RUSSIAN ORGANIZED CRIME (ROC)

Russian organized crime has become a significant problem for California law enforcement agencies. During the past several years, some Russian emigres have established a growing number of loosely structured criminal networks in this state that are involved in sophisticated criminal activities. The law enforcement intelligence community has also become aware of at least four structured Russian criminal organizations operating in California.

Russian organized crime includes crime groups from all the republics which comprised the former Soviet Union. These crime groups are operating in many of the major cities in California including Los Angeles, San Francisco, San Jose, Sacramento, and San Diego. Russian crime figures have been identified in cases involving extortion, prostitution, insurance and medical fraud, auto theft, counterfeiting, credit card forgery, narcotics trafficking, fuel tax fraud, money laundering, and murder.

Russian organized crime networks are also operating in New York, Boston, Chicago, Miami, Cleveland, Philadelphia, and Seattle. Many of the California-based networks communicate and, in many cases, are connected with these out-of-state groups in their criminal activities.

Many Russian organized crime groups in the United States have ties to organized crime groups in Russia. A report on organized crime presented to President Boris Yeltsin by Russia's Analytical Center for Social and Economic Policies, stated "The growth of organized crime threatens the political and economic development of Russia and creates conditions that could help bring the national socialists to power."

An estimated 80 percent of the private enterprises and commercial banks in Russia's major cities are forced to pay a tribute of 10 to 20 percent of their profits to organized crime.

On April 21, 1994, during a Senate hearing, CIA Director R. James Woolsey said, "Organized crime is so rampant in Russia that it threatens Boris Yeltsin's presidency and raises concern that syndicates will obtain and smuggle Russian nuclear weapons to terrorists or foreign agents."

Wooisey revealed that organized crime syndicates from Russia, Asia, and Africa are forming alliances with traditional Italian and Latin American organizations, creating a formidable threat to international peace and stability.

In recognition of this threat, the FBI recently established a Moscow office that will focus on Russian organized crime encroachment into the United States along with the potentially disastrous threat of trafficking in nuclear weapons. U.S. Aftorney General Janet Reno has named Russian organized crime groups in the United States a priority target for the U.S. Department of Justice. Law enforcement agencies throughout the U.S. now consider Russian organized crime a major threat and are developing strategies and forming task forces to counter that threat.

During the 1970s and 1980s, according to the U.S. Immigration and Naturalization Service, approximately 200,000 Soviet citizens, many who were Russian-Jewish refugees, immigrated to the U.S. Although the Soviet government liberalized its Jewish immigration policy, it is believed that under this guise the KGB also emptied their prisons of hard-core criminals, much like Cuban dictator Fidel Castro did during the Mariel boatlift of 1980. Many of these criminals are believed to have continued their life of crime in the United States.

The flow of Soviet refugees increased following congressional enactment of the Lautenberg Amendment in November 1989, which allows up to 50,000 Soviet refugees to enter the U.S. each year. This was followed by the adoption in May 1991, of Russia's first law granting its citizens the right to immigrate and travel freely.

In 1994, according to the U.S. Immigration and Naturalization Service, the majority of former Soviet emigres and refugees entering the U.S. declared as their intended state of residence New York, followed by California, Washington, Illinois, Pennsylvania, Massachusetts, Maryland, New Jersey, Ohio, and Oregon.

According to an April 1986 report by the President's Commission on Organized Crime, the first indication of an organized crime element among Russian immigrants came in 1975 when a gang from the Odessa region of Russia was discovered to be involved in major fraud. The victims were other Russians living throughout the United States. The group became known as the "Potato Bag Gang" because victims believed they had bought a sack of gold coins but actually received only a bag of potatoes.

Soviet criminal networks gradually expanded into other criminal activities such as extortion, theft, prostitution, and actively preyed upon newly arriving groups of Russian emigres by extorting money from them. The Brighton Beach area of New York City became the hub for Russian organized crime in this country during the mid-1970s. There, Russian criminals developed a working relationship with the La Cosa Nostra (LCN) which allowed them to establish fuel tax fraud schemes in certain areas of New York. The LCN forced the Russian criminals involved in these frauds to pay a large portion of their proceeds as a "tax" to operate.

Russian Organized Crime Groups and Structure in Russia - In early 1993, the Russian Ministry of Internal Affairs reported there were over 5,000 organized crime groups operating in Russia. These groups were comprised of an estimated 100,000 members with a leadership of 18,000. Although Russian authorities have currently identified over 5,000 criminal groups in that country, Russian officials believe that only approximately 300 of those have some identifiable structure. Organized crime groups in Russia are not nearly as structured as those in the U.S., such as the LCN.

Knowledgeable sources within the Financial Crimes Enforcement Network (FinCEN) have provided one model of the structure of groups in Russia. The principle behind this structure is to minimize contact with other cells that could lead to the identification of the entire organization.

Each boss, called a "pakhan," controls four criminal cells through an intermediary called a "brigadier." The boss employs two spies that watch over the action of the brigadier to ensure loyalty and that he does not get too powerful. At the bottom of the structure are criminal cells specializing in various types of criminal activity or functions such as drugs, prostitution, political contacts, and "enforcers." A similar structure places an elite leadership on top which is buffered by support and security personnel from the street operators who are commifting the crimes. Street operators are not privy to the identity of their leadership. Strategy and planning is done only at the top echelon in order to minimize the risk of detection.

According to law enforcement sources, those structures described above would fall into the old style of Soviet criminal enterprises. It is quite possible as organized crime has changed in Russia, so has the structure of these groups.

Thieves' Code of Conduct - There is a traditional code of conduct within this old style of organized crime in Russia called "Vory v Zakone," or thieves in law. This group existed throughout the Soviet era and continues today throughout the republics of the former Soviet Union. In this society the thieves in law live and obey the "Vorovskoy Zakon," the thieves' code. The members are bound by 18 codes and if they are broken, the transgression is punishable by death.

Law enforcement officials in the former Soviet Union indicate that most of the organized crime groups are well organized with sophisticated technical equipment, computers, transportation, financial support, and an excellent counterintelligence network. Those groups are involved in extortion, precious metal and raw material smuggling, money laundering, fraud, weapons smuggling, narcotics trafficking, and black marketing.

