
276 Money Laundering: A Guide for Criminal Investigators, Third Edition
enterprise, the seizures in fraud cases were frequently larg-
er—sometimes staggeringly so. The Madoff case involved
tens of billions of dollars in alleged fraud. Perhaps one bil-
lion dollars of this money has been recovered.
The use of asset forfeiture to obtain restitution for fraud
victims wasn’t initially contemplated when Congress enacted
18 USC §981 to deal with money laundering forfeiture. That
changed with the addition of section (e) (6) in 2000 and
the passage of CAFRA. Now, the tool is available and the
Justice Department has policies and procedu ...