LAW ENFORCEMENT SENSITIVE — FOR OFFICIAL USE ONLY

Active Federal Enforcement Actions:
Hawala, Unlicensed Money Transmission, and
Related Financial Crimes in Minnesota

A Public Record Compilation for Law Enforcement
All Sources: Federal Indictments, DOJ Press Releases, Court Filings,
Congressional Letters, FinCEN Orders, and Media Reporting
Current as of March 2026

At a Glance

$9BEstimated Total MN
Social Services Fraud
$250M+Feeding Our Future
Fraud Alleged
$700MCash Flagged Leaving
MSP Airport (2024-2025)
98Total MN Fraud
Defendants Charged
79Feeding Our Future
Defendants
28 yrsLongest FOF
Sentence
14MN Programs Under
Fraud Audit
4FinCEN MSBs Under
Investigation

I. Feeding Our Future — The Largest COVID-19 Fraud in U.S. History

Feeding Our Future was a Minnesota nonprofit founded in 2016 that opened more than 250 sites and fraudulently obtained over $250 million in Federal Child Nutrition Program funds. The organization claimed to serve 90 million meals in under two years. FBI surveillance showed one site claiming 6,000 daily meals averaged approximately 40 visitors. Only about 3% of funding was reportedly spent on actual food.

Defendants and Sentencing Status

DefendantRoleOutcomeSentenceRestitution
Aimee Bock, 44, Apple ValleyFounder / Executive DirectorGuilty on all 7 counts (Mar 19, 2025): wire fraud, conspiracy, briberySentencing: May 21, 2026$5.2M forfeiture ordered
Abdiaziz Shafii Farah, 36, SavageScheme leader / "early mover"Guilty on 23 of 24 counts (June 2024 trial)28 YEARS (Aug 6, 2025)$47,920,514
Mohamed Jama IsmailCo-conspiratorGuilty at trial (June 2024)12 years (Oct 15, 2024)$47+ million
Abdimajid Mohamed Nur, 24, ShakopeeCo-conspiratorGuilty on 10 of 13 counts (June 2024)10 years (Nov 24, 2025)$47,920,514
Salim Said, 36, PlymouthCo-conspiratorGuilty on all 21 counts (Mar 19, 2025): wire fraud, briberyPendingTBD
Sharon RossCo-conspiratorGuilty plea43 months (Feb 7, 2025)$2,434,360
Sahra NurCo-conspirator ($5M stolen)Guilty plea4 yrs 3 mos (May 23, 2025)$5 million
Abdi Nur SalahFormer Senior Policy Aide to Mayor FreyGuilty plea to wire fraud (Jan 28, 2025) — $3.4M stolenPendingTBD
Total: 79 defendants charged. 63 found guilty (57 plea deals, 7 at trial). 1 acquitted. Remaining cases pending.

Juror Bribery Scheme

During the first trial (spring 2024), five defendants conspired to bribe a juror with $120,000 in cash for a not-guilty vote. The juror reported the bribery to the court. All five pleaded guilty by May 2025:

Where the Money Went

DestinationWhat Was PurchasedAmount / Detail
KenyaApartment building (Nairobi, South C neighborhood); Karibu Palms Resort (Diani Beach); land in Mandera Town (Kenya/Somalia/Ethiopia border); 20% stake in a Kenyan real estate companyMillions. Ahmednaji Maalim Aftin Sheikh (Kenyan national, brother of Abdiaziz Farah) charged with international money laundering for creating sham entities to move funds.
TurkeyReal estate purchasesDocumented in court filings.
Dubai / UAEJewelry$3.9 million in jewelry from Dubai.
Domestic (US)Luxury vehicles (Porsche, GMC, Tesla); residential and commercial real estate in MN, OH, KYAbdiaziz Farah: over $300,000 in vehicles in 6 months.
OtherMaldives honeymoon, luxury hotels, mealsDocumented in trial testimony.