1.Forsake his relatives--mother, father, brothers, sisters... 2.Not have a family of his own -- no wife, no children; this does not however, preclude him from having a lover. 3.Never, under any circumstances work, no mafter how much difficulty this brings-, live only on means gleaned from thievery. 4.Help other thieves -- both by moral and material support, utilizing the commune of thieves. 5.Keep secret information about the whereabouts of accomplices (i.e. dens, districts, hideouts, safe apartments, etc.). 6.In unavoidable situations (if a thief is under investigation) to take the blame for someone else's crime; this buys the other person time of freedom. 7.Demand a convocation of inquiry for the purpose of resolving disputes in the event of a conflict between oneself and other thieves, or between thieves. 8.If necessary, participate in such inquiries. 9.Carry out the punishment of the offending thief as decided by the convocation. 10.Not resist carrying out the decision of punishing the offending thief who is found guilty, with punishment determined by the convocation. 11.Have good command of the thieves'jargon ("Fehnay"). 12.Not gamble without being abie to cover losses. 13.Teach the trade to young beginners. 14.Have, if possible, informants from the rank and file of thieves. 15.Not lose your reasoning ability when using alcohol. 16.Have nothing to do with the authorities (particularly with the ITU [Correctional Labor Authority]), not participate in public activities, nor join any community organizations. 17.Not take weapons from the hands of authorities; not serve in the military. 18.Make good on promises given to other thieves.

Although Russian organized crime activity in the United States has been expanding for the past 20 years, its most significant growth has occurred during the past five years. In August 1993, the FBI reported there were 15 organized crime groups in the United States with former Soviet ethnic origins. There is considerable debate in the law enforcement community as to the level of organization and structure of Russian organized crime groups in the United States. Additionally, many of the Russian emigres who are involved in criminal activity in this country may be career criminals specializing in crime areas having little or nothing to do with Russian organized crime groups.

Current information indicates that most Russian organized crime groups are loosely organized and do not have elaborate levels of structure. These groups are often influenced by their ethnic or regional backgrounds. They have formed networks that operate in situations of mutual interest and often shift alliances to meet particular needs.

There is ample information that Russian crime groups operating on the East Coast cooperate and communicate with West Coast groups. Additionally, Russian organized crime groups in the U.S. communicate and operate with organized crime groups in Russia. FBI Director Louis Freeh stated that over 200 of Russia's 6,000-odd crime gangs operate with American counterparts in 17 U.S. cities in 14 states. According to intelligence reports, members of criminal groups in Russia are sent to reinforce and consolidate links between groups in Russia and the United States. Russian organized crime figures are also sent to this country to perform a service such as a gangland murder or extortion.

According to law enforcement sources, Vyatcheslav Ivankov ("Little Japanese") a Russian organized crime leader, was believed to have traveled to the United States to organize ROC groups in the U.S. and establish links to ROC groups in the former Soviet Union. Ivankov is considered to be a highranking organized crime leader, or thief in law, both in Russia and the U.S. Ivankov was arrested in Brooklyn, New York, on June 8, 1995, for trying to extort $3.5 million from a Wall Street investment firm.

Vyatcheslav Ivankov Some descriptions of the more publicized Russian organized crime groups in the United States are as follows:

According to law enforcement sources, there are approximately 300 former Soviet Union crime figures and associates in the San Francisco Bay Area, including San Jose. There are approximately 600 to 800 Russian crime figures and associates in the Los Angeles area, home to the second largest number of Russian immigrants in the United States. These figures include members of the Russian and Armenian organized crime groups.

Northern California Auto Theft Group - A Northern California auto theft group came to the attention of law enforcement personnel in Sacramento and other parts of Northern California, Oregon, and Washington State in early 1993. This group is primarily made up of blue collar type workers from the Ukraine and Western Russia. Specializing in auto theft and VIN switching, younger members of this group steal vehicles while the older members operate body shops. This group utilizes Interstate 5 to travel to Oregon and Washington to sell the stolen vehicle parts to other Ukrainian and Russian criminals. Additionally, this group is becoming involved in extortion, cellular telephone fraud, prostitution, and trafficking small amounts of narcotics. Group members have been known to carry weapons and are becoming increasingly violent.

This group does not appear to have any clear cut, well defined structure, though its members appear to have formed networks and cooperate with each other in their criminal endeavors.

Odessa Mafia - The Odessa Mafia is considered the dominant Russian organized crime group in the United States. This group established itself in the Brighton Beach area of New York City between 1975 to 1981. In the early 1980s the Odessa Mafia sent two sub-groups to San Francisco and Los Angeles with their leadership remaining in Brighton Beach. The San Francisco Bay Area Odessa Mafia group, unlike their southern counterpart, appear to be highly structured and well organized.

Secrecy surrounds their activities and the language barrier creates additional problems for law enforcement authorities. This has resulted in very liftle information concerning the hierarchy, the scope of their operations, and the number of members. This crime group is believed to be involved in extortion, money laundering, fraud, loan sharking, and homicide.

Armenian Organized Crime Groups - The Hollywood area of Los Angeles and the city of Glendale are the focal points for Armenian organized crime activity. This area has the largest Armenian population outside of the Republic of Armenia.

According to law enforcement sources, several Armenian organized crime groups are becoming well organized with a structured hierarchy. There are in excess of 450 members and associates of these groups. These crime groups are involved in extortion, fuel frauds, credit card fraud, murder, kidnap, and narcotics trafficking. One group is believed to have approximately 150-200 members. Several members of this organized crime group were convicted in 1994 in Los Angeles of attempted murder, kidnaping, and extortion. This group is believed to be responsible for extorting a number of victims in the Armenian community.

Russian organized crime in California is involved in extortion, narcotics, murder, auto theft, and loan sharking, as well as insurance, fuel, telecommunication, and credit card frauds. The following cases are examples of several different crime categories.

Extortion - Five members of an Armenian organized crime group in Los Angeles were convicted in 1994 for extortion, kidnaping, and attempted murder. They forcibly detained and threatened victims and their families with great bodily harm unless they paid the suspects money. This group is believed to have extorted the Armenian community in the Los Angeles area for the last 13 years.

Fuel Frauds - Fuel frauds, mostly in Los Angeles and New York, cost both the federal and state governments approximately $2 billion annually in tax revenue. The majority of the fuel frauds are committed by Russian and Armenian organized crime groups operating in Southern California. There are a variety of schemes involving the fuel fraud including falsifying state and federal tax forms, use of fictitious companies, known as a "burn" company, extending fuel by blending tax free additives such as transmix or alcohol, rigging fuel pumps, manipulating dyed fuels designated for off-road purposes, and selling lower grade fuel as a premium product.

