Diplomatic Security Memorial: Ten U.S. Embassy Kabul Guards Killed in Truck Bomb #OTD #2017

 

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U.S. Embassy Honduras Cancels Routine Services For June 3-7 After Protesters Torch Access Gate

 

Protesters in Honduras set the access gate to the U.S. Embassy in Tegucigalpa on fire with tires doused with fuel according to Reuters. The report says that “the protesters chanted “American trash, American trash” outside the embassy, which was not being guarded at the time.”

CNN notes that “the fire was extinguished by mid-afternoon, and a State Department spokesperson later said no embassy personnel were injured in the incident.”

The U.S. Embassy was not being guarded at the time of the protest?

As of 1 am EST, we have not been able to find an official statement from Foggy Bottom. US Embassy Honduras CDA Heide Fulton did release a statement (see below) and announced the suspension of routine consular services for next week due to the fire damage.

USG Charges Two Individuals For Visa Fraud Conspiracy Involving the Moroccan Diplomatic Mission and Seven Domestic Workers

 

On March 13, SDNY announced that two individuals were charged for visa fraud conspiracy involving the Moroccan Consulate and Mission in New York. The complaint includes an individual not named as a defendant in the Complaint (“CC-1”), a diplomatic agent accredited to the Permanent Mission of the Kingdom of Morocco to the United Nations (the “Moroccan Mission”) with the rank of Ambassador. Footnote #5 in the complaint says that the USG anticipates that it will enter into a non-prosecutorial agreement with each of the seven domestic workers, all nationals of the Philippines). Footnote #6 notes that the DSS Special Agent is aware that as an ambassador accredited to the Moroccan Mission of the United Nations, CC-1 possesses full diplomatic immunity under Article V of the United Nations Agreement and Article (39)1)of the Vienna Convention on Diplomatic Relations.

Via USDOJ/SDNY:

Geoffrey S. Berman, the United States Attorney for the Southern District of New York, and Christian J. Schurman, Director of the U.S. Department of State’s Diplomatic Security Service (“DSS”) at the United States Department of State, announced today the arrest of MARIA LUISA ESTRELLA JAIDI (“JAIDI”), who was charged by complaint along with her brother, RAMON SINGSON ESTRELLA (“ESTRELLA”), for their involvement in a conspiracy to commit visa fraud, make materially false statements, and induce aliens to illegally come to, enter, and reside in the United States.  JAIDI was arrested today in Ancramdale, New York, and will be presented this afternoon in White Plains federal court before the U.S. Magistrate Judge Paul E. Davison.  ESTRELLA remains at large.

U.S. Attorney Geoffrey S. Berman stated:  “As alleged, the defendants abused our nation’s process for admitting consular officials in order to bring domestic workers into this country for their own monetary gain and lifestyle.  On top of that, Maria Luisa Estrella Jaidi exploited these workers by not providing them the critical protections and benefits they would have been entitled to had they been properly brought to this country with the appropriate visas.  Today’s charges demonstrate that fraud and abuse of this type will not be tolerated.”

DSS Director Christian J. Schurman said:  “DSS demonstrated its commitment to protecting the integrity of U.S. travel documents and the rights of foreign nationals visiting the United States.  We will continue to pursue those who abuse domestic worker visas to manipulate and exploit their employees for personal gain.  DSS’s strong relationship with our law enforcement partners and the U.S. Attorney’s Office for the Southern District of New York, continues to be essential in the pursuit of justice.”

According to the allegations in the Complaint unsealed in White Plains federal court[1]:

From approximately 2006 up to 2016, JAIDI and ESTRELLA conspired with an individual not named as a defendant in the Complaint (“CC-1”) to fraudulently procure visas for at least seven Filipino domestic workers (the “Domestic Workers”).  CC-1 is a diplomatic agent accredited to the Permanent Mission of the Kingdom of Morocco to the United Nations (the “Moroccan Mission”) with the rank of Ambassador.  From approximately 1980 through approximately 2016, CC-1 and JAIDI were married.

In order to fraudulently obtain visas for the Domestic Workers, JAIDI and CC-1 caused the Domestic Workers to submit visa applications containing materially false statements and to submit fraudulent employment contracts in support of those visa applications.  ESTRELLA – who is JAIDI’s brother and who resides in the Philippines – helped recruit several of the Domestic Workers in the Philippines to work for JAIDI and CC-1 in the United States and instructed the Domestic Workers to make false statements in their visa applications and to officials at the U.S. Embassy in Manila.