Political Connections

Abdi Nur Salah, who pleaded guilty to wire fraud ($3.4M), worked for nearly a decade in Minneapolis city hall — first as aide to City Council Member Abdi Warsame, then to Mayor Jacob Frey. Trial briefs allege Salah used political influence to lobby politicians to pressure the Minnesota Department of Education not to shut down Feeding Our Future.

Al-Shabaab Connection

Disputed but under investigation: Multiple law enforcement sources told investigators that millions sent through hawala networks from Minnesota's Somali community wound up with Al-Shabaab. One confidential source stated: "The largest funder of Al-Shabaab is the Minnesota taxpayer." The former U.S. Attorney stated there was "never any evidence that this money went to fund terrorism." The matter remains under Treasury Department investigation.
Sources: DOJ USAO-MN press releases (78th defendant, 28-year sentence); IRS-CI (Kenyan national charged); FBI (dozens charged, $250M scheme); Sahan Journal (sentencing tracker); Star Tribune; Fox 9; City Journal.

II. The $700 Million MSP Airport Cash Corridor

YearCash Flagged by TSADaily Average
2024$342,370,000~$938,000/day
2025$349,400,000~$957,000/day
Total~$691,770,000~$1 million/day

TSA flagged nearly $700 million in cash in passengers' luggage leaving Minneapolis-St. Paul International Airport over two years. The volume is described as 10 to 100 times higher than cash outflows from other major U.S. airports including DFW, ATL, and JFK.

Key Details

Why This Matters for County Law Enforcement: The cash leaving MSP originates somewhere in Minnesota. It is collected, consolidated, and transported to the airport by couriers. The collection points — convenience stores, import-export shops, private residences — are located in counties across the state, not just Hennepin. Tracing the upstream collection network is where county-level investigation intersects federal enforcement.
Sources: VIN News; Simple Flying; WABC Radio; Fox News; Kenya Insights.

III. DOJ Surge into Minnesota

National Fraud Enforcement Division

On January 8, 2026, the Trump administration announced the creation of a new National Fraud Enforcement Division within the Department of Justice, focused on rooting out fraud across the federal government. Minnesota was identified as the primary target.

Prosecutor Deployment

AG Pam Bondi dispatched a team of additional federal prosecutors to reinforce the U.S. Attorney's Office in the District of Minnesota, promising "severe consequences" for fraudsters. This represents a doubling of DOJ presence in Minnesota for fraud investigations.

Scale of Prosecution

MetricNumber
Total persons charged (all MN fraud schemes)98
Convictions secured64
Estimated total fraud stolen"Well in excess of $1 billion" (U.S. Attorney for D. Minn.)
Programs under audit14 Medicaid and social services programs deemed "high risk"

Programs Under Investigation

Sources: Fox News; NBC News; ABC News; CBS News; Fox 9; PolitiFact.

IV. FinCEN Enforcement Actions

Geographic Targeting Order (GTO)

Issued: January 9, 2026 | Effective: February 12, 2026 through August 10, 2026
Coverage: Hennepin and Ramsey Counties (Minneapolis and St. Paul)
Requirement: Banks and money transmitters must report all international funds transfers of $3,000 or more where the beneficiary is located outside the United States.
Exemptive Relief: On February 27, 2026, FinCEN narrowed requirements for banks but not for MSBs — money service businesses remain fully subject to the GTO.

Four Notices of Investigation

FinCEN issued four formal notices of investigation to money services businesses (MSBs) in Minnesota under BSA examination and investigative authority. The investigations are focused specifically on MSBs providing services outside the formal banking system — i.e., suspected hawala networks. The names of the four MSBs have not been publicly disclosed.

FinCEN Alert

FinCEN issued a nationwide alert urging financial institutions to identify and report fraud associated with Federal child nutrition programs — a direct response to Feeding Our Future.

Law Enforcement Training

FinCEN provided on-the-ground training for Minnesota-based federal, state, and local law enforcement on utilizing financial data (Suspicious Activity Reports) to combat fraud schemes.