The "daisy chain" scheme is the predominate method of fuel tax fraud. The daisy chain scheme starts with a string of companies created by Russian and Armenian organized crime groups and is designed to create a massive paper trail. In the daisy chain, a "burn" company is created and exists only on paper. By the time auditors and investigators unravel the series of transactions to determine the tax liability, the "burn" company has disappeared without a trace of records or assets. These groups are pocketing up to 50 cents per gallon in federal and state taxes which enables them to sell the petroleum products below cost. Selling fuel below cost forces the legitimate operators out of business. Often these groups force legitimate businesses out of business using intimidation tactics through kidnaping, assaults, and bombings.

On September 13, 1995, 13 Russian Armenian subjects were arrested and charged with racketeering, including multiple acts of mail and wire fraud, money laundering, extortion, and distribution of heroin and other narcotic controlled substances. The Russian Armenian group, called the Mikaelian Organization, after the group's leader and self professed "godfather" of the Russian Mafia, Hovsep Mikaelian, ran a black market diesel fuel network that supplied gas stations and truck stops throughout Southern California. They defrauded the Internal Revenue Service and the California Board of Equalization through various fraudulent schemes, by purchasing millions of gallons of diesel fuel and avoiding a huge tax liability.

The Mikaelian Organization used wholesale permits obtained fraudulently to purchase tax-free diesel fuel that was intended to be used solely for off-road purposes such as farming and construction. The fuel was then diverted and sold at numerous independent diesel fuel stations, several of which were controlled by this organization. Up to 42 cents per gallon of the federal and state tax collected at the time of sale was pocketed by this organized crime group.

This group was also involved in gaining control, through threats and extortion, of a large segment of the independent diesel fuel wholesale and retail service station and truck stop markets. Permits were also obtained by submitting fraudulent paperwork. In some cases, jet fuel, which can be purchased tax free, was added to the diesel fuel and sold at the service stations and truck stops.

According to the U.S. Aftorney in Los Angeles, this group managed to avoid paying $3.6 million in taxes in just one year. The arrests culminated a two-year joint task force investigation conducted by the Federal Bureau of Investigation, the Internal Revenue Service, the Los Angeles Police Department, the Long Beach Police Department, the California Department of Justice, the Department of Defense, and the Department of Transportation. The task force confiscated more than $2 million in cash and property, including a BMW, Jaguar, and two Rolls Royces.

In order to counter the diesel tax frauds, Senate Bill 840, introduced by former Senator Robert Presley and former Assembly member Johan Klehs, was passed into law and took effect July 1, 1995. The purpose of the new law, which now parallels federal law, is to reduce diesel fuel frauds by imposing tax collection at a higher point (terminal level) in the distribution chain. Under the new law, taxes will be collected on tax exempt fuel by the terminal operator and refunded by the state (tax refund). A terminal is defined as a storage facility where fuel is stored and delivered to buyers. Fuel is delivered to the terminal directly from the refinery which is the first level in the distribution chain.

Telecommunications Fraud - Russian crime figures in the Los Angeles area are extensively involved in telecommunications fraud (cloned cellular phones). Law enforcement sources indicate that the activity is spreading to Northern California. This illegal process involves stealing electronic serial numbers of customers' cellular phones and programming them into computer chips, thus making a duplicate or clone of the telephones. While cloning has been going on for some time, it has grown rapidly and become more sophisticated as the industry has expanded. One cellular station in the Hollywood area is losing approximately $2 million a month in fraudulent calls made on cloned cellular telephones. Armenian organized crime figures are believed to be responsible for the majority of this fraudulent activity.

Narcotics - ROC groups are not extensively involved in narcotics distribution in California. However, there have been significant events and cases that indicate a possible future trend in this area.

On March 4, 1993, a Russian emigre was arrested for pefty theft. The Burbank Police Department recovered two kilos of cocaine and $2,200 in cash from the emigre's vehicle. It was later learned the emigre was also involved in shipping stolen vehicles to Russia.

On May 1, 1993, a Russian emigre was arrested for immigration violations. Information from the Immigration and Naturalization Service indicates that the emigre was involved in smuggling cocaine from the U.S. to Russia through his import/export business in Southern California. This emigre had spent 13 years in a Russian prison.

In February 1995, Tracey Hill, believed to be a courier for a ROC group, was arrested in Redding, California, for possession of 18 kilos of cocaine. Hill was en route to Vancouver, B.C., from the Los Angeles area.

On May 4, 1995, seven kilos of heroin was seized from a member of an Armenian organized crime group based in the Glendale area. The heroin came from the Middle East and was intended for distribution in the United States.

Medical/insurance Fraud - In Los Angeles, Russian organized crime figures have been involved in various frauds that run the gamut from staged auto accidents to false billing schemes. In 1991, in a case considered the largest of its kind, the U.S. Aftorney's Office in Los Angeles charged 13 defendants in a $1 billion false medical billing scheme that was headed by two Russian emigre brothers, Michael and David Smushkevich. The Smushkevich brothers have long been suspected of being part of a loosely organized Soviet crime syndicate operating in the Los Angeles area during the late 1980s and early 1990S. .14 The 175 count indictment capped a six-year investigation by federal, state, and local agencies.

Authorities reported that the brothers orchestrated a massive fraud scheme to use mobile medical laboratories to conduct unnecessary and false tests on patients. They then sent inflated and false bills to insurance companies and collected large fees. The scam eventually spread to Missouri, Illinois, and Florida. On September 20, 1994, the alleged ringleader, Michael Smushkevich was sentenced to 21 years in prison for fraud, conspiracy, racketeering, and money laundering. Smushkevich was also ordered to forfeit $50 million in assets, pay more than $41 million in restitution to government agencies and insurance companies victimized by the scheme, and pay a $2.75 million fine. David Smushkevich testified for the prosecution and received probation. It is estimated that the Smushkevich brothers pocketed between $50 and $80 million in profits. It is believed the brothers hid their money in an unknown country.

Loan Sharking - In October 1991, two Russian organized crime figures were convicted in Los Angeles of extorting a Russian emigre businessman. The two Russian organized crime figures lent money to the victim at a 30 percent interest rate. The victim borrowed $125,000 and over eight years had paid back $480,000 but still owed $120,000. The suspects threatened the victim and his family if they didn't pay the rest of the money that was owed.

