A Guide to Anti-Money Laundering for Crypto Firms

Scam Artist Launders Money Through Casino and Luxury Goods

Financial Crime Gaming & Gambling Knowledge & Training

Federal authorities in the US are hunting a scam artist who allegedly sold luxury vehicles online to car dealership owners who never received them, and laundered thousands of dollars through a Cincinnati casino.

Ismail Shalash sold vehicles to dealerships across the US, defrauding five victims in four states out of a total of $1.7m and attempting to defraud eight victims in five states out of a total of $3.4m.

According to the FBI, victims would try to contact Shalash (sometimes using the alias Armand Brigante of MDDI Inc) after waiting for the purchased vehicles to be delivered. But the vehicles never came, and the victims received no refund.

Authorities reviewing his bank account found that after receiving money from victims through wire transfers, Shalash would withdraw large amounts and cash them in at a casino. He would then launder the money by cashing out in credits.

The Hard Rock Casino Cincinnati’s Currency Transaction Reports (CTRs) reveal that between May 24th and August 24th, Shalash cashed in $464,796 and cashed out $789,541 – significantly more than he had deposited.

Documents also show patterns of suspicious activity in which Shalash’s casino account was used as a “conduit to transfer significant amounts of funds he received from victims through financial transaction channels”.

In September, a federal arrest warrant was issued for Shalash, who has dual Jordanian and Palestinian citizenship, after he was charged with wire fraud and money laundering. However, he had already moved to Morocco with his new wife Abir Mulawwah.

Shalash withdrew $500,000 in cashier’s checks before fleeing Cincinnati, while Mulawwah opened a safety deposit box at a bank in Houston, believed to be used to store Shalash’s illegally obtained funds.    

In November, FBI agents learned that Mulawwah was planning to return to the US and retrieve her safety deposit box. Arriving in Houston she went on a shopping spree, paying for items in cash.

“Mulawwah was planning to travel back to the United States frequently and slowly take cashback with her to Morocco,” documents read, adding that she planned to “purchase high dollar items in the United States and take them to Morocco to sell.”

A search of the safety deposit box found $300,000 in cash and Mulawwah was stopped from boarding a Turkish Airlines flight. FBI officials say that when interviewed, Mulawwah claimed she was no longer married to Shalash and had not been in contact with him since September. She was arrested and now faces charges of conspiracy to defraud the US, false statements, and money laundering. Shalash is still at large. 

Money laundering tactics

Despite the growing prevalence of illicit activity online, this case shows that cash continues to be a popular vehicle for money launderers. Compliance teams should look at the tactics employed by the money launderer here, including the use of casinos – which are a popular vehicle for criminal activity – spending on luxury goods that might not be easily detected, and the use of safety deposit boxes. 

The scope of the activity across multiple US states and countries is also notable, highlighting the importance of adverse media checks to help detect patterns that siloed transaction data may not, and the need to monitor high-risk individuals regularly. Screening online forums can be overlooked by compliance teams, but in a case such as this forums may have been used by victims to complain about Shalash’s activities. 

Financial institutions that are providing services to casinos and other high-risk venues should ensure that a comprehensive review of the business’ AML program is part of the onboarding process. Casinos themselves must also ensure they have conducted appropriate due diligence on customers accessing their services, whether in-person or online. 

In November, Bicycle Hotel & Casino in California found itself in trouble due to shortcomings in its AML program and failures to file SARs and CTRs for a foreign national who conducted millions of dollars in cash transactions at the casino in 2016. The casino was fined $500,000 and will submit to increased reviews of its AML program.

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Originally published December 2, 2021, updated December 2, 2021

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