In particular, ESTRELLA, JAIDI, and CC-1 caused five of the Domestic Workers to falsely state in their visa applications that they would be employed as secretaries, administrative assistants, or technicians at the Moroccan Mission or at the Consulate General of the Kingdom of Morocco in Manhattan.  In addition, ESTRELLA, JAIDI, and CC-1 caused each of the Domestic Workers to submit fraudulent employment contracts to the State Department in support of their visa applications.  The fraudulent employment contracts also overstated the Domestic Workers’ salaries, understated their hours, and falsely guaranteed benefits, including, among others, sick leave, dental insurance, and medical insurance.

Once the Domestic Workers arrived in the United States, JAIDI and CC-1 employed the workers as their personal drivers, domestic helpers, farmhands, and assistants at their residence in Bronxville, New York, as well as at their farm in Ancramdale, New York.  JAIDI and CC-1 paid the Domestic Workers significantly less than the minimum salary required by law and regularly compelled them to work far in excess of 40 hours per week.  In addition, JAIDI and CC-1 generally denied the Domestic Workers the benefits set forth in their employment contracts, compelled the Domestic Workers to work seven days a week, and required the Domestic Workers to surrender their passports.

Read in full: Two Charged In White Plains Federal Court For Visa Fraud Conspiracy Involving Moroccan Consulate And Mission In New York

Attachment(s):

What happens after pay period #26?

Posted: 1:26 am EST

The State Department issued a thin Furlough Guidance Handbook to employees on January 4. It notes that State Department employees funded with no-year or multi-year accounts received their paychecks for pay period #25 on Thursday, January 3, 2019. Foreign Service annuitants received their December annuity payments on January 2, 2019 (Note that pension is not funded by annual Congressional appropriations but is drawn from the Foreign Service Retirement and Disability Fund). The Guidance says that State will also be able to make payroll for these employees for pay period #26 (actual pay date is January 17). What happens beyond that seems to be a big question mark beyond the nugget that CGFS will be issuing some future guidance.

Should the lapse in appropriations continue past the end of pay period 26 (January 5, 2019), the Bureau of the Comptroller and Global Financial Services (CGFS) intends to process payroll for pay period 26 to meet the Department’s Thursday, January 17, 2019 official pay date, for those individuals (both direct-hire employees and LE staff) who are funded using no-year or multi-year accounts that have residual balances. CGFS will be preparing and issuing T&A guidance for bureaus and posts for reporting time during any periods of lapse for pay period 26 and any later pay periods. Furloughed, excepted, and intermittent excepted employees who are not funded would not receive another pay check until there is legislation to permit payment.

01/04/19DS-5113 Agency Notice of Unemployment Compensation for Federal Employees
01/04/19SF-8 Unemployment Compensation for Federal Employees Program

We should note that a January 7 update to AFSA members flagged down a different date, which is this Friday, January 11:

In order to meet normal deadlines for processing payroll in time to meet the next payday on January 17, AFSA understands that funds need to be appropriated by Friday, January 11. The bill that funds operations at State and USAID passed the Senate Appropriations Committee in June by a 31-0 vote, but that bill has not yet gone before the full Senate. 
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If that does not happen by the end of the week, however, some members of the Foreign Service (including some members who have been required to report to work) may not receive a paycheck on January 17. As a first step to preparing for that difficult possibility, members are encouraged to read the new Furlough Handbook to review options for coping with the financial consequences of the partial government shutdown.

Consular Affairs

An update on our query about Consular Affairs funding — we’ve heard from a source that CA/EX recently sent a notice to consular sections informing folks that the bureau “anticipates” being able to continue paying its staff and providing consular services as long as the funding situation with partner bureaus/agencies allowed them to continue providing service that generates revenue. Here are a couple of dire scenarios that have a potential to impact thousands of working people and their families, and not just within the State Department. 

If partner agencies are not able to do their work due to the ongoing funding lapse, it could have a potential to derail consular services. Think DHS or  FBI.  Visa services require that applicant fingerprints, photo and personal data be sent to DHS for the purpose of checking the applicant’s fingerprint information against DHS databases and establishing a record within DHS’s Automated Biometric Identification (IDENT) system. Visa issuance data is then forwarded to DHS for use at US ports of entry to verify the validity of the visa. Visa services also require the  transmission of  applicant fingerprints and personal data to the FBI fingerprint system for the purpose of checking to determine if the person has a criminal record that would have an effect on visa eligibility. If DHS and FBI stop providing those clearances, embassies and consulates won’t be able to issue visas worldwide. And that would have a cascading impact on services, fees collected, and employees getting paid.  Also if/when visa issuances stop, there will be economic consequences for the tourism, travel and hospitality industries. What’s that going to do to the international travelers spending in the United States, or travel industry employment, both direct and indirect employment?

