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DE RUEHTV #0140/01 0250537
ZNR UUUUU ZZH
R 250537Z JAN 10
FM AMEMBASSY TEL AVIV
TO RUEHC/SECSTATE WASHDC 5076
INFO RUEHRO/AMEMBASSY ROME 8617
RUEHJM/AMCONSUL JERUSALEM 3571
RHMFIUU/DEPT OF HOMELAND SECURITY WASHDC

UNCLAS TEL AVIV 000140 
 
SENSITIVE 
 
DEPT FOR CA/FPP, SARAH SEXTON 
CA/FPP: PLEASE PASS DOL 
CA/FPP: PLEASE PASS DOJ 
CA/FPP: PLEASE PASS FPMS 
DEPT FOR DS/IP/NEA 
DEPT FOR DS/DO/ICI 
DHS FOR CIS/FDNS 
DHS FOR CBP 
DHS FOR ICE 
ROME FOR DHS/ICE 
 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: CVIS ASEC KFRD KCRM CMGT PINR IS
 
SUBJECT: IN DEPTH: DEAD SEA COSMETICS AND SKINCARE INDUSTRY FRAUD 
 
REFTEL: A) 09 TEL AVIV 423 
 
1.(SBU) SUMMARY: Tel Aviv has been investigating visa fraud in the 
U.S. Dead Sea Cosmetics and skincare industry since 2007, when it 
became a noticeable problem.  From September 2008, Dead-Sea related 
fraud has been one of Tel Aviv's Fraud Prevention Unit's  (FPU)and 
Assistant Regional Security Officer-Investigator's (ARSO-I) main 
foci.  Since then Tel Aviv has learned a great deal about the 
multi-million dollar industry and its fraudulent activities.  Of 
particular concern is that the majority of the workers in this 
industry are Israeli, whether they are B1B2 visa holders, LPRs or 
dual American-Israelis; key companies have told us that they prefer 
to hire Israelis instead of Americans.  Of late, the industry has 
been using its kiosk marketing experience to branch out into related 
fields: hair straighteners, hair extensions, hair accessories and 
other assorted items such as other types of cosmetics, perfumes, 
pillows, toys, wind spinners and even, roasted nuts. 
 
The Dead Sea industry has spread to more than 36 states, creating a 
major presence across America.  This industry also operates in 
countries like Australia, New Zealand, the UK, and Germany. 
Unfortunately, its U.S. presence is not entirely "clean," for there 
are known issues of B1B2 visa holders working illegally; illegal 
worker exploitation; no federal or local taxes being paid on 
workers' earnings; filing applications for extensions and/or changes 
of status as a means of continuing illegal work; bogus marriages to 
keep key staff in the United States; B1 in lieu of H3 letter and H3 
visa scams; non-transparent corporate structures established to 
create distance from illegal workers; transport of huge sums of cash 
to Israel suggesting organized crime and money laundering; as well 
as an increased number of real estate ventures that suggest the 
same.  Moreover, it is culturally acceptable for post-army Israelis 
to work illegally in the United States; key parts of the Dead Sea 
industry have been able to base a large part of their business 
models upon the employment of illegal workers. 
 
These issues and other important topics of concern will be 
delineated in this lengthy background cable.  The unifying factor is 
that all of these issues have wider implications.  Aside from the 
criminal aspects of this fraud, a key implication is the increased 
visa revocation/refusal and denial of entry rates for post-army 
Israelis, which among other things, complicate Israel's high-profile 
desire to join the Visa Waiver Program.  Contact information for 
readers who wish to receive e-mail updates is available at the end 
of this cable.  END SUMMARY 
 
-------------------------------------------- 
H2B Workers Capped - B1B2 Workers Essential 
-------------------------------------------- 
2.(SBU)The number of H2B workers has been capped at 66,000 per 
fiscal year, with 33,000 to be allocated for employment beginning in 
the 1st half of the fiscal year.  From 1 Oct-31 Dec 2009, Tel Aviv 
issued 283 H2Bs-all for the Dead Sea industry.  Our experience tells 
us that there are far more than 283 Israelis working at kiosks 
across the United States--we suspect the numbers to be in the 
thousands; those additional, illegal workers are mainly B1B2 visa 
holders as that path is far cheaper and less hassle than filing 
petitions, and etc.  The Dead Sea industry knows it cannot sustain 
itself with just H2B, H3, J1 SWT, E and L visa and American-Israeli 
workers.  Thus, B1B2 workers (B1B2ers) are vital to their oft-stated 
plans to employ only Israelis.  Further, an argument can be made 
that these companies are hiring in a discriminatory fashion in that 
their main goal is to hire Israeli workers to the exclusion of 
others.  To illustrate how crucial B1B2ers are to these companies: 
say a Dead Sea company has 2-4 kiosks in nine medium-sized 
metropolitan-area malls with 2-3 workers per kiosk.  Assume 3 kiosks 
per mall and 2-3 workers per kiosk.  The number of workers ranges 
from 54-81 in this area with just ONE company.  Now, extrapolate 
that scenario across the United States.  With the hundreds of Dead 
Sea companies and thousands of kiosks in existence, it becomes clear 
that Israeli-Americans, H2Bs, Js, etc. cannot sustain the Israeli 
workforce plan--B1B2ers do.  Given that there are many more kiosks 
now than several years ago, it becomes more obvious that the decline 
in H2Bs and the rise in B1B2ers enabled the H2B program to become a 
"fig leaf" for these companies and their illegal workers. 
 
3.(SBU)Bolstering the above scenario is Document Benefits Task Force 
(DBTF) information (passed to ARSO-I) containing names of 50 Israeli 
B1B2 or VWP workers who had been working in the Houston area.  Post 
is currently analyzing these 50 cases: 22 B1B2s were issued by Tel 
Aviv in 2008-9 alone; 11 B1B2s were issued by Tel Aviv prior to 
2008; 11 are thought to be VWP nationals and, 6 names were too 
common to distinguish.  Further, the DBTF's activities have led to a 
particular company's scramble to replace/move elsewhere their B2 
workers with those holding H2Bs. 
 
4.(SBU)ARSO-I has been notifying the Government of Israel (GOI) of 
all incoming criminal deportations from the United States.  He also 
receives notification of all deportations and has noticed a sharp 
increase in young Israelis being deported for overstays or visa 
status violations.  Though anecdotal evidence, it points to a wider 
problem. 
 
5.(SBU) The list of 50 Houston-based workers is not the first or 
only one Tel Aviv's Fraud Prevention Manager (FPM) has received; CBP 
sent a list of 60+ workers who had been discovered working illegally 
at a Florida-based company.  As part of a multi-faceted fraud 
strategy, FPM has since revoked (and sent revocation requests to CA) 
a large number of B1B2s belonging to known workers.  Tel Aviv's 
interviewing officers are constantly trying to find ways to detect 
Israelis who intend to work; needless to say, coaching and other 
assistance has made it very difficult to detect these cases.  An 
analysis of case notes pertaining to the applicants on both lists 
showed that most of these Israelis had given solid stories, thereby 
convincing consular officers to overcome 214b.  The toughest aspect 
for 214b is not determining whether the applicant will return, but 
whether s/he will abide by their visa's terms.  Tel Aviv FPU is open 
to ideas on improving its detection of those intending to work; we 
are continually brainstorming solutions, but none have proven 
effective thus far. 
 