Sources: Treasury press release sb0354; FinCEN press release; Davis Polk client update; Federal Register; Faegre Drinker analysis; ABA Banking Journal.

V. Congressional Oversight

A. House Oversight Committee — Minnesota Social Services Investigation

Chairman Comer launched the investigation in December 2025, citing an estimated $9 billion stolen from Minnesota social services programs under Governor Walz.

DateAction
Dec 22, 2025Chairman Comer sends letter to AG Bondi requesting DOJ prioritize Minnesota fraud.
Feb 10, 2026House Oversight hearing on Minnesota fraud.
Mar 2, 2026Chairman Comer letter to DOJ regarding obstruction and funding concerns.
Mar 4, 2026Governor Walz and AG Ellison testify before the committee.

Key findings: The committee found that senior Minnesota officials were aware of fraud for years, possessed the authority to stop payments, and "repeatedly failed to act." The committee released testimony alleging a fraud "cover-up" by Governor Walz and Attorney General Ellison, including allegations of retaliation against state whistleblowers.

B. Tim Mynett / Rose Lake Capital / eStCru LLC Investigation

On February 5, 2026, Chairman Comer sent a letter to Timothy Mynett (husband of Rep. Ilhan Omar) demanding financial and corporate documents tied to two companies:

EntityTypeConcern
eStCru LLCCalifornia-based winery businessRep. Omar's financial disclosures showed Mynett's ownership stakes in these companies surged from $51,000 in 2023 to as much as $30 million in 2024 — an unexplained 58,000% valuation increase raising concerns about unknown investors potentially buying political influence.
Rose Lake Capital LLCInvestment consulting firm

Documents Demanded (deadline: February 19, 2026)

The Naeem Mohd Lawsuit

Naeem Mohd, a D.C.-area investor, sued Mynett and business partner Will Hailer, alleging he invested $300,000 based on a guaranteed 200% return within 18 months. The returns were never paid. Settlement reached September 2024; terms not disclosed. A guaranteed 200% return is a classic financial red flag associated with money movement schemes, not legitimate profit.

Additional Detail: The Rose Lake Capital website was scrubbed of 9 officers/advisors in late 2025 as federal scrutiny intensified. Website scrubbing when investigation pressure increases is a documented red flag for operations attempting to distance personnel from entity structures under review.
Sources: House Oversight Committee letters and press releases; MinnPost; Minnesota Reformer; Fox News.

VI. Banking De-Risking — How Hawala Lost Access to Banks

Understanding the banking collapse is essential to understanding why cash-based hawala operations exploded in Minnesota.

Timeline

YearEvent
~2010U.S. government finds cases of Minnesota residents sending money to Al-Shabaab through hawala networks. This triggers a cascade of bank closures.
2011Amina Farah Ali and Hawo Mohamed Hassan convicted in District of Minnesota for providing material support to Al-Shabaab through hawala (see Section VIII).
2010-2014Almost all mainstream U.S. banks drop Somali MTO accounts. 80% of Somali hawalas lose banking relationships.
~2015Merchants Bank of California — which handled 60-80% of all U.S.-to-Somalia fund transfers — announces closure of Somali MTO accounts under federal regulatory pressure.
2015-presentWithout banking access, hawalas increasingly rely on cash couriers carrying suitcases of currency on commercial flights. This is the pattern now under investigation at MSP.
The Paradox: Federal pressure to prevent terror financing pushed hawala operations out of the banking system and into cash — making them harder to monitor, not easier. The $700 million in cash leaving MSP is, in part, a consequence of de-risking. Money that once moved through auditable bank wires now moves in suitcases.

Scale of remittances: Somalia's remittance economy represents 15-20% of the country's total economic output. The Somali diaspora sends approximately $1.3 billion annually worldwide, with an estimated $215 million from the United States. Most of this flow is legitimate — workers sending money to families. The enforcement challenge is separating legitimate remittances from fraud proceeds and terror financing.

Sources: Oxfam; Foreign Policy; PBS NewsHour; NPR; Sahan Journal; MinnPost.