We should note that DHS’s Automated Biometric Identification System or IDENT, is operated and maintained by OBIM (IDENT currently holds more than 200 million unique identities and processes more than 300,000 biometric transactions per day). OBIM resides in DHS’s Management Directorate. During the lapse in appropriations, the Directorate estimates 193 employees as the total number exempt/excepted employees to be retained out of a total of 1,777 employees. So they have people working over there but for how long? How long can people work with no pay?

Additionally, DOJ’s 2019 Contingency Plan says that “all FBI agents and support personnel in the field are considered excepted from furlough.” It also says that “At FBI headquarters, the excepted personnel will provide direction and investigative support to all field operations and excepted headquarters functions. This includes personnel in the Criminal Justice Information Services Division, which provides fingerprint identification services to criminal and national security investigations, and the Records Management Division, which provides name check services to criminal and national security investigations.”

Regarding partner bureaus — consular operations do not stand alone at overseas posts. They are not able to operate without security guards, typically locally hired security guards. Local guards are not under consular sections but under the purview of Regional Security Officers. They are funded under the Bureau of Diplomatic Security within the Worldwide Security Protection, an account that the State Department previously identified as “initially have [ing] available balances”. We don’t know how much available balances DS has, but when that account is depleted, there won’t be money to pay the local guards, and posts cannot just use comp time or issue IOUs. And if there are no local guards to provide this critical function, posts won’t be able to open their consular sections to the public. That will have a cascading effect on services provided, fees collected, employees getting paid, and beyond. 

Also below, the State Department furlough Q&A includes the following;

On jobs during furlough: May I look for a job during the furlough if that is required to apply for unemployment compensation in my state?

A. A furloughed employee may seek employment without advanced authorization and can provide to the unemployment office any evidence that he or she is in fact seeking employment. Some States require claimants be engaged in an active search for work to be eligible for unemployment compensation. Department employees are reminded that relevant ethics laws, rules, and regulations continue to apply to them while in furlough status, including restrictions on outside employment with non-federal entities. For example, Department employees employed by a non-Federal entity during the furlough may later be restricted from participating in their official capacity in matters that affect that entity. If you have specific questions about your potential employment, you can contact EthicsAttorneyMailbox@state.gov.

For presidential appointees and covered noncareer employees (e.g., both noncareer SES and SFS and certain Schedule C employees), there are certain restrictions on outside earned income. Employees who file a Public Financial Disclosure Report (OGE 278e) must also file a recusal notice at negotiationnotice@state.gov when negotiating outside employment.

If you have more specific questions not covered above, you can contact negotiationnotice@state.gov.

Injury while on furlough: If employees are injured while on furlough or LWOP, are they eligible for workers’ compensation?

A. No, workers’ compensation is paid to employees only if they are injured while performing their duties. Employees on furlough or LWOP are not in a duty status.

Can somebody please ask the State Department what happens to employees in war zones and high threat posts who may be injured during this shutdown?

Mental Health Resources:

MED’s Employee Consultation Services (ECS) office remains open with reduced staffing during the furlough. You can reach ECS at 703-812-2257 or email MEDECS@state.gov.FEDERAL

Medical Evacuation:

New medical evacuations and ongoing medevacs are considered excepted activities and will continue during the furlough.

Employee Health Benefits and Life Insurance: Will I still have coverage under the Federal Employee Health Benefits (FEHB) program during the furlough?

A. Yes, the employee’s FEHB coverage will continue even if an agency does not make the premium payments on time. Since the employee will be in a non-pay status, the enrollee share of the FEHB premium will accumulate and be withheld from pay upon return to pay status.

For Federal Employee Group Life Insurance (FEGLI), coverage continues for 12 consecutive months in a nonpay status without cost to the employee (5 CFR 870.508(a)) or to the agency (5 CFR 870.404(c)). Please note that premium payments are required if an enrolled employee in nonpay status is receiving workers’ compensation (5 CRF 870.508(a)).