Auto Theft - The Northern California auto theft group specializes in auto theft and operates in Sacramento, other parts of Northern California, Oregon and Washington. Younger members of this group steal vehicles while the older members operate body shops. The body shops are used as chop shops where stolen auto parts are used to reconstruct vehicles bought from salvage pools. Vehicles are also stolen, surgically stripped, and the hulls dumped where they are easily found by law enforcement personnel. These vehicles end up at salvage yards where members of this auto theft group buy the surgically stripped hull and ultimately put the vehicle back together at the chop shops. Vehicles are also bought at the salvage pools for their VIN numbers. The VIN numbers are switched to stolen vehicles.

The vehicles are then taken out of state and re-registered in an attempt to conceal or clear the salvaged title. Many of the stolen vehicles are believed to be shipped out of the country through Seattle, Oakland, and other port cities. This crime group may be using Russian organized crime groups to ship the vehicles to Europe or Russia where they are sold for substantial profits.

Murder - Andrey Kuznetsov and an associate, Vladimir Litvinenko, were shot to death in Kuznetsov's rented house in West Hollywood on January 26, 1992. Kuznetsov was believed to have been the leader of a Los Angeles fraud ring with ties to Russian organized crime in New York and Russia. His widow claimed he introduced her to Russian organized crime leaders and members in Los Angeles and New York.

Los Angeles Sheriffs Deputies arrested two Russian emigres at the murder scene. Sergei Ivanov was drenched in blood and carrying a handgun. An accomplice, Alexander Nikolaev, was also arrested with Ivanov. Sheriffs deputies found the two suspects in the act of cufting off the victims' fingers to hinder identification. Found in the house along with the bodies were numerous boxes of electronic equipment, copiers, TV sets, fax machines, and stereo components. Authorities state most of the equipment was stolen or bought illegally through the use of fraudulent'credit cards and check kiting.

Money Laundering - Russian organized crime groups in the former Soviet Union are wire transferring huge amounts of money, ranging from several thousand to millions of dollars from bank accounts located in Finland, Cayman Islands, and Europe to U.S. banks.

The source of this money is believed to come from narcotics activity, illegal trade in arms and antiques, and prostitution. Money is also stolen from the Russian government. According to a Russian newspaper, upwards of 1.5 trillion rubles (worth in excess of $1 billion) were stolen from the state with forged documents in 1992 to 1993.

ROC groups launder the money through a elaborate trail of fictitious companies set up in Russia. The money is wire transferred to "tax haven" countries such as those in the Caribbean Islands. Money is also reportedly wire transferred to other countries in Europe, such as Switzerland and Finland. A substantial amount of this money is ending up in U.S. banks. Most of the wire transfer activity is occurring in California's larger cities such as San Francisco and Los Angeles. It is believed that once the money has been exchanged into U.S. dollars, some of the money is sent back to Russia and is invested in lucrative financial and industrial projects, real estate, enterprises, and banks.

The Russian emigres connected to the U.S. bank accounts are opening import/export businesses in the Los Angeles and San Francisco areas. These business may be set up for the sole purpose of shipping large amounts of U.S. dollars to and from Russia.

In New York, the LCN and Russian organized crime figures have formed working relationships in areas of fraudulent fuel tax schemes. The LCN is believed to have forced the Russians to pay tribute on the profits they made on these schemes.

There is no information indicating that the LCN is exacting tribute from Russian fuel tax fraud operations in California.

Colombian cocaine distributors are believed to have formed an alliance with organized crime groups in Russia to import large quantities of cocaine into that country. These ties became evident after a 1.1 metric ton shipment of cocaine was seized in St. Petersburg, Russia in February 1993.

Criminal intelligence reports indicate Russian organized crime groups are not extensively involved in narcotics distribution in California. However, the following significant case illustrates a possible future trend and the alliances that are forming.

On September 8, 1993, several Russian crime figures were arrested in St. Augustine, Florida for conspiracy and intent to import 800 kilos of cocaine. These subjects were attempting to establish a drug distribution route from Florida to Detroit and New York. It is believed groups of Russian organized crime figures in Los Angeles and New York were part of this operation. The Russian group was dealing with Costa Rican drug traffickers and had plans to smuggle a large quantity of cocaine from Colombia to Italy aboard a vessel. The Russian group was dealing with the Sicilian Mafia in this venture.

Although at the present time law enforcement authorities are not aware of any additional ties between Russian organized crime groups in California and other organized crime groups, it is probable that formalized alliances will occur in the future.

From the mid 1960's to the 1980's, approximately 35 million people were incarcerated in Soviet prisons. Approximately 28 to 30 million Russian inmates were tattooed. According to criminologist Arkady G. Bronnikov, who has studied taftoos of Russian prisoners for 30 years, inmates wore tattoos only after they had committed a crime. The more convictions a criminal received, and as the terms of incarceration became more severe, the more tattoos a convict would have.

Taftoos spell out lives of crime and establish the hierarchy of inmates. According to Bronnikov, at the top of the hierarchy are "pakhans" or organized crime bosses. The pakhans use the second level of the echelon known as the "authorities," (also known as enforcers, fighters, or soldiers) to carry out their orders. The "men" are the hard laborers and are the third level in the hierarchy. The lowest category are the "outcasts." These individuals are basically slaves to the upper levels of the echelon.

The tattoos present a picture of the inmate's criminal history. According to Bronnikov, "Tattoos are like a passport, a biography, a uniform with medals. They reflect the convict's interests, his outlook on life, his world view." A prisoner with an incorrect or unauthorized tattoo could be punished or killed by fellow inmates.

Law Enforcement agencies in California and the United States can expect to see more of these tattoos as the Russian criminal element surfaces. The tattoos may be of assistance in determining the subject's criminal background and activity.

Among the most significant organized crime groups to come to the aftention of law enforcement in California in recent years, are the Russian organized crime groups. These criminal organizations have the potential to become part of large international networks allowing them to launder money, smuggle goods, and narcotics, and import criminals to carry out specific crimes.

According to the U.S. Immigration and Naturalization Service, California is attracting the second largest number of Russian emigres settling in any state in this country. California is also experiencing a migration of Russian crime figures from the East Coast. This may be occurring because of the lack of strength the LCN has on the West Coast. The Russian organized crime groups would not have to pay a mob tax or tribute, thereby increasing their profits.

A comparison can be drawn between Russian immigration and that of previous emigrant groups who have become organized crime powers in the United States such as the La Cosa Nostra and Triads. These new Russian emigres will be a fertile source for recruitment by existing Russian organized crime groups. Many of these groups are still in an embryonic stage such as the Northern California auto theft group. However, as immigration increases, these Russian crime groups can be expected to expand and new groups will be established.