VII. IRS Criminal Investigation (IRS-CI) Activity

Secretary Bessent's January 9, 2026 Announcement

Treasury Secretary Bessent announced a coordinated enforcement package for Minnesota:

  1. IRS civil enforcement will audit financial institutions alleged to have facilitated laundering of social services funds.
  2. IRS fraud task force to investigate fraud involving pandemic-era tax incentives.
  3. 501(c)(3) audit initiative to probe potential misuse of tax-exempt status by entities implicated in fraud schemes.
  4. Treasury whistleblower channel opened for accepting tips on fraud, money laundering, and sanctions violations related to Minnesota.

IRS-CI Role in Active Cases

IRS-CI is a lead investigative agency (alongside FBI) on Feeding Our Future and related fraud cases. IRS-CI issued press releases for every major conviction and sentencing.

IRS-CI Nationwide BSA Statistics (2024)

MetricAmount
Fraud identified using BSA data$21.1 billion
Assets seized tied to criminal activity$8.2 billion
Restitution obtained for crime victims$1.4 billion
Sources: Treasury press release sb0354; Treasury press release sb0394 (whistleblower channel); Taxpayers Against Fraud (IRS-CI top ten cases).

VIII. Landmark Case — United States v. Amina Farah Ali and Hawo Mohamed Hassan

This is the case that proved hawala networks in Minnesota were funding Al-Shabaab and triggered the banking de-risking cascade.
FieldDetail
CourtUnited States District Court, District of Minnesota
Conviction DateOctober 20, 2011 (10-day trial)
Defendant 1Amina Farah Ali, 35, Rochester, MN — naturalized U.S. citizen from Somalia
Defendant 2Hawo Mohamed Hassan, 64, Rochester, MN — naturalized U.S. citizen from Somalia
Charges (Ali)1 count conspiracy + 12 counts providing material support to Al-Shabaab (13 total)
Charges (Hassan)1 count conspiracy + 2 counts false statements to FBI
Sentence (Ali)20 years in federal prison
Sentence (Hassan)10 years in federal prison
AppealEighth Circuit upheld both convictions (2015)

Methods

Significance for Current Investigations: This conviction established the precedent that Minnesota-based hawala networks were being used for terror financing. It triggered the banking de-risking cascade, pushed transfers into cash-based channels, and created the environment that produced the $700M MSP cash corridor now under investigation. The 2011 case is the root of the 2026 enforcement surge.
Sources: DOJ Office of Public Affairs; MPR News; Star Tribune; CBS News; CNN.

IX. Recent Enforcement Actions (2025-2026)

Housing Stabilization Services (HSS) Fraud

DateAction
Sept 2025Eight individuals charged: Moktar Hassan Aden, Mustafa Dayib Ali, Khalid Ahmed Dayib, Abdifitah Mohamud Mohamed, Christopher Adesoji Falade, Emmanuel Oluwademilade Falade, Asad Ahmed Adow, Anwar Ahmed Adow
Dec 2025Five additional defendants charged. HSS program paid out $61M in claims in first 6 months of 2025. Pristine Health LLC (St. Paul) used as vehicle.

Autism Services / EIDBI Fraud

DefendantDetail
Asha Farhan Hassan, 28Charged with wire fraud for $14M autism fraud scheme. Pleaded guilty.
Abdinajij Hassan YussufOperated Star Autism Center LLC. Offered kickback payments to parents. Charged.

2026 Federal Actions

DateAction
Jan 8, 2026DOJ creates National Fraud Enforcement Division. Prosecutors deployed to MN.
Jan 9, 2026Treasury Secretary Bessent: FinCEN GTO, IRS task force, 501(c)(3) audits, whistleblower channel.
Feb 5, 2026House Oversight letter to Tim Mynett demanding financial records.
Feb 12, 2026FinCEN GTO takes effect in Hennepin and Ramsey Counties.
Feb 24, 2026FinCEN GTO exemptive relief narrows bank requirements (MSBs remain fully covered).
Mar 2, 2026House Oversight letter to DOJ on obstruction and funding.
Mar 4, 2026Governor Walz and AG Ellison testify before House Oversight Committee.
Sources: DOJ USAO-MN (six additional defendants); IRS-CI (autism fraud); MN AG (HSS and EIDBI); ABC News; CBS News; Fox 9.