 

US Embassy Kinshasa Remains Closed to the Public For Sixth Day Over Terror Threat #DRC

 

On December 2, the US Embassy Kinshasa in the Democratic Republic of the Congo announced that it will be closed to the public again due to a terrorist threat against USG facilities in the capital city. Below is part of the announcement:

The U.S. Embassy in Kinshasa is working closely with the Government of the Democratic Republic of Congo to address a terrorist threat against USG facilities in Kinshasa.  The U.S. Embassy in Kinshasa will be closed to the public on Monday, December 3.

 Actions to Take:

·        Maintain a heightened level of vigilance and practice good situational awareness.

·         Monitor local media for updates.

·         Keep a low profile and notify friends and family of your safety.

·         Review the country page  and remain alert for potentially dangerous situations.

US Embassy Kinshasha previously “received credible and specific information of a possible terrorist threat against U.S. Government facilities in Kinshasa” on November 24, 2018. It initially closed to the public with only minimal staffing on Monday, November 26, 2018.

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Whistleblower Protection Memo – How Useless Are You, Really?

Back in July, we blogged that State/OIG cited a State Department’s revocation of an employee’s security clearance in retaliation for whistleblowing in its Semi-Annual Report to Congress for October 2017-March 2018. State/OIG recommended that the whistleblower’s security clearance be reinstated (see State/OIG Finds @StateDept Revoked Security Clearance in Retaliation For Whistleblowing).  Retaliatory revocation is not an unheard of practice but we believed this is the first time it’s been reported publicly to the Congress.

Also in July, there was a joint OIG-State memo noting that “Whistleblowers perform a critically important service to the Department of State and to the public when they disclose fraud, waste, and abuse. The Department is committed to protecting all personnel against reprisal for whistleblowing.  This summer OIG told us that Congress enacted a new provision in 2017 that requires an agency to suspend for at least 3 days a supervisor found to have engaged in a prohibited personnel practice, such as whistleblower retaliation, and to propose removal of a supervisor for the second prohibited personnel practice. (see @StateDept’s Retaliatory Security Clearance Revocation Now Punishable By [INSERT Three Guesses].

In September, we note the time lapse since the official report was made to the Congress and wondered what action the State Department took in this case.  If the State Department believes, as the memo states that “Whistleblowers perform a critically important service to the Department of State and to the public” we really wanted to know what the State Department has done to the official/officials responsible for this retaliatory security clearance revocation.

We also want to see how solid is that commitment in protecting personnel against reprisal — not in words, but action.  So we’ve asked the State Department the following questions:

1) Has the security clearance been reinstated for the affected employee, and if so, when?

2) Has the senior official who engaged in this prohibited personnel practice been suspended per congressional mandate, and if so, when and for how long? and

3) Has the State Department proposed a removal of any supervisor/s for engaging in this prohibited personnel practice now or in the past?

As you can imagine, our friends over there are busy swaggering and to-date have not found the time to write back.

Folks, it’s been eight months since that annual report went to the U.S. Congress. If you’re not going to penalize the official or officials who revoked an employee’s security clearance out of retaliation, you were just wasting the letters of the alphabet and toner in that darn paper writing out a whistleblower protection memo.

And the Congress should be rightly pissed.

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Is @StateDept Working to Minimize the Health Attacks in China? #Cuba #MissingARBs

Via  NBC News:

NBC News also reviewed hundreds of pages of medical records of U.S. government workers evacuated from both Cuba and China, including those the U.S. has “medically confirmed” were attacked and those it ultimately said were not.
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Most of the American diplomatic evacuees have improved enough to resume work, State Department officials said. Some have been granted accommodations, such as shortened work hours, dimmed office lights or special glasses. Meanwhile, the White House National Security Council is preparing legislation to deal with gaps that Workers’ Compensation doesn’t currently cover, such as care for affected spouses or pay-outs for permanent impairment of the brain.

In internal State Department instructions reviewed by NBC News, workers in Cuba and China were told not to discuss what they knew with the public, with reporters or on social media.
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In May, Pompeo called Werner’s case “entirely consistent” with the Cuba patients. But now top U.S. diplomats say they’re not sure it’s the same thing, with one telling the House Foreign Affairs Committee it’s “apples and oranges.”

And the State Department, in explaining why it’s not setting up a review board to assess the response in Cuba, told NBC News that Pompeo didn’t believe there was enough information to prove that Werner’s injury was “related to a U.S. government mission abroad.”