Russian organized crime groups in the United States and Russia have formed alliances with the La Cosa Nostra, the Colombian cocaine cartels, and the Sicilian Mafia. These alliances allow these groups to potentially become a dominant wholesale cocaine and heroin distribution factor in California.

As Russian organized crime continues to expand in California, it is probable they will form working relationships with other criminal groups such as the LCN, white collar criminals, or other non-traditional organized crime groups.

Because of their experience at "working the system" in the former Soviet Union, Russian organized crime groups can be expected to continue their involvement in sophisticated criminal schemes, such as fuel and insurance frauds in the United States. Russian organized crime groups specialize in targets of opportunity and take advantage of bureaucratic mazes to build their profit base. They bring with them knowledge and methods to operate complicated fraud schemes which allow these white collar criminals to flourish. While public and law enforcement attention is drawn to gangs and street violence, Russian organized crime groups will make inroads into California using these complex criminal schemes requiring extensive investigative efforts.

Law enforcement sources directly involved in the investigation of fuel frauds indicate that SB 840 will not eliminate the fraudulent schemes. Russian and Armenian organized crime groups will continue to defraud state and federal governments out of excise fuel taxes by coming up with elaborate refund schemes. It is believed that these groups will pool their resources to purchase their own terminals. Once in possession of a terminal and using falsified federal and state tax exemption forms the criminal groups can hide the true ownership of the fuel. They will continue to blend fuels, under-report volume of fuel sold, improperly dispose and store hazardous waste, and sell lower grades of fuel as a premium product. Legitimate terminal operators may be bribed or even threatened into accepting fraudulent state and federal tax exemption forms.

These criminal groups will import tax exempt fuels from other states or Mexico. Fuel will be exported out of state. Once exported out of state, the tax liability will be extremely difficult to track.

These groups discriminately use violence to intimidate competing fuel distributors to force them out of business or sell their business to the criminal groups at reduced prices. These frauds also allow the criminal groups to sell fuel below market price which forces the legitimate operator out of business or into illegal activity to maintain their livelihoods.

Members of Russian organized crime groups are violent but violence is usually employed for specific reasons such as eliminating competition and informants or punishing those who abscond with funds. They are much like the LCN and not like street gangs who use indiscriminate violence. Additionally, law enforcement authorities in California have had several confrontations with crime figures from the former Soviet Union. These crime figures are not afraid of American law enforcement or the criminal justice system and pose a potential threat to police officers.

According to law enforcement sources, drug trafficking has not yet become a major focus for Russian organized crime groups in this state. Given the profits to be made and the experience many of these groups have with drugs in the former Soviet Union, it is highly probable that this will become a growing part of their illicit operations in California. Law enforcement agencies in California have begun to make some inroads against Russian organized crime. However, more information and resources are needed to determine the scope of their criminal operations, the structure and size of their organizations, intra and interstate networks, and their international ties to organized crime in Russia.

Because there is a lack of intelligence data relating to Russian organized crime groups and their structure in this country, it is almost impossible at the present time to determine their magnitude or scope of operations. Based upon this lack of information, it is difficult to develop efficient strategies to counter them.

The law enforcement community needs to work together in order to combat this new threat. In California efforts to combat Russian organized crime are underway. Three law enforcement groups meet routinely to share criminal intelligence and information on these organized crime groups.

"Mobsters Threaten the World's Nuke Safety CIA Chief Says." Boston Globe, April 1994.

Myer, Joseph, "Glasnost Gangsters in Los Angeles." Los Angeles Times, April 10, 1992.

Raab, Sylvian. "Top Echelon of Mobsters Pose Threat." New York Times, August 23,1994.

FBI Tracked Alleged Russian Mob Ties of Giuliani Campaign Supporter

By Knut Royce / The Center for Public Integrity

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WASHINGTON, December 14, 1999 — The Center for Public Integrity is investigating how billions of dollars of allegedly corrupted money from the former Soviet Union have found a haven in the United States, despite strict anti-laundering laws. Last month, the Center reported how a small San Francisco bank became a conduit for questionable funds as it, like many other banks around the country, aggressively pursued the cash from the former Soviet Bloc.

Today the Center reports on how political campaigns, also aggressively chasing after cash, end up with equally questionable contributions as suspected Russian organized crime figures seek to move into the U.S. political mainstream In future articles, the Center will show how the failure to sift the good money from bad is being replayed all over America.

A prominent commodities trader who acknowledges a business history with a reputed Soviet Bloc crime figure and a notorious arms dealer has been one of New York Mayor Rudy Giuliani's top campaign supporters. Giuliani is expected to be the Republican candidate next year for a U.S. Senate seat from New York (as of Dec 14, 1999).

Commodities trader Semyon (Sam) Kislin and his family also lavished thousands of dollars in contributions to Democratic Sen. Charles Schumer, to the Clinton-Gore re-election campaign, to former Republican Sen. Alfonse D'Amato and to a number of state and city politicians. Kislin sits on the New York City Economic Development Board.

Kislin is not alone among emigres from the former Soviet Union who have successfully established themselves in the United States while law enforcement agencies, particularly the FBI, track their alleged associations with organized crime.

The Center for Public Integrity has obtained confidential law enforcement documents detailing the activities of dozens of the emigres, but authorities rarely make cases and still less share the intelligence outside their departments.

A 1996 Interpol report claims that Kislin's firm, Trans Commodities, Inc., was used by two reputed mobsters from Uzbekistan, Lev and Mikhail Chernoy, for fraud and embezzlement. And a confidential 1994 FBI intelligence report on the Brooklyn, N.Y., mob organization headed by Vyacheslav Ivankov, the imprisoned godfather of Russian organized crime in the United States, lists Kislin as a "member/associate" of Ivankov's gang. It claims that his company co-sponsored a Russian crime boss and contract killer for a U.S. visa and asserts that he was a "close associate" of the late notorious arms smuggler Babeck Seroush, who later settled in Russia.

In a telephone interview on Dec. 17, Kislin confirmed he had employed Mikhail Chernoy at Trans Commodities, but said he didn't know Ivankov. "I never met this guy; I never saw him in my life," he said. He said that someone had forged his signature to obtain the hit man's visa. And, he confirmed, "I used to do business with Babeck Seroush."