X. Capital Flight Corridors from Minnesota

CorridorMechanismEvidence
MSP → Amsterdam → DubaiCash couriers on commercial flights. Suitcases of currency. Legally declared but volume is 10-100x other U.S. airports.$700M flagged by TSA (2024-2025). HSI investigation active.
Minnesota → KenyaReal estate purchases through sham entities. Apartment buildings, resort properties, land.Feeding Our Future court filings. Kenyan national charged with international money laundering.
Minnesota → TurkeyReal estate purchases.Feeding Our Future court filings.
Minnesota → Dubai/UAEJewelry purchases ($3.9M documented). Financial hub for onward distribution.Trial testimony. Dubai serves as hawala clearinghouse.
Minnesota → SomaliaHawala networks. Both legitimate remittances ($215M/year from US) and illicit funds commingled.Ali/Hassan conviction (2011). Ongoing Treasury investigation.
Minnesota → ChinaMoney routing documented in FOF proceedings.Court filings.
Qatar as Financial Hub: Treasury has identified Qatar as a high-level financial clearinghouse and potential "backdoor" for fund routing. Hamas leadership has historically been based in Qatar. Kenya and Dubai are characterized as "front doors" used to distract investigators while Qatar functions as the less-scrutinized routing node.

XI. Whistleblower Programs Available

ProgramBountyApplicationContact
AML Whistleblower Improvement Act (FinCEN/DOJ)10% to 30% of collected funds for sanctions over $1 millionUnlicensed MTOs, BSA violations, sanctions evasionFinCEN / DOJ
IRS Whistleblower Office15% to 30% of collected proceedsTax fraud, unreported income from unlicensed money transmissionIRS Whistleblower Office
Treasury Minnesota Whistleblower ChannelCase-dependentFraud, money laundering, sanctions violations specifically related to MinnesotaOpened Jan 2026 per Secretary Bessent announcement

XII. Enforcement Timeline (2011-2026)

DateEvent
Oct 2011Ali & Hassan convicted (Rochester, MN) — material support to Al-Shabaab via hawala. Sentences: 20 and 10 years.
2010-2014Banking de-risking cascade. Almost all U.S. banks drop Somali MTO accounts.
~2015Merchants Bank of California (last holdout) closes Somali MTO accounts. 80% of hawalas lose banking access.
2020-2022COVID-19 pandemic. Feeding Our Future scales to 250+ sites. $250M+ fraudulently obtained.
Sept 2022FBI/IRS-CI: 48 defendants initially charged in Feeding Our Future.
June 2024First FOF trial. 7 defendants. 5 convicted. Juror bribery scheme discovered.
Oct 2024First FOF sentence: Mohamed Jama Ismail, 12 years.
Aug 2025Landmark sentence: Abdiaziz Shafii Farah, 28 years.
Sept 2025HSS fraud charges filed. Eight defendants.
Dec 2025Chairman Comer launches House Oversight investigation. Additional HSS and EIDBI charges.
Jan 8, 2026DOJ creates National Fraud Enforcement Division. Prosecutors deployed to MN.
Jan 9, 2026Treasury Secretary Bessent: FinCEN GTO, IRS task force, 501(c)(3) audits, whistleblower channel.
Feb 5, 2026House Oversight letter to Tim Mynett / Rose Lake Capital / eStCru LLC.
Feb 12, 2026FinCEN GTO takes effect (Hennepin & Ramsey Counties, $3,000+ international transfers).
Mar 4, 2026Governor Walz and AG Ellison testify before House Oversight.
May 21, 2026Aimee Bock sentencing (scheduled).