6.(SBU) H2B statistics: In the past several fiscal years, Tel Aviv's 
overall H2B workload has dropped from a high of 1,658 cases in FY 
2008 down by more than half to 528 cases in FY 2009.  Reflecting 
enhanced scrutiny of these applications is the increase in the FY 
2010 H2B refusal rate to 45 percent from 10.9 percent in FY 2008. 
 
H2Bs 
FY 2006: 179 H2Bs issued; 25 refused. (204 cases) 
FY 2007: 997 H2B issued; 79 refused. (1,076 cases) 
FY 2008: 1,495 H2B issued; 163 refused. (1,658 cases) 
FY 2009:  381 H2Bs issued; 146 refused. (528 cases) 
FY 2010 to Dec 31: 283 H2Bs issued; 129 refused. (412 cases) 
 
-------------------------------------------- 
Recruitment of B1B2 Workers: Well-Organized 
-------------------------------------------- 
7.(SBU) Recruitment of B1B2ers is largely peer- and Internet- 
oriented and occurs year-round; not surprisingly, recruiters and 
Dead Sea managers themselves are usually former illegal kiosk 
workers.  It also begins while they are still in the military; 
recruiters have participated in job fairs for those finishing their 
mandatory service.  The hiring process is highly organized and done 
with no paper trail. 
 
8.(SBU)Israelis preparing to leave the army generally want to earn 
money (whether domestically or abroad) to pay for school, travel and 
other life goals.  Israelis have a close-knit social network and as 
such, it is not hard to find peers who have worked illegally and be 
reassured by the fact that they were not caught.  FPM spoke with an 
Israeli who had been swept up in a raid, and he said that the vast 
majority of his peers obtain a tourist visa with intentions of 
working and that a majority are not caught.  This situation creates 
a relatively permissive recruitment environment.  While in the 
United States, an Israeli can walk up to a kiosk and ask about 
employment; they also can utilize online social networks such as 
Facebook to find jobs. 
 
9.(SBU) With a few variations, recruiters rosily promise such things 
as the ability to earn USD 3-4,000 per month, 20-30 percent 
commission, payment of half of the airfare, housing at resort-like 
apartment complexes and availability of a car.  In some locations, 
rent is a token sum and in others, upwards of USD 500 per month is 
charged.  Qualifications are minimal: strong English skills and a 
U.S. visa. 
 
10.(SBU)Companies advertise in newspapers and online; an interested 
worker only needs to complete a questionnaire and wait until someone 
calls them.  Typically, they are given a number to call when they 
land in the United States.  One variation is that recruiters will 
meet the prospective worker at a local cafe or mall to finalize 
details.  Others call Web-site listed telephone numbers and leave a 
message; someone returns their call and then convinces them to work. 
 If they don't have a U.S. visa, recruiters have been known to coach 
them on how to evade our scrutiny. 
 
11.(SBU)Prior to arrival in the United States, workers typically are 
given an address to write on their I-94-which may or may not exist. 
Upon arrival in the United States, they usually are met at the 
airport and taken to their housing.  Should there be problems at 
immigration, they are provided with a number for someone closely 
connected to this industry.  As described by a former Israeli 
worker, the entire process was "all well organized." Substantiating 
this is an I275 Q/A comment, "They know when we are coming.  They 
come to the airport to collect us." 
 
--------------------------------------------- -- 
B1B2ers: Lack of Consequences Helps Dead Sea Industry and 
Perpetuates Israelis' Cultural Acceptance of Illegal Work 
--------------------------------------------- -- 
12.(SBU)There is an array of reasons why post-army Israelis work 
illegally in the United States; a key part of this fraud problem is 
these young Israelis' cultural acceptable of illegal work.  The 
prevailing perception amongst these Israelis is that selling Dead 
Sea products is a simple way to earn a lot of money, can be done 
easily and that most are not caught.  One turnaround said, "people 
[in Israel] told me it was ok [to sell Dead Sea products].  There 
are a lot of people [who] sell Dead Sea products in the United 
States."  According to another Israeli who was caught and jailed, 
most of his peers know they intend to work well before applying for 
U.S. visas and obligingly tell interviewing officers that they know 
this work is illegal.  Illustrating the situation's pervasiveness is 
that some Israelis travel annually to work; others travel every two 
years.  This Israeli also estimated that there are "thousands of 
B1B2 workers across the United States"; statistics and anecdotal 
evidence cited in this cable strongly support this estimate.  He 
also theorized that quite a few come from the lower end of the 
socioeconomic scale--not poor, and not upper middle class.  Post has 
seen cases of Israelis relinquishing good jobs, such as those with 
the National Police, to work illegally and cases of illegal Israeli 
workers with a high-profile government or corporate parent.  Of note 
is that, due to the preference for Army service, Israeli-Arab kiosk 
workers are rare. 
 
13.(SBU)The deception by those intending to work illegally begins 
well before they arrive at the visa interview window and repeats at 
POEs.  In a secondary interview with CBP, one turnaround said, 
"....I don't remember who told me what to say, but everyone in 
Israel knows about going to America to work, and they say to tell 
the U.S. Embassy that you're going on vacation. It's easier to get 
the via."  Companies and recruiters have been known to advise 
applicants to: create a fake reason for the trip, such as attending 
a friend's wedding (in one case, CBP discovered the friend was 
already married!); and not to worry as "[After entering] as a 
tourist... they would take care of my paperwork."  Other examples 
are instructions to: "...tell US consular officials that he intended 
to visit a friend's aunt in NYC so that he could obtain a US visa 
and, "...to tell POE that I was coming for "retail manager in 
training program" (she worked as a secretary for a Dead Sea CEO). 
In addition to the lies, this B1B2 applicant pool tends to write on 
their DS 156's "None" for their U.S. destination and contact 
information (they know that if they were to put Ohio, we'd know they 
intended to work).  Interviewing officers have a hard time pinning 
them down to an exact U.S. address or contact as they generally say 
they are going to New York or some other common destination to see 
family such as an uncle or aunt (when they intend to work in AZ, TX, 
OH, TN or even in AL).  By contrast, H2B applicants diligently 
provide this information as given to them by the companies. 
 
14.(SBU)In general, kiosk workers are not a static bunch.  Some work 
several weeks or months at a kiosk in one area, say Cleveland, and 
then shift to another area such as Las Vegas for a few weeks or 
months and so on.  A strong network of Israelis paves the way for 
their job moves-if things do not work out at one kiosk, an Israeli 
can call upon the network to help his/her transfer to a another 
kiosk which could be local or out of state. 
 
-------------------- 
Paying B1B2 Workers 
-------------------- 
15.(SBU) Kiosk area managers and/or U.S.-based recruiters usually 
take care of compensating their illegal workers.  Pay tends to range 
from USD 1,000-3,200 per month, with the majority paid on the mid to 
lower end of this scale.  It is rare to earn a lot of money and, as 
expected, the higher end is occupied by those who excel at sales. 
Tel Aviv is aware of situations in which workers end up owing their 
employers money. 
 