Giuliani's prospective Democratic opponent, first lady Hillary Rodham Clinton, returned a $1,000 contribution several weeks ago after the newsmagazine U.S. News & World Report disclosed it had been given by the wife of one of Bulgaria's alleged top racketeers, Ilia Pavlov, who lives in the United States.

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Amount
Source of Funds

Kathleen Brown $25,000 Golden ADA contribution to gubernatorial campaign

Alan Hevesi $11,000 Sam, David and Henry Kislin

Rudolph Giuliani $14,250 Semyon and Ludmila Kislin, direct contributions, 1994 and 1997. Kislin hosted a fund-raiser for Giuliani at a Brooklyn restaurant: amount raised unknown.

Rudolph Giuliani $1,000 Arik Kislin, 1995.

Jules Polenetsky $7,700 Kislin contribution when Polenetsky ran

New York Liberal Party $30,000 Kislin donation during Giuliani mayoral campaign on that ticket.

Clinton-Gore $2,000 Semyon and Ludmila Kislin, primary committee 1995.

Hillary Clinton $1,000 Wife of an alleged Bulgarian top racketeer, Ilia Pavlov. The money was subsequently returned.

National Republican Congressional Committee $2,750 Jacob Bogatin, president of YBM Magnex, donations in 1996 and 19997.

Charles Schumer $8,000 Sam, Ludmila, son David and daughter Regina, $2,000 each, 1998.

Former Sen. Alfonse D'Amato $1,000 Sam Kislin

Bob Dole $250 Ludmila Kislin

Sources: Federal Election Commission, New York Campaign Finance Board, Guiliani campaign and news reports

33 posted on 12/20/2005 12:07:35 PM EST by Liz

http://www.freerepublic.com/focus/f-news/1379128/posts
Chasing the death dividend

When the U.S. Coast Guard raided a Russian fishing vessel on the Pacific Ocean in 2001, investigators hit a jackpot: more than 12 tons of chalky powder hidden beneath a mountain of frozen squid, the largest haul of cocaine ever intercepted at sea.

At the time, they had no idea they also had tapped in to what federal authorities call another massive deception.

Agents tracing the source of the cocaine and probing possible money laundering eventually seized files that led deep into one of the financial industry's darkest corners: investing in the life spans of old or dying people, transactions known as viaticals.

Based on those records, federal authorities are investigating Mutual Benefits Corp. of Florida and filed a civil complaint two months ago that the Ft. Lauderdale-based viatical seller made false promises of extraordinary profit as it reeled in $1billion from 29,000 investors.

But a Tribune investigation found that Mutual Benefits is just one example of alleged deception in the rapidly growing viatical industry, a loosely regulated, often-misunderstood world that is riddled with fraud.

Dozens of companies selling viaticals maintain stellar regulatory records and have been consistently profitable. But since 1998, more than 100 companies have run afoul of state laws and regulations, records show.

The Tribune reviewed thousands of court files, analyzed government enforcement records from across the country and studied 400 current and defunct companies, piecing together a troubling portrait of an evolving industry.

In a viatical transaction, a person with, for example, a $100,000 life insurance policy might sell it for $50,000--though that figure could be lower or higher--and the investor is entitled to the full amount, minus commissions. The cold calculus is inescapable: The quicker the original policyholder dies, the better the investment.

But those profits often have proved elusive, while the industry has proved resistant to reform.

The Tribune investigation found that:

- Despite the industry's problems, a dozen states have failed to adopt laws restricting viatical businesses. Two dozen other states, including Illinois, rely only on vague regulations that serve to provide haven to troubled companies. Mutual Benefits was banned from doing business in five states but continued to operate in Florida--and in Illinois.

- Since 1995, at least 56 industry executives have been convicted of felonies for activities ranging from elaborate pyramid schemes--companies selling non-existent policies--to recruiting terminally ill patients to apply for multiple policies without disclosing their conditions, state and federal court records show.

- At least half a dozen doctors have been accused of manipulating medical diagnoses in attempts to assure investors that policyholders were near death. In most cases, these doctors delivered life expectancies without consulting with patients or their doctors.

- Companies commonly ply investors with complex contracts that downplay financial risks and obscure key disclosures, more than a dozen state investigations found. Behind advertisements guaranteeing safe and secure investments is the reality that investors may be responsible for premiums if the policyholder lives beyond life expectancy. Over time, that means investors could lose part of their principal.

"This is not a certificate of deposit," said William Scott Paige, the Florida founder of Wm. Paige & Associates, one of the country's oldest viatical companies. "No one can ever accurately predict life expectancy. They can make estimates and projections. But that's all they are."

Viaticals, which got their name from a Latin word meaning "provisions for a long journey," have gained in popularity in the past decade. When executed honestly, the deals can benefit everyone involved.

Policyholders gain a tax-free influx of cash that can be used to feather their last days in comfort, from dream vacations to new medicines.

Investors can receive rates of return double or triple that of safer investments, such as certificates of deposit or mutual funds. And the companies and brokers typically profit by taking a commission out of the money investors pay.

Eager to shed its image of shady deals, the industry now refers to its wares as life settlements. And instead of focusing on terminally ill policyholders, companies have expanded their reach to include most any older person.

But that has not been enough to reform the industry.

"We are very vulnerable to fraud and bad players," said Doug Head, director of the Viatical and Life Settlement Association of America, an Orlando-based trade group. "States don't know how to grapple with us. We are in deep need of standards."

Lawyers for Mutual Benefits say the company ran into problems not because of fraudulent business tactics or low standards in the industry but because regulators were overaggressive, which led to the raid on the company's offices.

"It's not a Ponzi scheme," said Jon Sale, a Miami attorney representing one of the company's officers. "Evidence will show that there's $200 million in escrow to pay [insurance] premiums with, which the company was not required to do."

He also disputed the Securities and Exchange Commission's claim that phony life-expectancy estimates were given to investors before they purchased a policy.

"Of course there are a lot of fraudulent viatical companies," Sale said. "But this isn't one of them."

AIDS afforded opportunities

Viatical companies grew quickly in the 1980s as the AIDS crisis presented an opportunity to buy large numbers of policies from dying patients. Mutual Benefits was founded later, in 1994, but still focused on AIDS patients and rapidly expanded to be one of the nation's largest buyers of benefits.

By the late 1990s, as medical advances prolonged the lives of many AIDS patients, payouts from Mutual Benefits' investments slowed down drastically. But the company didn't reveal this to future investors, according to SEC charges.

