs);
  • investing illicit drug monies in a restaurant in Glen Bernie, Maryland & additional businesses;
  • and using law firm mail to distribute money orders drug dealers purchased with illicit monies.

Video: AMC Network Entertainment, LLC

Copyright 2020 Fred L. Abrams

Money laundering by rigging courtsOne money laundering method involves hiding money by rigging court cases.¹ A plaintiff sues a defendant over a supposed breach of contract. Meanwhile, nobody knows the defendant is the plaintiff’s strawperson and the two have rigged the court case. When the plaintiff wins the bogus breach of contract case, the Court issues a money judgment against the defendant. Then, the plaintiff secretly transfers money to the defendant. The defendant launders plaintiff’s money by paying it to the plaintiff to satisfy the money judgment. This kind of money laundering could have occurred in the following fact pattern which I have changed for privacy reasons. The fact pattern includes comments about money laundering from counsel in Switzerland.

I) Mr. “J’s” Missing $500 Million At His Swiss Bank

Mr. “J” who lives in New York City e-mailed a NY lawyer. Although Mr. J’s e-mail was written in English it had some spelling errors. Mr. J’s e-mail said that Mr. J sold his commercial real estate to corporation “X” for $500 million USD in cash. X however, failed to pay Mr. J the $500 million. Mr. J then brought a lawsuit against X in Zürich, Switzerland and the Court entered a $500 million money judgment against X. To satisfy the judgment, X deposited $500 million in cash into Mr. J’s  bank account in Zürich. Mr. J’s e-mail also claimed the $500 million was now missing from Mr. J’s Zürich bank account. Mr. J’s e-mail said Mr. J wanted to hire the NY lawyer to recover Mr. J’s $500 million from the bank in Zürich.

II) Was Mr. J Hiding Money Through Money Laundering?

The NY lawyer thought that Mr. J might have been hiding money at his Zürich bank account. The NY lawyer therefore forwarded Mr. J’s e-mail to counsel in Zürich, Switzerland. Counsel in Zürich sent the New York lawyer a reply e-mail which said in relevant part:

In my view [Mr. J’s e-mail] is indeed suspicious. I see several signs for this, for example: The text is confusing and has English mistakes (‘proof’ instead of ‘prove’). The sums involved are extravagant and are simply too important to have disappeared. While the absolute size of the amounts involved is not unheard of, it would be unusual for such sums to be deposited in cash. This means that the transactions involved would have been carefully investigated by the bank as part of their due diligence, but no details of this investigation are offered [at Mr. J’s e-mail]. It is a known tactic of money laundering to obtain judgements or arbitral awards in rigged cases (where the opposing parties are in fact conspirators) to justify a seemingly impeccable source of funds. The background of the Zürich proceedings is not explained in any way. If one really wanted to get to the bottom of this, the best course would be to seek legal assistance from the Swiss authorities. For this, some US (or other) prosecutor would need to make a request to the Swiss authorities, perhaps based on alleged money laundering. The Swiss authorities should then be able to access the bank documentations from anywhere in Switzerland (and not only from Zürich), the court documents from the alleged Zürich proceedings, even files from lawyers. Based on this information further steps could be contemplated. I advise utmost caution in dealing with this matter.


¹I listed additional laundering methods at “Red Flags For An Asset Search.”

Copyright 2020 Fred L. Abrams

(This chart identifies alleged members and suspected businesses of the drug trafficking organization discussed at the press release available by clicking here.)

Make flowcharts in your asset search to show how your adversary has hidden money or other assets from you. The flowcharts in your asset search might document that your adversary hid assets through any one or a combination of the following:

  • fraudulent transfers
  • business entities;
  • nominees;
  • foreign bank accounts;
  • trusts;
  • sham loans;
  • multiple jurisdictions; etc.

How your adversary hid assets may become even more apparent to you if you make a flowchart (a.k.a. link chart). A free platform for making flowcharts is at the Visual Investigative Scenarios webpage. It is a good flowcharting tool for tracking assets & cases involving asset recovery.