16.(SBU)The most common method of payment is cash "under the table." 
 Per I275 reports, an assortment of cash payment methods exists: 
having the worker establish a U.S. bank account and then depositing 
cash or checks; pay worker USD 1,000 for the first month while still 
in Israel and then thereafter, pay USD 300 per week--the USD 1,000 
would be deposited into an Israeli bank account and USD 300 given in 
cash once state-side; having their pay wired to an Israeli bank 
account; having the worker open a U.S. credit card account and 
transferring money to the card, and etc.  Some workers know that no 
local or federal taxes are being deducted from their pay; others are 
told that "that has been taken care of." 
 
-------------------------------- 
B1B2 Worker Exploitation Issues 
-------------------------------- 
17.(SBU)The methods of exploitation we have seen are: 
 
a. Payment of prohibited H2B fees.  Those who withdraw from H2B work 
early state-side or while still in Israel have been unable to 
receive refunds of the extra, and prohibited, monies they had paid. 
Exemplifying this situation is a company that is known to charge 
Israeli H2B applicants a $100 fee as collateral for visa approval; 
if denied their H2Bs that company refused to return that money to 
the applicants on the basis that the failure to obtain a visa was 
the applicants' fault, not theirs. In addition, that same company 
charges H2B candidates half of the $1,000 cost to petition for the 
visa; the candidate pays $100 prior to leaving Israel and the 
remaining $400 is deducted from their first four salary payments. 
 
b. "Legal" status: Company told person that s/he could work legally 
on the B-1; told him/her it was "ok to work and that nothing was 
going to happen." When that person asked the recruiter about a work 
visa, s/he was told "not to worry about it." One company even told 
B1B2ers that "[they] can work for 3 months legally and after 3 
months, [they] can't." 
 
c. Job deceit: One person thought he had started a real job with an 
Israeli company and that he was being sent to the United States for 
training; he soon discovered that the "training" would be work and 
that there was no job waiting for him back in Israel. These 
companies have been known to move their employees around as they see 
fit.  An Israeli, originally recruited to work in the logistics 
department, was transferred to a kiosk when the company needed more 
cart workers.  Another variation is to promise to send a worker to, 
say, Los Angeles, and upon arrival, send them to, say, El Paso. 
 
d. Long hours, little pay. Six day workweeks and 11 hr workdays are 
not uncommon.  Some workers are paid only their commission, e.g. no 
minimum wage salary.  The majority are not paid anywhere near the 
$3-4,000+ a month promised by recruiters.  An Israeli who quit his 
H2B job this month informed us that he and his colleagues had been 
paid only a basic salary of $1500 a month and that their company 
took $500 a month from each of them to cover living expenses, such 
as rent.  After adding in other expenses, they ended up having to 
pay their employer money when they left, earning nothing, contrary 
to what was promised. 
 
e. No local or Federal taxes paid.  Given that the tendency to be 
paid in cash, most workers do not know that taxes must be paid on 
money earned. Nor do the companies enlighten them. 
 
f. Social Security Numbers (SSNs).  Illegalities abound in this area 
as shared SSNs, fraudulent SSNs and having no SSN are not uncommon. 
 
 
g. Employment Eligibility Verification I-9 forms not completed for 
workers.  Dead Sea companies have failed to complete I-9s for their 
workers.    All U.S. employers must complete and retain an I-9 for 
each worker-including citizens and noncitizens. On the I-9, the 
company must examine the employment eligibility and identity 
document(s) a worker presents to determine whether the document(s) 
reasonably appear to be genuine and relate to the individual and 
record that document information on the I-9.  This documentation 
provision is likely the sticking point for these companies as they 
do not want any evidence of hiring B1B2ers. 
 
h. Organized Crime enforcement tactics:  ARSO-I and FPM are aware of 
recruiters who threaten workers if they do not do their work as 
intended.  One such recruiter threatened a worker's family back in 
Israel with harm if the worker did not continue working at the 
kiosk.  ARSO-I is looking into these cases for prosecutorial 
potential. 
 
i. Department of Labor violations.  Examples include assigning 
workers to employment locations different from those listed on the 
DOL certifications.  As mentioned above, companies have been known 
to move workers around at will, according to current needs. 
 
j. And, no doubt, there are other methods of exploitation not 
described here. 
 
--------------------------------------------- - 
I-539 Extensions Filed to Continue Unauthorized Work 
--------------------------------------------- - 
18.(SBU)Many B1B2ers fail to disclose unlawful employment on their 
I539s to extend current status or switch to H2B or even H3 status. 
These applications are filed as a way to buy time to continue 
working.  To reduce scrutiny, Israelis have been known to file I539s 
in a different state from where they had been residing. 
 
19.(SBU)Another known tactic to keep Israeli workers in the United 
States is petitioning for a change of status for their workers from 
B2 to H3 in April since the companies have typically claimed their 
"peak load" occurs during the Christmas holiday season.  To 
complicate things further, they even petition to change the same 
H2Bs who entered as B2s and then worked in the kiosks during the 
holiday season over to H3 trainees after they re-enter the United 
States as B2s again in April and May.  The H3 classification is very 
problematic; see paragraphs 22-30. 
 
--------------- 
Marriage Fraud 
--------------- 
20.(SBU) There seems to be an overwhelming indication that the 
owners, principal partners and area managers of Dead Sea-related 
companies are enlisting U.S. citizens to commit marriage fraud in 
order to enable  their open-ended "legal" U.S. stays.  These 
"couples" knowingly engage in fraud, with payments to the U.S. 
citizen and pre-organized meetings to prepare for their USCIS 
interviews.  In October, Tel Aviv investigated a marriage fraud case 
on behalf of USCIS Phoenix that resulted in the withdrawal of both 
the I130 and I485 forms.  USCIS is investigating other cases of Dead 
Sea-related marriage fraud and Tel Aviv is willing to assist as 
necessary. 
 
---------------- 
Crooked Lawyers? 
---------------- 
21.(SBU)Lawyers appear to very much a part of the Dead Sea fraud 
scheme.  FPU is aware of a lawyer who advised an Israeli to obtain a 
new PPT to hide his/her lengthy U.S. stay.  Another lawyer reassured 
a group of B1H3 workers that they were in "legal status" whilst 
their I539s were pending with USCIS.  Skating close to ethical 
"lines," one lawyer even advised a high-level Dead Sea company owner 
(who was denied a visa in both Tel Aviv and Jerusalem) as to whether 
attempting to cross illegally from Mexico was preferable to Canada. 
That individual was caught trying to cross the U.S.-Mexican border 
by making false claim to U.S. citizenship; ARSO-I is working with 
DS/LAFO/DS on this case.  Such is the draw for Israelis working in 
this industry in the United States that they are willing to risk 
detention and possible prison time to work there.  Most tellingly, 
ARSO-I and Tel Aviv FPM have noticed that there are a handful of 
lawyers who have been filing the vast majority of the Dead Sea 
industry's petitions, I539s and I130s/I485s with USCIS.  Sometimes, 
new lawyers pop up, though they, too, appear to have connections to 
these key lawyers. 
 