The company was formed in the mid-1990s by Leslie and Joel Steinger; their brother Steven, who goes by the last name Steiner; and Peter Lombardi, a family friend, according to a deposition from Steiner last month. All but Steiner have been named in the SEC civil complaint, though his consulting company was included.

The SEC's civil complaint accuses Mutual Benefits of improperly using investors' money. In response to the commission's request, a federal judge froze the company's assets and put it in receivership. The Florida Office of Statewide Prosecution has filed criminal charges of racketeering and investment fraud, while the state's Department of Insurance has suspended the company's viatical license.

The SEC in its complaint questioned the legitimacy of nearly $26 million paid by Mutual Benefits to an array of consulting firms connected to the brothers and Lombardi.

Les Steinger's Rainy Consulting Group received $9 million over four years, while Lombardi's PJL Consulting Inc. got $8.3million, Joel Steinger's Kensington Management Inc. was paid $6.3 million, and Steiner's SKS Consulting took in $2.3million, according to court documents.

Accurately predicting life expectancy is the linchpin of the viatical and life settlement industry. But because the process can be shrouded in secrecy, this calculation often has been the first point of deception.

The life-expectancy factor

George and Rose Bonomo of Plainfield, southwest of Chicago, reviewed the medical analysis provided by Mutual Benefits before investing $100,000 in 1996 on the insurance policies of two HIV-positive men.

They received a letter signed by Dr. Clark Mitchell affirming that the first man was expected to die within a year and the second within three years. The Bonomos are suing Mutual Benefits. Their Chicago attorney, Rick Schoenfield, provided an account of what happened to them.

The medical letters, which are meant to assure investors that life expectancy has been gauged by an independent, comprehensive medical review, held great weight for the Bonomos, Schoenfield said.

In the Bonomos' case, each AIDS patient received a discounted payoff, about 70 percent of their policies' face value, and Mutual Benefits received a commission. If both men died as expected, the Bonomos expected to receive just under a 30 percent return on their investment.

In the late 1980s, an AIDS diagnosis often meant death was swift and certain. By the late '90s, however, medical advances stunted many cases, and viatical companies were put on shaky ground.

Many companies' portfolios crashed because too many patients lived too far beyond expectations, state bankruptcy records show.

In some cases, doctors admitted, they earned fat fees as long as their life-expectancy estimates did not spoil the investment potential of a policy.

This year, as the Bonomos waited for the investment to pay off and couldn't get their phone calls returned, they grew suspicious. On April 30, they filed a civil claim against Mutual Benefits in U.S. District Court in Chicago.

Three days later, government agents seized control of the company, leveling a flurry of accusations, including that Mitchell and other doctors fabricated life expectancies.

With the company now in the grip of bankruptcy, they aren't sure they will collect anything, Schoenfield said.

Federal and state agents charge that Mutual Benefits masked the fact that 90 percent of policyholders, most of whom have AIDS, had lived substantially beyond life expectancy. Mutual Benefits' portfolio was not diversified to offset risks, court records show.

Doctors implicated

But the core problem, government investigators concluded in May, was that about 65 percent of policies purchased by Mutual Benefits were assigned life expectancies that were not based on "any meaningful review or confirmation by an independent physician." In their May complaint against Mutual Benefits, SEC investigators claim Mitchell was one of the culprits.

Mitchell's attorney did not return calls.

This was not the first time Mitchell's name had appeared on questionable medical diagnoses. In 2001, he was charged with 25 felony counts involving fraud based on allegations that he fabricated or manipulated life-expectancy records for Mutual Benefits. Information about the case is unavailable because the file has been sealed, according to court officials.

Government agents also detailed the actions of another physician, Edgar Escobar, who is accused of arbitrarily calculating estimates based on the wishes of Mutual Benefits founder Joel Steinger.

"Substantially all of the life expectancies purportedly assigned by Mitchell and Escobar were in fact determined by [Joel] Steinger," according to an SEC affidavit. The doctors often did not review medical records to confirm diagnosis or plot life expectancy. Instead, they issued "fraudulent life-expectancy figures that had already been designated by [Joel] Steinger."

A third doctor, Anthony LaMarca, was paid to verify life expectancies, according to court records. About 20 percent of his cases were adjusted to shorter time periods considered more acceptable to Joel Steinger, government investigators said in court filings.

In an interview, LaMarca disputed claims that 20 percent of his cases were adjusted, calling the figure closer to 3 percent.

"Those were revised because new medical information was brought to light," he said. LaMarca, who said he has cooperated with the SEC, said his medical reviews were not done on patients who had AIDS or were HIV-positive.

Mutual Benefits is only the most recent company stung by allegations of life-expectancy fraud. Nestled in the ocean resort town of Delray Beach, Fla., Dedicated Resources was one of the darlings of the industry until its sudden and unexpected collapse in 2001. The company blamed unforeseen medical advances for prolonging life spans. Disenchanted investors refused to pay extra premiums to keep the policies active.

Raking in millions

Court records provide a more detailed snapshot of a company that raked in multimillion-dollar salaries for founder Michael Zadoff and other family members, and show fat fees paid to an out-of-state doctor who estimated life expectancies after reading abbreviated medical files sent in overnight mail packets.

Dedicated Resources' medical review of patients consisted of a 30-minute examination of photocopied patient files by Dr. Lon Baratz in Rochester, N.Y., according to depositions filed in a Florida civil suit by disgruntled investors.

Baratz testified that he received $75 to $100 for each assessment. He rendered opinions without talking to the original physician or patient, according to his 2002 deposition in a pending civil case.

Patient files were bundled together by the dozens and shipped overnight to Baratz. Files never included copies of X-rays or other information that would have allowed an independent review. But photocopies of original doctors' medical charts were available, Baratz testified.

From 1993 to 1998, Baratz reviewed about 800 files and was paid about $70,000, according to his deposition in a recent civil case. Baratz was asked by attorneys representing investors to produce his records. Baratz said he shredded everything.

"It just made sense," he said.

Baratz did not respond to a request for an interview.

Viatical industry trade groups have long complained that their industry is unfairly tainted by the media. In 1999, Deborah Rhoades, then vice president of the National Viatical Association, told The Associated Press that fraud is not widespread.

Two years later, Rhoades was convicted in one of Ohio's largest viatical swindles. She had risen to become president of the now-defunct Washington, D.C.-based industry trade group.