Somebody please set us straight here. Wasn’t there an ARB for the Cuba attack? Or was there an ARB Havana but no ARB Guangzhou? How did State made a determination that there wasn’t enough information  the injury was “related to a U.S. government mission abroad” without convening an Accountability Review Board? Did they use their Magic 8 crystal ball?

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Related posts:

@StateDept’s Aviation Program Down to Just 206 Aircraft, Also Spends $72M on Unnecessary Services

Per 2 FAM 800: INL/A serves as the Departments aviation service provider (with the exception of aircraft charters managed by A/LM/OPS for logistics support of nonrecurring and unpredictable requirements like oddly-sized shipments, evacuations and other emergency assistance to Posts) and is coordinator of all aviation related to AGB [Aviation Governing Board] approved acquisitions.  INL/A is responsible for complying with the provisions of this chapter as well as OMB Circulars A-126, A-76, A-11, and A-94 and Federal Management Regulation 10233. Additionally, as part of the Departments Management Control Plan (see 2 FAM 020), INL/A must establish cost-effective management control systems to ensure that aviation programs are managed effectively, efficiently, economically, and with integrity.

Excerpt below via State/OIG:  Audit of the Department of State’s Administration of its Aviation Program (Sept 2018).

The Department is not consistently administering its aviation program in accordance with Federal requirements or Department guidelines. Specifically, OIG found instances in which significant aviation operations were undertaken without the knowledge or approval of the AGB, which is required by Department policy. In addition, the AGB is not fulfilling its responsibilities to evaluate the usage and cost effectiveness of aircraft services, as required by Office of Management and Budget Circulars and Department guidance. Furthermore, INL administer ed country-specific aviation programs differently depending on whether a post used the worldwide aviation support services contract. As a result of limited AGB oversight and the absence of evaluations to determine the appropriate usage and cost effectiveness of the Department’s aircraft operations worldwide, the Department is not optimally managing aviation resources and spent $72 million on unnecessary services from September 2013 to August 2017.

Snapshot: The Department’s aviation program was created in 1976 to support narcotics interdiction and drug crop eradication programs. The aviation program has since grown to a fleet of 206 aircraft and aviation operations that extend from South America to Asia and include transportation services for chief of mission personnel. In 2016, the Government Accountability Office (GAO) reported that the Department owned more aircraft than any other non-military agency and was one of three agencies with the most “non-operational” aircraft. At the time of GAO’s analysis, the Department had 248 aircraft; the Department has since decreased that number to 206. As shown in Figure 1, as of January 2018, the aircraft inventory included airplanes (fixed-wing), helicopters (rotary-wing), and unmanned aircraft.

As of January 2018, the Department had aviation operating bases overseas in five countries —Colombia, Peru, Panama, Afghanistan, and Iraq —and a support base at Patrick Air Force Base located in Melbourne, FL. The Department closed aviation programs in Cyprus and Pakistan during 2017. The Department plans to re-open an operating base in Guatemala. In addition, the Department has two dedicated chartered aircraft located in Cartersville,GA, and Nairobi, Kenya.

The Department’s Aviation Governing Board (AGB) is responsible for providing oversight of aviation activities, including approving policies, budgets, and strategic plans. The AGB was established in 2011. It is chaired by the Assistant Secretary of the Bureau of International Narcotics and Law Enforcement Affairs (INL) and has three other voting members—the Assistant Secretaries (or designees) from the Bureaus of Diplomatic Security, South and Central Asian Affairs, and Near Eastern Affairs.

INL/A consists of approximately 60 Civil Service personnel and 13 personal services contractors. To carry out the Department’s aircraft operations, maintenance, and logistics for the country-specific aviation programs, INL/A administers and oversees a worldwide aviation support services contract that provides a contract workforce of more than 1,500 personnel. According to an INL/A official, starting November 1, 2017, DynCorp International began its fifth extension of a $4.9 billion worldwide aviation services contract.

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US Embassy Senegal Inaugurates New Regional Tactical Training Center

On September 6, the State Department and the Government of Senegal inaugurated a new regional counterterrorism training facility in Thiès, Senegal.

U.S. and Senegalese officials formally dedicated the new Regional Tactical Training Center, which was funded, constructed, and equipped through the Department of State’s Antiterrorism Assistance (ATA) program. The new center is ATA’s first regional training facility in West Africa.

Once fully operational, the training center, part of a pre-existing Senegalese training facility, will reportedly expand ATA’s capacity to train Senegalese and other West African partner nation law enforcement officers at this regional counterterrorism training hub. ATA will provide training in hard skills such as crisis response, explosive incident countermeasures, post-blast investigations, and rural border patrol operations.