--------------------------------------- 
Recent Arrests of Israeli B1B2 Workers 
--------------------------------------- 
22.(SBU)Tel Aviv CONS and ARSO-I are pleased with the uptick in 
attention various Department of Homeland Security (DHS) agencies and 
U.S. Attorneys have given to the B1B2er problem.  In November, 
Houston's ICE Documents and Benefits Fraud Task Force (DBTF) 
arrested 11 Israeli B1B2ers as part of a wider operation; ICE 
Seattle (Tri-cities office) arrested 11 more in late December and 
another Seattle office had arrested 5 earlier.  These arrests' 
timing has been fortuitous to Tel Aviv's ongoing educational 
campaign targeted to the post-army demographic about the potential 
consequences of working illegally in the United States.  We hope 
these arrests and Tel Aviv's recent 214B revocations of large 
numbers of B1B2ers' visas will filter through the close-knit 
post-army community and encourage them to think twice about working 
illegally.  On a side note, these revocations ensure that B1B2ers 
cannot re-enter the United States; some have been admitted despite 
TECS and other lookout entries for them. 
 
------------------------------------------ 
B1 in Lieu of H3 Training Letter and H3 Scam 
------------------------------------------ 
23.(SBU) On B1 in Lieu of H3 trainee (B1H3) issues, 9 FAM 41.31 
N11.9 says:  a. Aliens already employed abroad, who are coming to 
undertake training and who are classifiable as H3 trainees.  The 
regulations state that in order for an alien to be classifiable as 
H3, the petitioner must demonstrate that: 
(1) The proposed training is not available in the alien's own 
country; 
(2) The beneficiary will not be placed in a position which is in the 
normal operation of the business and in which citizens and resident 
workers are regularly employed; 
(3) The beneficiary will not engage in productive employment unless 
such employment is incidental and necessary to the training; and 
(4) The training will benefit the beneficiary in pursuing a career 
outside the United States. 
 
24.(SBU)Note that ALL four conditions in 9 FAM 41.31 N11.9 must be 
met to qualify for H3 status.  The most difficult item to overcome 
is condition 1.  Israel does have a Dead Sea skincare and cosmetics 
industry in which Israelis sell to American tourists, people from 
all over the world and to local customers.  Thus, per this 
interpretation, this H3 training field IS available in Israel.  In 
addition, 9 FAM 41.31 N11.9 (4) says the training is supposed to 
benefit the Israeli's career abroad--however that standard is also 
tough to meet as these Israelis tend not to have had Dead 
Sea-related careers prior to going to the United States for their 
B1H3 "training."  Their work back-grounds tend to encompass portable 
employment fields such as bartending, working at a gas station, cell 
phone sales/service, working as a secretary, etc. 
 
25.(SBU) It is rare that young, post-army Israelis present a visa 
application to us requesting B1 in lieu of H3 status.  In fact, Tel 
Aviv's Fraud Prevention Manager (FPM) is aware of only one such visa 
case at post since the summer of 2008--that one was refused on 214b 
grounds.  Of concern is the situation in which Israelis in this 
demographic present B1H3 letters to CBP officers at Ports of Entry 
for admission for 3-6 months' training, misleading both CBP and 
Embassy Tel Aviv consular officers. 
 
26.(SBU) Often, these Israelis apply for a visa under the guise of 
going to the United States on a 2-3 week vacation (it is now rare 
for us to see requests for trips of longer duration) to visit 
family, friends, travel, etc.  Tel Aviv consular officers, despite 
the employment of a variety of interviewing tactics, have no way of 
knowing which ones were specifically told by local recruiting 
companies to not reveal their true intention to work in the United 
States to them.  It is known that recruiters have no interest in 
Israelis who do not already possess a U.S. visa as that is one of 
two key job requirements; the other is possession of 
English-language skills.  After they receive their U.S. visa, the 
company will then furnish them with B1H3 training letters and coach 
them to tell CBP that they are coming for "just for training," etc. 
so as to facilitate their entry into the United States. 
 
27.(SBU)To combat the B1H3 letter scam, tools we employ include: the 
stapling of a card onto passports of those issued B1B2 visas 
advising against unauthorized employment in the United States; and 
extensive CCD notes that include a key phrase "vacation only," trip 
information as presented (e.g. location and duration) and job 
occupation.  The latter is important as those who present B1H3 
letters will almost always say they have been working for a local 
Dead Sea company for at least a short period.  If they recently 
applied for a visa at Tel Aviv, these applicants usually do not 
indicate during the interview or on the application itself that they 
already have been working for these local Dead Sea companies.  In 
other words, a different employer is likely listed in the CCD. 
 
28.(SBU)Regarding remuneration of B1H3 workers, 9 FAM 41.31 N11 
says: There are cases in which aliens who qualify for H1 or H3 visas 
may more appropriately be classified as B-1 visa applicants in 
certain circumstances, e.g., a qualified H1 or H3 visa applicant 
coming to the United States to perform H1 services or to participate 
in a training program.  In such a case, the applicant must not 
receive any salary or other remuneration from a U.S. source other 
than an expense allowance or other reimbursement for expenses 
incidental to the alien's temporary stay....it is essential that the 
remuneration or source of income for services performed in the 
United States continue to be provided by the business entity located 
abroad, and that the alien meets the following criteria: 
(1) With regard to foreign-sourced remuneration for services 
performed by aliens admitted under the provisions of INA 
101(a)(15)(B), the Department has maintained that where a U.S. 
business enterprise or entity has a separate business enterprise 
abroad, the salary paid by such foreign entity shall not be 
considered as coming from a "U.S. source;" 
(2) In order for an employer to be considered a "foreign firm" the 
entity must have an office abroad and its payroll must be disbursed 
abroad. To qualify for a B-1 visa, the employee must customarily be 
employed by the foreign firm, the employing entity must pay the 
employee's salary, and the source of the employee's salary must be 
abroad; and.... 
Going against 9 FAM 41.31 N11.9 (2) and (3), the B1H3 "training 
program" in reality has these Israelis engaging in unauthorized full 
time employment selling Dead Sea products at mall kiosks across the 
United States.  In general, they are paid in cash based upon their 
level of sales, which can range from USD 250 to USD 800 per week. 
Wire transfers from the United States to workers' Israeli accounts, 
payments to Israeli credit card accounts, and checks deposited to a 
U.S. bank account are among the other known means of payment.  All 
of these payment methods are considered U.S. source, thus not 
foreign as they should be. 
 
29.(SBU)Known B1H3 letter drafters (Israel-based) are: 
 
STS (majority user and has several TECS records), AK Global 
Investments and Management LLC, KIT, Gaya Inc, Global Spa LTD, Ela 
Marketing LLC, Tal Yosifun LTD, JNS Global Israel LTD, Sol 
Enterprise Israel LTD, Market Trade LTD, Mor Universal Management 
Consultants, and Global Market Trade LTD (formerly JG Cosmetics 
LTD). [NOTE: Gaya Inc and Sol Enterprise Israel LTD have residential 
addresses.] 
 