Rhoades' case was linked to convictions of 17 other viatical executives, including fellow Ohioan J. Richard Jamieson. His company, Liberte Capital, defrauded more than 3,000 people of $100 million, court records show.

Once the owner of luxury cars and mansions, Jamieson was sentenced to 20 years in prison in December. He was ordered to repay about $92 million for the embezzlement and his role in coaching AIDS victims on how to lie to obtain policies.

Liberte Capital bought policies for pennies on the dollar. Investors were to be paid when the policyholders died. Because of this investigation, 85 insurance companies canceled most of the fraudulent policies. The insurance companies saved more than $25 million; investors lost everything.

The viatical industry's history is stamped by dozens of such fallen companies and executives. Michael Lee Davis founded his own viatical company after he was paroled from prison. He had been convicted in 1981 of murder for his role in a Houston murder-for-hire plot in which a husband, wife and son were killed for their insurance benefits.

Once Davis was freed, he again turned to life insurance to earn money. But he and his viatical company, First American Fidelity Corp., soon ran afoul of the law again.

In 2000, he was convicted of fraud for recruiting 20 people to lie about pre-existing medical conditions to obtain $5 million in policies. Davis used the falsely obtained policies to take money from investors, a Texas court found.

Policyholder scams

Scams in the industry also have involved the original policyholders.

Four years ago, more than 50 FBI and state agents poured into the Lexington, Ky., headquarters of Kelco Viatical and its subsidiary, Genesis Viatical, in an investigation dubbed Operation Clean Sheet.

To secure more policies, Kelco encouraged AIDS patients to get small life insurance policies that did not require medical tests. Kelco bought the policies and resold them to investors who were promised up to 30 percent returns, according to court records.

But the insurance companies learned of the fraud and canceled the policies, leaving investors with no hope of recovering their investments. The crime is known as clean sheeting because policyholders falsely claim their medical records are clean.

The FBI convicted 19 people of the scheme, including the company's top three executives. After being sentenced to 14 years in prison in 2003, Kelco founder Stephen Keller became a fugitive. He was tracked to Panama and arrested by U.S. marshals in February.

Government regulators have struggled to do something as simple as legally define viaticals and life settlements. What has emerged is a confusing latticework of regulations and legal opinions, allowing shady and nimble companies to easily hopscotch across state borders to avoid government investigators.

At the heart of the debate is whether a viatical or life settlement transaction should be regulated as an insurance product or as a security. The viatical industry describes itself as an alternative niche of the mainstream insurance industry, arguing it should fall under the authority of state insurance regulators, which generally are not as aggressive in pursuing fraud as federal agents.

The federal government believes the industry oversteps the traditional insurance market. The government argues that viaticals are clearly investments and should be governed as securities, which have strict federal regulations.

Renewed debate

The debate has been revived by the Mutual Benefits case. Lawyers for the company argued in court that federal securities law did not apply to the firm's deals.

On June 25, U.S. District Judge Federico Moreno sided with the SEC, finding that the investors in policy benefits offered by the company are putting money into a type of security. Mutual Benefits' attorneys immediately announced plans to file an appeal.

Moreno's ruling is at odds with a 1996 decision that resulted when the SEC filed a civil case against Texas-based Life Partners Inc. A federal appeals court sided with Life Partners' argument that it was fundamentally selling an insurance product.

The SEC's case against Mutual Benefits is widely seen as pivotal in the argument over how to regulate the industry. Should the SEC prevail, the federal precedent could be the spark to touch off new, specific state securities laws, said Tanya Solov, director of the Illinois Department of Securities.

Entangled with drug dealers

Mutual Benefits, which is in receivership, has been the focal point of more than a half-dozen Florida investigations in the past decade. But it took a federal investigation into drugs to uncover the business documents that led to the company's downfall.

Carl Villazon, a Florida deputy and forensic accountant on a task force attached to the U.S. Department of Homeland Security, helped raid Mutual Benefits offices in November 2002.

"Specifically, the investigation concerns allegations of laundering of narcotics proceeds through investment-grade viatical and life insurance policies," he wrote in an affidavit unsealed this year in U.S. District Court in Florida.

Since the high seas drug bust in 2001 aboard the Svesda Maru, agents have unearthed an elaborate criminal network of Mexican and Russian crime lords working in collusion with Colombian drug cartels. A trail of cash led to Mutual Benefits, according to court records.

Six cartel members, including one who was a Mutual Benefits contractor, have been indicted for drug dealing and money laundering. Mutual Benefits is named but not charged. Company attorneys say they did not know the foreign-based investment money represented laundered drug proceeds.

In his affidavit, Villazon detailed how the federal task force turned over an array of files and computers to the SEC in March. Armed with the evidentiary windfall, the SEC and Florida regulators took action. Many of the records seized from company files in 2002 were filed in court this year, stripping away the facade of a company on the brink of a financial abyss.

None of the executives or their attorneys would comment on the accusations.

Colombian success story

Court records reveal that Mutual Benefits marketed viaticals in Mexico and South America beginning in 2001. In Ecuador, for example, the company detailed plans to unleash 50 brokers, with the goal of grabbing an estimated $24 million from investors.

Their most successful contractor was in Colombia. Jaime Rey Albornoz, a globe-trotting broker, had the uncanny ability to rake in millions of dollars, as shown by company records submitted as exhibits in the SEC's pending case.

Albornoz was indicted last month as a drug cartel member along with four co-defendants, who are charged with moving millions of illegal drug dollars around the world and into Mutual Benefits investments, according to the federal indictment filed in U.S. District Court in Florida. Prosecutors allege that the cartel planned to profit not only from the legitimate investment results but from the commissions earned by Albornoz.

Co-defendant Rodrigo Jose Murillo also has been indicted in San Diego in connection with the drug seizure aboard the Svesda Maru.

Federal officials have not filed any drug-related charges against officers of Mutual Benefits. But they say their investigation shows that this is the first time suspected drug traffickers have used insurance investment companies as sanctuaries for dirty money.

Almost three years ago, Albornoz was buoyant as he recapped recent successes, including helping sell 1,000 policies valued at $25 million, according to company memos submitted as exhibits to the court.

"Using the words of a Colombian airline, `We must be doing something right,"' Albornoz wrote to Joel Steinger.

Albornoz detailed business meetings in Chile and Toronto, where he reportedly obtained tentative commitments from managers of large mutual and pension funds interested in funneling $100 million into investments.

"The potential is so big," he concluded, "that I do not think we are large enough to handle future demands."

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