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The Cornerstone Report: Volume 3, Issue 1

Man Pleads Guilty to Operating Unlicensed Money Transmitting Business

Mohummed Islam Uddin, 39, a naturalized U.S. citizen from Bangladesh, operated Ibrahim Money Exchange, which was responsible for transmitting about $3 million to Bangladesh with little or no documentation about the senders or recipients of the money transfers.

ICE executed a search warrant and apprehended Uddin at his residence in March 2003. Evidence seized indicated that Uddin was preparing to depart the U.S. for Bangladesh. Additional documentary evidence revealed a pattern of unusual banking activity by using seven bank accounts in support of a money transmitting business.

Uddin operated a trade-based scheme to facilitate his illegal money transmitting business in which telephone calling cards were purchased on behalf of a pre-paid phone card merchant in Bangladesh. The merchant served as Uddin's distribution agent for Ibrahim Money Exchange. Uddin would purchase the cards with U.S. currency from a legitimate and unwitting U.S. communications corporation on behalf of the Bangladeshi merchant. The merchant would generate sales in local currency (takas) from the sale of the phone cards.

    Red Flag Indicators

    Flag icon Frequent transactions or purchase of negotiable instruments under $10,000 in order to avoid filing a Currency Transaction Report (CTR).

    Flag icon Splitting large currency deposits among several bank accounts.

    Flag icon Reluctance or refusal of depositor to provide identifying information to bank employees.

    Flag icon Purchase of any monetary instrument with large amounts of currency by a non-customer.

    Flag icon Wire transfers by charitable organizations to companies located in countries known to be bank or tax havens.

    Flag icon Transfer of funds to a commercial account with no logical relationship or connection to the sender of the funds.

The ICE investigation uncovered that once the merchant received the takas, he would then distribute the funds to the ultimate recipients in Bangladesh on behalf of Ibrahim Money Exchange. Uddin avoided paying the fees to convert U.S. dollars to takas, and was also able to avoid conducting suspicious international wire transfers.


Did You Know?
  • ICE agents have made nearly 3,000 outreach presentations to more than 57,000 individuals worldwide.

  • In Fiscal Year 2005, ICE agents seized $1.3 billion in illicit cash and assets.

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