30.(SBU)Known US counterparts to above Israeli comapnies: 
 
A&B United, Coral Cosmetics, E-Marketing, Enias Beauty, Everesteam, 
Feel Free LLC, Gill Cosmetics, Gizbo Trading, JNS Global, Lali 
Beauty (aka Cart Planet), Libra LLC, LMD 4 Florida, Lucidity 
Enterprises, Mall Security Enterprises, MDS, Micaella, Nine DEC, 
Sound Creation, Spa to Go (MI), Stanga and Suns Inc. 
 
31.(SBU) H3 Statistics: Of note is Tel Aviv's dramatic drop in H3 
cases between 2008 and 2009--likely due to the B1H3 letter scam and 
submission of I539 applications to change status to H3. 
 
H3s 
FY 2006: 15 H3s issued; 4 refused. (19 cases) 
FY 2007: 49 H3s issued; 22 refused. (71 cases) 
FY 2008: 47 H3s issued; 19 refused. (66 cases) 
FY 2009: 8 H3s issued; 4 refused. (12 cases) 
FY 2010 to Dec. 14: 0 H3s issued; 1 refused. (1 case) 
 
-------------- 
E and L Visas 
-------------- 
32.(SBU)E visas: Shell companies have been known to be established 
in order to "qualify" an Israeli for E1 status.  E1 visas, in 
general receive close scrutiny in Tel Aviv; Dead Sea-related cases, 
due to their non-transparent corporate structure, receive even 
further scrutiny.  As a fraud prevention measure and, mainly because 
of their low volume, ConGen Jerusalem agreed to transfer their E 
cases for Tel Aviv to process.  Of its own cases, Tel Aviv approved 
eight and rejected six such E1 visa cases; rejections were due to 
lack of qualifications. 
 
33.(SBU)L visas:  Tel Aviv recently returned to USCIS a Dead Sea 
company's L petition because additional information that we received 
revealed there was no intra-company connection between the Israeli 
entity and the U.S. entity other than a distributor relationship. 
As with E visas, Tel Aviv will be keeping a close eye on these 
cases. 
 
----------------------------------- 
Q4 Visas for Israeli Kiosk Workers? 
----------------------------------- 
34.(SBU) A Dead Sea company, one that may have organized crime (OC) 
connections, continues to tell us they are pushing for the creation 
of a Q4 visa category to permit Israelis to work at U.S. kiosks 
selling Dead Sea products.  FPM first heard of this idea back in the 
fall of 2008 from this company's owner and continues to hear about 
Q4 plans.  The argument for the Q4 visa rests upon the "uniqueness" 
of having an Israeli sales force within the Dead Sea industry.  Tel 
Aviv does not view this proposed visa category as credible, for it 
could be used as a way to legitimize B2 workers and continue the 
pattern of not being open to hiring U.S. citizens. 
 
35.(SBU)Moreover, there is nothing intrinsic to the Dead Sea that 
Israelis are privy to that other people in the world cannot find 
out. In fact, company representatives repeatedly have stated to 
ARSO-I and FPM that only Israelis are capable of working for them 
and that they do not hire Americans because they are lazy.  Their 
attitude has more to do with high pressure sales techniques and 
controlling a vulnerable work force; ARSO-I and FPM have seen these 
elements in these companies' instruction manuals. 
 
-------------------------------------- 
I275s - Dead Sea Information Goldmine 
-------------------------------------- 
36.(SBU)Dead Sea-related denials of entry easily top Tel Aviv's list 
of reasons for POE turnarounds.  Two hundred and sixty-one (261) 
such I275s have been received here since October 2007.  In Jan-Nov 
2009, FPM received 162 I275s, reflecting POEs' increased scrutiny of 
post-army Israelis--the group that is most likely to work without 
authorization.  Since we probably do not receive every Dead 
Sea-related I275 from each and every POE, the total number we have 
likely does not represent the total number of Israelis denied entry. 
 Newark, with 65 cases, processed the most I275s in Jan-Nov 2009; 
Atlanta Hartsfield and Chicago O'Hare are second and third, 
respectively, for the same period.  The November 2009 CBP Travel 
Industry Bulletin spotlights Atlanta, which is one of the busiest 
airports in the world, and the mention of Israeli fraud on page two 
says something about the level of their concern regarding this 
issue.  Previously, as described in reftel A, Israelis intending to 
work were advised by their companies and recruiters to avoid 
Atlanta.  Disseminating this type of information has become more 
sophisticated due to online videos advising which airports to avoid, 
and etc.  As with Atlanta, Israelis are beginning to avoid Newark. 
Where will they go next? 
 
37.(SBU)To help close the communication gap, FPM has reached out to 
POEs that handle Israeli arrivals and shared information in the 
attempt to maintain an "advantage."  The outreach is done via the 
FPM's ad-hoc Dead Sea e-mails that share trends/data and information 
with CBP, FDNS, ICE, USCIS and others.  FPM maintains several 
e-distribution lists.  Represented in the CBP POE list are:  ATL, 
BOS, CHI, DET, HOU, IAD, JFK, LAX, MIA, MSP, NEW, PDX, PHI, PHX, SEA 
and SFO.  If you would like to receive these Dead Sea e-mails, 
please write to vincentwm@state.gov. 
 
38.(SBU) All 261 of our I275 cases have been analyzed extensively 
for intel- and data-gathering purposes, and shared internally and 
externally.  What's noteworthy? 
 
21-24 is the main age cluster; 
57.5 percent are females and 42.5 percent males; 
46 percent are from central Israel (interesting as the north and 
south are less well-off areas); 
75.5 percent applied for B2 status upon entry; 
16.9 percent presented B1H3 letters; 
 
POE denials: 
52.5 percent worked on a previous trip; 
31 percent intended to work if admitted to the United States; 
47.9 percent were caught on the second entry attempt due to having 
worked on the first entry; and 
 
POE denial grounds per INA: 77.4 percent were 7A1, and 
17.6 percent were 6C1 in addition to 7A1. 
 
39.(SBU) We suspect that quite a few Israelis manage to evade CBP 
successfully and, for every I275er caught, there are likely several 
B1B2ers.  Via word of mouth, the smart ones come for a short, 1-2 
month stay to work, earn money and leave.  They then return the 
following year for the holidays, which is the principal money making 
season.  According to our CBP contacts, these individuals are much 
harder to catch. 
 
40.(SBU) FPM encourages POEs to send via e-mail or snail/express 
mail copies of Dead Sea-related I275s for intel and analytical 
purposes; Please see paragraph 75 for Tel Aviv's mailing address 
details. 
 
---------------------------- 
Validation Studies Underway 
---------------------------- 
41.In October 2008, Tel Aviv implemented changes in its evaluation 
of post-army visa applicants, and as a result, its refusal rate 
began to climb sharply.  FPM requested an ATS/ADIS validation study 
of B1B2ers in April 2009.  The results indicated it was too early 
for an informative study as many of these Israelis were still in the 
United States. We plan to follow up on this group at the 18 month 
mark; we suspect we'll see lengthy stays, numerous extensions and 
changes of status.  Meantime, we continue to flag issued cases 
within this demographic by adding particular phrases into NIV case 
notes for additional validation studies. 
 
