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U.S. Department of Homeland Security
Office of Investigations
Benefit Fraud Unit - (Office)

r^itf/^ U.S. Immigration

and Customs
Benefit Fraud Referral '^^ Enforcement

Precedence: (Level 1/Level 2/Level 3) Date:

To: Call-Up Date:

(SAC Office Location)

Attention:
(Unit or Official who will receive BFR)

Approved By: (Name) Contact:

(Phone Number) (Contact Person)
Group Supervisor (Phone Number)
(Title)

Subject: (Category of Case)

Level 1 Benefit fraud organizations, facilitators and/or individuals who pose a

imminent threat to public safety and or national security

I J Mandatory case opening and reporting

Level 2 Benefit fraud organizations/Benefit fraud facilitators

( | With HQOI approval mandatory case opening and reporting

Level 3 Individual violators

I I With HQOI approval mandatory case opening and reporting

Page 1 of2

Lau I jifoi cement Sensilne

 L;i>* {• n t o t c c t m i H Sensitive

Files(s):

1. General BFU Number: (Generated Tracking Number)

2. Individual (Names / A-Number / TECS Number / DOB / COB / Alias)

Asset Forfeiture Interest: No (If yes, then please refer to SAC Asset Forfeiture Officer.)
Line Number: (Case Management per TECS II Sub-Categories for Immigration Cases)
Case Synopsis: (A brief explanation of the case, not to exceed a paragraph.)
Narrative Summary: (Background and details of the case to date; however, usually not to
exceed three or four pages. If the BFR is classified, each paragraph must be marked
appropriately.)
Actions Recommended: (Specific leads to be undertaken by the receiving office are set out
here. If the request is for action, e.g., arrest pursuant to warrant or known violations, that is also
to be set out here in specific detail. If there are caveats, or limitations upon action, those also
must be laid out in this section with sufficient detail to permit the receiving office to comprehend
those limits.)
Enclosure(s): (Provide only those enclosures necessary for the receiving office to adequately
perform the work requested.)

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Lnloi cement Sensitive

 Bureau of Immigration and Customs Enforcement
HQ/OI 50/5
Office of Investigations 42$lStrtaNW
Washington. DC 20S36

SEP - 5 2003

MEMORANDUM FOR SPECIAL AGENTS IN

FROM: John P. Clark

Director Investigation:

SUBJECT: Establishment of ICE Benefit Fraud Units

Effective September 12, 2003, a pilot project establishes ICE Benefit Fraud Units to support
the Bureau of Citizenship and Immigration Services' (BCIS) Service Centers in Vermont, Texas
and California. These units will be comprised of existing ICE resources currently assigned to the
Service Centers in addition to existing ICE investigative resources from the former Central, Eastern,
and Western Regional Offices of Investigations, to include the appropriate support staff. The
National Benefits Center (Missouri) and Nebraska Service Center will be addressed at a later time.
A list of affected positions is attached to this memorandum.

The ICE Benefit Fraud Units will:

1. work in conjunction with the BCIS' Fraud Detection Units (FDU) at the Service Centers;

2. be the primary recipients of allegations, leads and fraud trends referred by FDU;

3. review, evaluate, and prioritize fraud leads for Investigation action; and

4. in coordination with the respective SAC offices, forward cases to the SAC, for
appropriate follow up or work the case under the supervision of the SAC and in
coordination with ICE Headquarters.

An ICE Benefit Fraud Coordinator will be established in Dallas, Texas. The ICE Benefit
Fraud Unit Supervisors will report to the Benefit Fraud Coordinator in Dallas, Texas. The
Coordinator will report to the Director of the Identity and Benefits Fraud Unit, Division 3 at ICE
Headquarters. The attachment shows the personnel who will become part of the ICE Benefit Fraud
Units and the field chain of command.

Attachment (2)
ICE Benefit Fraud Units (Service Centers) Field Structure

NeH Jacobs
National Benefit Fraud Coordnator
Dallas, TX

Anthony Esposilo T Scon Robertson Paula Cofrigan

Group Supervisor. Western Group Supervisor, Central Group Supervisor, Eastern
Laguna Miguel, CA Dallas. TX Burlington. VT

Staff Staff
Staff Special Agents (4) Special Agents (7)
California Service Center
Special Agents <7) Program Staff (5) Program Staff (4)
Laguna Miguel. CA
Program Staff (6) S«6 Attached See Attached
Jimmie Ward
See Attached
Supervisory Special Agent

Texas Service Center

Vermont Service Center
Staff Dallas, TX
Wilttston. VT
Special Agents (3) Carmeto Ortiz
Jacqueline Moyer-PadiHa
Special Agent
Supervisory Special Agent
_L