Photo via US Embassy Dakar

Below via:

Senegal Regional Tactical Training Center

With the success and subsequent growth of its regional training program in Jordan, ATA determined there was an operational need and an opportunity in Senegal to develop a West African regional training center.

ATA conducted a site survey in March 2015 at the pre-existing Tactical Training Center in Zone 7 (CET-7) in Thiès, Senegal. In January 2018, officials from both nations laid the cornerstone to begin construction of the new facility.

The new construction combined with the tactical capabilities of the pre-existing facility provide a modern regional training hub capable of conducting up to four ATA training programs simultaneously and in a more cost-efficient manner.

The RTTC includes a 100-person-capacity conference room, two classrooms, and an adjacent 900-square-foot warehouse with a secured armory, storage and staging rooms, a workshop area, and office space. A modular shoot-house with movable and interchangeable walls, an observation catwalk, and roof is planned for completion by September 2019.

The location of the new training center at the CET-7 affords ATA the use of the pre-existing, on-site tactical training and life-support facilities, including a simulated urban village, pistol and rifle ranges, more than 25 kilometers of terrain for land navigation and tracking, and a demolition range.

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US Embassy Santo Domingo: Man Pleads Guilty to One Count of Bribery of a Public Official

On September 14, USDOJ announced that Luis Santos of New Jersey pleaded guilty to bribing a State Department employee.  Santos admitted to paying $2,381 to a U.S. Consular Adjudicator at the U.S. Embassy in Santo Domingo.

Bergen County, New Jersey, Man Admits Bribing State Department Employee

TRENTON, N.J. – A Bergen County, New Jersey, man today admitted giving a bribe to an employee of the U.S. Department of State, U.S. Attorney Craig Carpenito announced.

Luis Santos, 37, of Teaneck, New Jersey, pleaded guilty before U.S. District Judge Michael A. Shipp in Trenton federal court to an information charging him with one count of bribery of a public official.

According to documents filed in the case and statements made in court:

Santos paid $2,381 to a U.S. Consular Adjudicator in Santo Domingo, Dominican Republic, to favorably handle and review non-immigrant visas, which allowed individuals from the Dominican Republic to apply for entry into the United States.

The bribery charge carries a maximum potential penalty of 15 years in prison and a fine of up to $250,000. Sentencing is scheduled for Dec. 18, 2018.

U.S. Attorney Carpenito credited special agents of the U.S Department of State Diplomatic Security Service with the investigation leading to today’s guilty plea.

The government is represented by Assistant U.S. Attorney Karen D. Stringer of the U.S. Attorney’s Office, Special Prosecutions Division in Newark.

Defense counsel: Thomas Ambrosio Esq., Lyndhurst, New Jersey

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Based on court filings (PDF), a cooperating witness (“CW”) was employed by the State Department as a U.S Consular Adjudicator in Santo Domingo, Dominican Republic.

2. From on or about September 22, 2017 to on or about March 9, 2018, SANTOS contacted the CW via WhatsApp and solicited the CW to participate in a bribery and fraud scheme, whereby SANTOS would pay money to the CW in exchange for the CW favorably handling and adjudicating fraudulent NIVs.

3. Throughout in or about February 2018, SANTOS sent the CW, via WhatsApp messaging, the names and appointment confirmations for five NIV Applicants, all of whom had interviews scheduled with the U.S. Consulate in Santo Domingo in or about March 2018 ( collectively, the “March Applicants”). SANTOS offered to pay the CW $500 for each fraudulent NIV issued to one of the March Applicants.

4. On or about February 25, 2018, SANTOS and the CW met in Hoboken, New Jersey (the “Hoboken Meeting”). During that meeting, which was consensually recorded by law enforcement, SANTOS confirmed that the March Applicants would pay $1,000 each for their fraudulent NIVs, and that the money would be split three ways, with a portion going to the CW in exchange for the CW favorably reviewing and adjudicating the five NIVs.

5. Law enforcement arranged for the issuance of what appeared to be genuine visas for the March Applicants. Accordingly, when each of the March Applicants appeared for their respective interviews, they were informed that their applications had been approved.

6. On or about March 9, 2018, SANTOS caused a relative in the Dominican Republic to wire $2,380.95 ($2,500 less the transfer service processing fee) to the CW via a money transferring service in exchange for the approval of NIVs for the five March Applicants.

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