------------------------------------------ 
Transport of Cash Connected to Dead Sea Industry 
------------------------------------------ 
42.(SBU) Transport of cash from the United States to Israel has long 
been a concern of FPM and ARSO-I as it not only implies illegal 
employment, but also money laundering, and thus, potential organized 
crime connections to the industry.  Information gathered from the 
I275s and from CBP show that Israelis, including relatives or 
friends of illegal workers, have been caught outbound transporting 
large sums of money back to Israel.  In one case, a young Israeli 
couple was discovered transporting over USD 26,000 for their illegal 
worker friends to Israel; they had lied about the amount to prevent 
the money's seizure.  Further, ARSO-I has discovered through a 
source that young Israeli workers returning to Israel have been 
tasked with carrying back money for the company.  These workers are 
then met by a contact in Israel; the money is collected at or near 
the airport and is delivered to a local company representative. 
 
43.(SBU)At Newark, Israelis regularly have been caught by its 
Outbound Currency Enforcement Team (OCET).  Generally, these 
Israelis have been in the United States for four to six months and 
are carrying about USD 8,000 to USD 9,800, just under the reporting 
limit.  In addition to carrying cash for the companies, these 
workers also have been known to wire some of the money to Israel or 
have someone carry some of it home for them or buy items with their 
illegal earnings such as laptops, i-Phones, clothing, etc.  OCET 
places long-term lookout on these cash-carrying individuals and 
reports those who admit to and/or have proof of working illegally to 
Tel Aviv.  Tel Aviv FPM then evaluates these individuals for 214B 
visa revocations and adds corporate intel gleaned by OCET from these 
cases to the Dead Sea Excel file.  Tel Aviv welcomes submissions 
from other OCET teams. 
 
44.(SBU) There is a catch-22 situation in which CBP knows that 
Israelis had worked illegally, with or without proof of employment 
and/or admission of unauthorized employment.  If the Israeli 
declares under $10,000 or over that amount--as long as they declare, 
they are free to return to Israel.  Per Newark's OCET's experience 
and TECS records, Newark estimates that roughly 800 Israelis who 
carried $5,000 or more and stayed four to six months were either 
stopped, interviewed and/or had outbound examinations in CY 2009. 
The scale of this cash transport is not small-for just one POE: 800 
Israelis multiplied by $5000 minimum, equals a lot of money--at 
least $4 million! 
 
--------------------------------- 
Dead Sea and Organized Crime (OC) 
--------------------------------- 
45.(SBU) Organized Crime in the Dead Sea industry is a real concern. 
 Tel Aviv has consistently received information that large sums of 
money are allegedly being laundered and transported between the 
United States and Israel.  Due to the amount of money being 
laundered and transported, Tel Aviv has long suspected a link 
between the Dead Sea industry and OC.  In early December, FPU 
received an e-mail from an informant who said he had information 
alleging that a key Dead Sea company is connected to OC.  ARSO-I and 
FPU subsequently interviewed this informant; the ARSO-I's report of 
this interview states: "The SUBJECT stated that s/he is in 
possession of computer disks with all of this company's accounts, 
money totals, smuggled bulk cash from the United States to Israel 
and has a complete understanding of the alleged illegal activities 
to include the employing of illegal workers, suspected drug 
smuggling, money laundering, intimidation, threats, extortion, and 
tax evasion.  The SUBJECT also claimed that this company is 
allegedly owned by a major organized crime family in Israel that has 
threatened SUBJECT'S life, extorted money from SUBJECT, and has sent 
people to physically assault SUBJECT."   Due to the ongoing criminal 
investigation in the United States, no additional details can be 
released at this time. 
 
46.(SBU)Further adding credibility to our suspicions, is an arrest 
case from this past summer in Japan where kiosks run by young 
Israelis were allegedly being used by an OC organization to launder 
its drug money and real estate investment deals.  As noted above, 
some Dead Sea companies have real estate and investment companies as 
part of their overall structure. 
 
47.(SBU)Shell and holding companies are all part of the industry's 
corporate strategy, designed mainly to distance themselves from the 
illegal workers at the kiosks.  To exemplify, one Dead Sea holding 
company has 60+ companies under it.  Now, assume that one of those 
60+ companies has a contract with another company and that other 
company then hires the illegal workers.  This scenario is quite 
common, complicating our efforts to combat and uncover Dead Sea 
fraud.  Furthermore, once a company is found to be employing illegal 
workers it merely changes its name or creates a new owner for a 
shell company and applies for H2B petitions.  As mentioned earlier, 
there are a handful of attorneys who have been filing the majority 
of the Dead Sea industry's petitions and I539s.  They appear to be 
passionate lobbyists for these new companies--almost as if there had 
been a previous working relationship (as in, with the "old" 
company). 
 
48.(SBU) Sometimes, key Dead Sea players have been "caught-out" by 
their own non-transparent corporate structures.  Recently, Tel Aviv 
received an e-mail complaint from one of the known Dead Sea lawyers 
that also included the CEO's angry e-mail to that lawyer.  Problem: 
that CEO had, in theory, nothing to do with the petitioning company 
as he was the CEO of a different company. FPM investigated and 
discovered that the CEO's company sub-leases the kiosks to the 
petitioning company.  Furthermore, the CEO's company has a TECS 
record that says it doesn't exist. 
 
49.(SBU) As a side note:  Tel Aviv FPU has a large and growing list 
of known OC figures identified through open source materials and 
confirmed by ARSO-I through Israeli Law Enforcement sources.  Tel 
Aviv FPU and ARSO-I are working with the Legal Attach on possible 
strategies to combat OC in conjunction with FPU's revocation of 
visas for convicted OC members. 
 
---------------------------------- 
Dead Sea Industry and Real Estate 
---------------------------------- 
50.(SBU)Increasingly, we are seeing signs of involvement in real 
estate by many of the key Dead Sea players.  One example is the 
recruiter mentioned in the 6E deterrent section.  In addition, our 
ARSO-I recently interviewed someone with extensive knowledge of a 
particular Dead Sea company; this person alleged that money 
laundering is occurring through the real estate arms of these 
companies.  The real estate arms of these companies are also 
involved in employing young Israelis to work for them in violation 
of their visa status.  Further, substantiating this trend, ARSO-I 
reported that his source stated that the real estate business was 
becoming as important as the kiosks. 
 
51.(SBU) Another aspect of the real estate issue is these companies' 
provision of housing for their workers, whether legal or not. 
Industry-wide, there are a large number of apartments and, 
increasingly, houses, located near the malls where they work. 
Placing at least four or more workers in a two bedroom place and 
charging each person USD 500 a month has made housing another 
potential money-maker.  As the addresses of these apartments/houses 
may indicate intent to work, Tel Aviv FPM has been tracking them in 
an Excel document that contains comprehensive information on the 
Dead Sea industry.   Addresses are gleaned from I275s, H2B DS 156s, 
and received from other inter-agency sources. 
 