Staff
Special Agents (2)
 Eastern Region

Name Tide/Program Code Grade

Paula Corrigan Supervisory Criminal Investigator, Program 1230 GS 181 1-14
William Embick Criminal Investigator (detailed to Glynco), Program 1 230 GS 181 1-13
ralrick Cannon Criminal Investigator, Program 1 230 GS 181 1-13
Lynn Hunt Criminal Investigator, Program 1230 GS 1811-13
Ccn Kem Criminal Investigator, Program 1 230 GS 181 1-13
Cevin Sibley Criminal Investigator, Program 1230 GS 1811-13
Stephen Munroe Criminal Investigator (overture), Program 1230 GS 1811-13
telly Leadbeatcr Vogram Analyst, Program 1 230 GS 0343-1 2
Paula Miller Investigative Assistant, Program 1230 GS 1802-7
Vacant Criminal Investigator (JTTF), Program 1230 GS 1811-14
Vacant Secretary, Program 1230 GS 031 8-6
Vacant Student Trainee. Program 1230 GS 0399-2/3/4

Vermont Service Center

Name Tide/Program Code Grade

Jacqueline Moycr-Padilla Operations Officer GS 1801-13
Ignore Macmillian Criminal Investigator GS 1811-12
lose E. Onega Criminal Investigator GS 1811-12

Central Region

Name Tide/Program Code Grade

T. Scott Robertson Supvy Criminal Investigator, Program 1 23 1 .000 GS 1811-14
Icflrey Barc/.ak Criminal Invcsdgator, Program 1234.000 (detailed to NSU) GS 181 1-1 3
Dwaync Peterson Acting Interim RD, Program 5230.000 GS 1801-15
Kenneth Fauble Program Analyst, Program 1231.000 GS 343-1 2
Carla Chandler Program Analyst, Program 1234.000 GS 343-11
Edward Tisdale Mgmt & Program Analyst, Program 1231.000 GS343-I2
Kathy Tillinjdia.sc Mgmt & Program Analyst, Program 1231.000 GS 343-1 2
Vickie Bates Program Admin Assistant, Program 1 234.000 GS 303-7
loci Baltic* Crim Inves (T-ProJ'lTF), Program 1230.000 GS 1811-13
Vacant (v/Lynn Coseiitine) Criminal Investigator, Program 1231.000 GS 1811-13
Vacant (v/Daron Mrkva) Criminal Investigator, Program 1231.000 GS 1811-13
Etarin Brckhus Stafl' Assistant to Deputy Regional Director/1221.000 GS 301-7

* Indicates position detailed to the local SAC office.

 Texas Service Center

Name Tide/Program Code Grade

Carmelo Ortiz Criminal Investigator GS 1811-12

Western Region

Name Title/Program Code Grade

Anthony Esposito Supervisory Criminal Investigator/ 123 1.000 GS 1811-14
Richard Burgess Criminal Investigator/ 1 23 1 .000 GS 1811-13
Ira Fleischer Criminal Investigator/ 1 23 1 .000 GS 1811-13
Fjrwin Martinez Criminal Investigator/ 123 1.000 GS 1811-13
Valerie Mincheff Criminal Investigator/1231.000 GS 1811-13
Sul-an Peebles Criminal Investigator/ 123 1.000 GS 1811-13
lames Pilkington Criminal Investigator/1 23 1.000 GS 1811-13
Mirjana Gajardo Management Assistant/ 1 23 1 .000 GS-7
Maryann Montalvo Program Analyst/ 1 23 1 .000 GS-12
Kenneth Takeda Assets Forfeiture Area Coordinator/ 123 1. 000 GS-13
Vacant Management Assistant/ 123 1.000 GS-7
Vacant Management Assistant/ 1 23 1 .000 GS-7
Vacant Criminal Investigator/ 1 23 1 .000 GS 1811-13
Rcnee Wolibrd Staff Assistant lo Deputy Regional Director/ 122 1. 000 GS 30 1-11

California Service Center

Name Tide/Program Code Grade

Jiuimic Ward Operations Otticer GS 1801-13
Michael V. Dunn Criminal Investigator GS 1811-12
Victor Ix-'y Criminal Investigator GS 181 1-12
Janies IJ. Schneider Criminal Investigator GS 1811-12
 Desk Officer Assignments (2/04) ;
SAC Primary Backup
Atlanta Fichou Gilmer
Dallas Fichou Gilmer
Denver Fichou Gilmer
El Paso Fichou Gilmer
Phoenix Fichou Gilmer
Seattle Fichou Gilmer
Tucson Fichou Gilmer
Los Angeles Gilmer Komosa
Miami Gilmer Komosa
New Orleans Gilmer Komosa
New York Gilmer Komosa
Newark Gilmer Komosa
Tampa Gilmer Komosa
Boston Komosa Trill
Buffalo Komosa Trill
Chicago Komosa Trill
DC Komosa Trill
San Juan Komosa Trill
St. Paul Komosa Trill
Baltimore Trill Fichou
Detroit Trill Fichou
Houston Trill Fichou
San Antonio Trill Fichou
San Diego Trill Fichou
San Francisco Trill Fichou