Chart courtesy of U.S. Department of the Treasury.

Copyright 2020 Fred L. Abrams

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

Free Asset Search Tools

Free asset search tools range from seeking information about shell companies to detecting real estate ownership in New York City. At “CorporationWiki” you may possibly gather information about shell companies & at “ACRIS” you can search for NYC real estate ownership. I mentioned CorporationWiki & ACRIS at “A Low-Cost Asset Search” or “Asset Searches & Open Source Intelligence” which list more asset search tools. In addition, you can search leaked documents by using free asset search tools.

Computer hackers or informants may supply journalists with stolen banking; attorney-client privileged; or other confidential documents. When the stolen documents concern the public, “there is a significant legal distinction between stealing documents and disclosing documents that someone else had stolen previously.” Democratic Nat’l Comm. v. Russian Fed’n, 392 F. Supp. 3d 410, 431 (S.D.N.Y. 2019). As a result, journalists sometimes disclose leaked documents.

The International Consortium of Investigative Journalists (“ICIJ”) for example, publishes its Offshore Leaks Database. Consequently, you can use this database to run free searches of specific persons or business entities. Although this database does not include banking information or e-mails, it has leaked information regarding more than 785,000 offshore entities.  Likewise, you can search the Distributed Denial of Secrets website.  Besides documents stolen from the Cayman National Bank, Isle of Man by hacker Phineas Fisher, this website has many more leaked documents.

Copyright 2019 Fred L. Abrams

Last Tuesday Senator Warren released her plan to track hidden money & fight corruption. Money launderers, tax dodgers, narco-traffickers; terrorist financiers and other fraudsters can easily establish shell companies without disclosing who actually owns the shell companies. They open bank accounts and maintain the bank accounts in the names of the shell companies, as mentioned at my December 10th & December 17th posts. As a result, the money launderers, terrorist financiers, tax dodgers, etc. secretly transfer money through these bank accounts.  By following these steps, they wash the money & hinder an asset search.

Therefore, part of Senator Warren’s plan seeks “beneficial ownership” disclosure regarding shell companies. The plan at Senator Warren’s website however, does not explain who would make the disclosure. Businesses that form and sell shell companies might have to identify the beneficial owners of shell companies and report this information to governmental authorities which track hidden money.  The beneficial owners of shell companies could also be required to make reports to governmental authorities.

Whatever your views about Senator Warren are, you will hopefully agree that it would be a good idea to require “beneficial ownership” disclosure. For the reason that the misuse of shell companies has real-world consequences as the “Victims of Offshore” video explains.

Video: Courtesy of ICIJ

Copyright 2019 Fred L. Abrams

An asset search for stock share certificates begins with looking for red flags.  These red flags are listed at the July 2019 paper “FIU Tools and Practices for Investigating Laundering of The Proceeds of Corruption.”  As page 19 paragraph 29 of the paper says, you should look for:

[R]eceiv[ing] or purchas[ing] shares (or the option to purchase shares):

  • In a company in exchange for services; or
  • In a company where the purchase is financed by the vendor; or
  • In a company where the purchase price is below the net asset value of the company; or
  • In a company and receives a dividend from the company which is disproportional to the purchase price; or
  • Which give the right to sell shares at a price which is higher than either the current market value or the price at which the shares were purchased; or
  • And profit from a share transaction where the purchase and selling dates of shares are within a short time period.”

The July 2019 paper is about corrupt politicians who launder illicit assets. Bribe-taking politicians for instance, may hide bribe monies by transferring them through “several foreign jurisdictions.”  Crooked politicians or other launderers also use stock share certificates in their schemes to hide assets.  They first establish shell companies. Next, they issue the stock share certificates for the shell companies to themselves. The crooked politicians/launderers then title bank accounts; real estate; high-value automobiles; etc. in the name of the shell companies. To see how some individuals carry out this kind of scheme you can read my post “Bearer Shares & An Asset Search.”

Copyright 2019 Fred L. Abrams