 
--------------- 
Made in Israel? 
--------------- 
52.(SBU)Given the shrinking Dead Sea, labor/shipping costs and the 
increasing volume of products being sold, Tel Aviv FPM and ARSO-I 
suspect that some of these "made in Israel" cosmetic and skincare 
item are actually made elsewhere.  Supporting this is ARSO-I's 
development of a source who informed him that one of the larger 
corporate groups was manufacturing soaps in the United States using 
possible illegal workers from Central America and then selling the 
product as from the Dead Sea, i.e. made in Israel.  Another likely 
source is China, which has both "dead seas" and cheap labor.  Last 
but not least, ICE Rome reported to ARSO-I and Tel Aviv that they 
suspect these companies may be importing soaps and creams in bulk to 
Israel and labeling them here before shipping to the United States 
using Israel's "most favored trading nation" status to save money. 
 
-------------------------- 
Interagency Success Story 
-------------------------- 
53.(SBU) In November, Houston's DBTF executed search warrants on a 
particular Dead Sea company.  The result: ten Israelis were arrested 
for working on B2 visas; numerous boxes of evidence were seized 
along with USD 70,000.  The company's H2B contract, translated by 
Tel Aviv FPU at the DBTF's request, was found to violate DOL and 
USCIS provisions.  ARSO-I and FPU have assisted DBTF with 
identifying people, detailing connections between 
individuals/companies and provided requested information whenever 
possible. 
 
54.(SBU)It is now rumored that the company being investigated by 
DBTF Houston has shuttered operations; Tel Aviv continues to monitor 
chat rooms and message boards for Dead Sea workers.  Indications are 
that this company's B1B2ers already have been moved to other areas 
and new companies (including shells) have been created to fill this 
corporate gap.  Moreover, Tel Aviv discovered that this 
Houston-based company has very close ties to another Dead Sea 
operation in Arizona.  ARSO-I has passed information to DBTF Houston 
as part of their ongoing investigation. 
 
55.(SBU)ARSO-I, ICE Rome and Tel Aviv have consistently waged an 
information campaign to enlist other regulatory and law enforcement 
entities to investigate this seemingly fraud-riddled industry on a 
nation-wide basis.  However, given the lack of interest in a 
national investigation, ARSO-I and Tel Aviv highly recommend that 
DBTFs nation-wide consider duplicating the Houston-based DBTF's 
recent successful efforts. 
 
56.(SBU) Tel Aviv believes that interagency efforts are crucial to 
combating and preventing Dead Sea Fraud.  FPM has developed a 
network of working contacts across the United States with various 
agencies such as CBP, ICE, FDNS and USCIS.  Tel Aviv greatly 
appreciates CBP's inclusion of its fraud prevention efforts in their 
official publications such as the New York/Newark Tactical 
Analytical Unit (TAU) Weekly Intelligence Brief and the Office of 
Intelligence and Operations Coordination's Weekly Intelligence 
Notes.  As one prong of a multi-faceted fraud situation, our 
continued inter-agency sharing of information, trends and analyses 
have and will continue to tighten the noose on Israelis working 
illegally.  Complementing the FPM's efforts is the ARSO-I's ongoing 
communications with Law Enforcement entities to facilitate 
information-sharing and to track a growing number of arrested 
Israelis and Dead Sea companies under investigation. 
 
----------------------------------------- 
6C and 6E Ineffective: Stronger Deterrents Needed 
----------------------------------------- 
¶57. (SBU) 9 FAM 40.65 INA 212(A)(6)(E) 
(6)Illegal entrants and immigration violators. 
(E) Smugglers. 
(i) In general.-Any alien who at any time knowingly has encouraged, 
induced, assisted, abetted, or aided any other alien to enter or to 
try to enter the United States in violation of law is inadmissible. 
 
 
Per 9 FAM 40.65 N5, 6E could be incurred for offering an alien a job 
under circumstances where it is clear that the alien will not enter 
the United States legally in order to accept employment. 
 
58.(SBU)Post is looking into either P6E- or 6E-ing known Israeli 
recruiters of B2 workers.  One recruiter recently applied for a 
visa, saying that he was in real estate and no longer in the Dead 
Sea business.  The applicant, because of his prior Dead Sea history, 
was vetted more closely by FPU.  FPU discovered that he had 
recruited B2 workers and was still doing so; a second interview by 
the ARSO-I and FPU resulted in a 6E finding.  Using the 6E provision 
can deter recruiters from traveling to the United States, however 
they would still be free to recruit B2 workers in Israel and online. 
 
 
59.(SBU)Per the above I-275 analyses, almost 18 percent of those 
denied entry are found ineligible under 6C1.  Israelis 6C1'd tend to 
be recent cases in which they obtained a visa from Tel Aviv telling 
one story (vacation) to the interviewing officer and another story 
(work) to CBP officers--misrepresentation.  Post has seen cases in 
which CBP could have and, for their own reasons, did not do so. 
Post is unable to make 6C1 findings unless the applicant was 
determined to have cut off a line of questioning with a material 
fact-in reality, this determination is made after the visa's 
issuance.  Due to Tel Aviv's lack of information as to when B1B2ers 
start work, it is difficult to apply the 30/60 day rule per 9FAM 
40.63 N4.7-1 and 9FAM 40.63 N4.7-2.  It is also not yet clear 
whether 6C1 will be a strong deterrent as most of those recently 
denied entry have been barred for at least five years.  After five 
years, they'll certainly learn first-hand the severity of the 
lifetime consequences of their 6C1 ineligibility when they apply for 
a new visa. 
 
-------------------------------------- 
New, Old Deterrent: Limit B1B2 Validity? 
-------------------------------------- 
60.(SBU)The essence of Tel Aviv's 214b problem is not whether the 
applicant will return, but whether the applicant will abide by the 
terms of his/her B1B2 visa.  This cable presents strong evidence 
that many post-Army Israelis violate the terms of their visas.  As 
this practice is culturally acceptable, Tel Aviv thus far has been 
unable to determine a pattern that would help interviewing officers 
identify mala-fide applications.  Several years ago, Tel Aviv 
limited visas issued to middle- and high-school aged students to the 
approximate end of their military service so as to prompt a look at 
their post-army situations.  Per CA's request this practice stopped. 
 Being able to review the applications of Israelis who previously 
received limited visas has been helpful in identifying patterns and 
in collecting crucial information about illegal recruitment and work 
practices. This, combined with the large number of post-army 
Israelis who work illegally on their B1B2 visas, has led Tel Aviv to 
re-examine the efficacy of limiting young Israelis' visas, with a 
focus on those who recently finished their military service.  We 
look forward to a dialogue with CA on this issue. 
 
61.(SBU)There are a variety of reasons described in this cable for 
Tel Aviv to re-consider limiting visas of those in the post-military 
service age group.  Of note is that, while in the military, Israelis 
must obtain special permission to vacation abroad and return to 
military service or face being charged as a deserter.  And for 
post-army Israelis, given the widespread and culturally accepted 
intentions to work illegally, the idea would be to limit post-army 
issued visas to one- or multiple- entry for one year (un-annotated), 
sharply reducing the time and opportunities to work illegally.  This 
one year visa limitation idea would also give us more information 
about their actual travel versus their stated plans, helping us 
better identify mala-fide first time applicants.  It should be noted 
that Tel Aviv's interviewing officers have been consciously 
evaluating each applicant as an individual and trying not to 
discriminate against a broad age-group category.  Frustratingly, we 
regularly receive reports on Israelis known to be working who 
appeared to be solid visa issuance cases during their interviews, 
which were based on the best available information regarding their 
ties. 
 