Identitv & Benefits Fraud Unit -HO Contact List

Interim Director Office Cell

Cynthia O'Connell (202)307-0651 (312)287-9865

Staffcrs/SrSAs/Detailees

Jean Yves Fichou 202 353 3287 408 640 8375

Doug Oilmer 202 305 8985 202409 1317
Liz Goyer 2026163722 202 528-5322
Cathy Komosa 2026163421 202 528-5342
Joe Ortega 202 305 3393 202498-9221
i ;™«i iWci™ "JO") ^07 fl4?4 70? 49S-9761
 REVISED CIS DRAFT- 10/1/03

CASE REFERRAL CRITERIA

Citizenship and Immigration Services (CIS) shall apply the following criteria when referring
cases to Immigration and Customs Enforcement (ICE) for investigation:1

I. BENEFIT FRAUD REFERRALS

> Level 1 - Preliminary Inquiry: CIS has determined that articulable fraud
indicators are present and that the case requires minimal ICE investigative
intervention before a proper adjudicative decision can be made. CIS will
request specific action, and explain its potential impact on the adjudication of
the related application and/or petition. CIS' primary objective is to validate or
invalidate fraud, and when fraud exists, get sufficient information in which to
deny the application or petition. This category of low-level investigative action
may include very basic observations, with no personal contact or confirmation
of public record information. ICE will have 30 days from the referral date to
complete the requested investigative action. If ICE is unable to accept the case
or complete the investigative action within 30 days, they will return the case to
their referring ICE-BFU, with a specific reason for an extension or declination.
After review, ICE-BFU will either forward the case to the referring CIS-FDU
with their findings, or return it to the field ICE office for investigative
purposes. ICE-BFU will advise CIS-FDU of any and all extensions. At no time
will an extension exceed 60 days, unless the initial investigative action raised
the level of the referral to Level 2 or 3. Cases that are returned without the
requested investigative action may warrant a compliance and verification-
related review by CIS, in an effort to obtain the information needed to make a
proper adjudicative decision.

> Level 2 - Limited Investigation: CIS has determined that articulable fraud
indicators are present and that the case requires ICE investigative intervention
before further administrative and/or prosecutorial action can occur. CIS will
request specific action, and explain the potential impact on the adjudication of
the related application and/or petition. CIS' primary objective is to validate or
invalidate fraud, and if fraud does exist, get sufficient information in which to
deny the application or petition. This category of mid-level investigation action
may include limited physical surveillance, interviewing witnesses and other
subjects (to possibly include sworn statements), obtaining information
pursuant to an administrative subpoena, etc. If ICE is unable to accept the case
or complete the investigative action within 60 days, they will return the case to

1 This caseload prioritization will enable ICE to engage its limited resources in a more efficient and effective
manner. Cases are referred to the applicable area ICE-Benefit Fraud Unit (BFU), via a CIS Fraud Detection Unit
(FDU).
 REVISED CIS DRAFT- 10/1/03
their referring ICE-BFU, with a specific reason for an extension or declination.
After review, ICE-BFU will either forward the case to referring CIS-FDU with
their findings, or return it to the field ICE office for investigative purposes.
ICE-BFU will advise CIS-FDU of any and all extensions. At no time will an
extension exceed 90 days, unless the initial investigative action raised the level
of the referral to Level 3. Cases that are returned without the requested
investigative action may warrant a compliance and verification-related review
by CIS, in an effort to obtain the information needed to make a proper
adjudicative decision.

> Level 3 - Full-field Investigation: CIS has identified fraud indicators

involving major conspiracies. These cases involve multiple
applications/petitions, and require full field criminal investigation.
Conspirators consist of repetitive petitioners, beneficiaries, and/or third parties
such as, organizations, attorneys, preparers, consultants, travel agents, notary
publics, schools, etc. Fraud schemes frequently result from intelligence
information, data mining and pattern analysis, established fraud indicators,
information shared between CIS and ICE, and/or leads provided by external
sources. CIS-FDUs will provide ICE a detailed analysis of their findings and
recommendations.

II. NATIONAL SECURITY REFERRALS

Cases involving foreign nationals suspected of being involved in terrorist or other
activities threatening national security.

III. PUBLIC SAFETY/INTEREST REFERRALS

Cases that pose a threat to public safety or contain elements of significant or
otherwise sensitive interest, to include:

• Mandatory Detention Cases

• Aggravated Felons
• Interpol Red Notices
• Re-entry Cases
• War Criminals
• Human Rights Violators