--------------------------------------- 
Visa Waiver Program (VWP) Implications 
--------------------------------------- 
62.(SBU) While security and biometric requirements are Israel's key 
hurdles to joining the VWP, it now has the added complication of 
being over the three percent refusal rate threshold due to post-army 
Israelis' tendency to abuse their visas.  Predictably, dual national 
Israeli workers with VWP country passports have bypassed Tel Aviv 
and entered the United States on their VWP passports.  Tel Aviv's 
adjusted refusal rate for host country nationals for B1B2 visas 
increased from 1.27 percent in FY 2007 to 4.38 percent in FY 2009. 
It appears this rate will climb further; for FY 2010, as of December 
30, it was 5.91 percent.  Worldwide, the refusal rate for all 
Israelis is higher yet.  Although our refusal rate continues to 
rise, we are still taking great pains to interview each applicant as 
individual cases. 
 
-------------------------------------------- 
Annotations as a Fraud Prevention Tool: Israelis Prove to be Clever 
and Adaptable 
-------------------------------------------- 
63.(SBU)As an innovative fraud prevention tool, Tel Aviv, in 
consultation with 9FAM 41.113 PN6, 9FAM 41.31 N19 and CBP officers, 
began adding a particular, positive annotation on some full-validity 
B1B2 visas issued to those within this problematic demographic.  Due 
to a lack of "tells," Tel Aviv has not been able to distinguish 
definitively between those who intend to abuse their visas by 
working illegally from those who do not; as mentioned above, 
recruiters are coaching applicants on what to do/say in their 
interviews.  Our annotations were intended to give CBP officers, who 
are able to talk to our applicants several weeks/months 
post-interview, an opportunity to prevent B1B2 visa abuse.  All 
applicants in this age group are potentially "at risk" for 
recruitment, especially after being granted B1B2 visas; because of 
this risk, CBP officers have told FPM that they appreciate our use 
of such annotations.  It should be pointed out that only a minority 
of visas for this demographic were annotated. 
 
¶64. (SBU) The first annotation employed was "First Trip: travelling 
to XYZ with XYZ relative."  This proved ineffective, for Israelis 
learned to create stories to cover discrepancies with the annotation 
and it applied only to the first trip.  To replace this, the more 
generic "B2 CCD" annotation informed CBP that the Israeli has 
sufficient ties to qualify for visa and told us their trip's intent 
was B2 purposes, tourism.  At any rate, clever Israelis figured out 
that B2 CCD meant they needed to be consistent with the false 
tourism story sold to Tel Aviv with CBP.  Given CA's aversion to 
annotations, we have ceased the use of B2 CCD annotations. 
 
65.(SBU) Predictably, Israelis are chatting online at sites devoted 
to working in the United States about perceived patterns of Tel 
Aviv's actions, including annotations.  While reviewing "Forums for 
Job Advertisements in the U.S.," FPU discovered this posting:  "I 
have an important question: I got a visa in the mail for 10 years 
and the visa was annotated 1st trip with parents. I am really not 
planning on traveling with my parents. Can anyone help? Tell me what 
can I do?"  The response was:  "you have been busted...this is a new 
policy that the Embassy has taken in order to make sure no one fools 
them.  Applicants say they are traveling with parents in order to 
maximize their chances in getting a visa.  No way in getting around 
this cause it appears in their computers. Best idea for you is to 
ask your mother if she wants to join you in this trip." 
 
------------------------------------ 
Facebook as a Fraud Prevention Tool 
------------------------------------ 
66.(SBU)The Internet has "gifted" us with new fraud tools for our 
toolbox. Facebook (FB) is a prime example as we use it in many ways. 
 
 
67.(SBU) Confirming Identities and/or Affiliations (assumes public 
access):  Not surprisingly, Dead Sea-related FB pages exist-most are 
in Hebrew:  two examples are "Carts in San Diego" and "Dead Sea in 
Miami."  FPU checks which "location" or "network" with which the 
person in question might be associated.  If an applicant signed up 
for the Houston network (or other area known for Dead Sea workers), 
it raises a red flag that they should be interviewed more thoroughly 
as to the trip's true purpose.  FPU also trawls through FB's Dead 
Sea-related groups to spot-check members or "fans" of a particular 
page against the CCD to see what type of visa, if any, they 
received.  Likewise, surfing through an applicant's list of 
"friends" for familiar Dead Sea names and/or for that person's U.S. 
contact's listing as a "friend" can be fruitful.  These searches 
help determine whether or not the applicant or the applicant's 
contacts are connected to Dead Sea-related activities. 
 
68.(SBU) FB pages have helped official investigations, too.  At the 
request of ICE, Tel Aviv, armed with some bio data, was able to 
verify the identity of a person who was working at a kiosk by 
finding that person's FB page photo and comparing it to his/her CCD 
photo. 
 
69.(SBU) Recruiters and job listings:  FB has pages for Dead Sea job 
listings and one such site is "Nova USA."  To investigate, the FPU 
visits that page and looks at the names of the administrators and 
the contact e-mail addresses for job listings (which can lead us to 
recruiters) and then checks the information against the CCD via a 
text search.  If there are "hits," then the information within these 
cases, such as other e-mail addresses are text searched to see where 
the information trail leads.  Ultimately, all key information is 
watch-phrased. 
 
------------------------------------ 
Outreach as a Fraud Prevention Tool 
------------------------------------ 
70.(SBU)In September, Tel Aviv publicly launched a consular video, 
"Illegal Work in the U.S.: Price is Too High" 
(usembassy-israel.org.il/consular/niv/index.a spx).  This video has 
been viewed on the Embassy's You-Tube channel over 5,700 times, 
easily making it Tel Aviv's most popular one.  In addition to also 
posting it on the consular section's FB page, the video is being 
played in the visa waiting room in a loop, along with a video that 
explains the application process.  Some Israelis who have been 
denied entry told CBP that they had seen the video while in the 
waiting room and that they still intended to work despite its 
warnings! 
 
71.(SBU)The video's debut launched an active, ongoing campaign by 
FPU to educate post-army Israelis about how to work legally in the 
United States.  The video was publicized on national radio, leading 
to a spate of national media articles on Israelis working in the 
United States.  In November, Channel 2, a key TV channel, picked up 
on this issue and invited two Israelis who had been denied entry to 
tell their stories in a live, five minute segment.  The moral: the 
consequences (barred from entering the United States for at least 
five years) are not worth the illegal work.  Right after their TV 
segment aired, FPU and ARSO-I met with one of these two Israelis. 
This meeting was an eye-opener, for we learned more about how young 
Israelis lie in their visa interviews.  FPU is currently scheduling 
additional individual meetings with I275ers to glean more 
information on how they succeeded in obtaining B1B2s when their true 
intent was to work.  As a counterfoil to meetings with I275ers, FPU 
has requested through ARSO-I to meet with several Embassy local 
guard force (LGF) staff, who also belong to this problematic age 
group; the RSO's office is currently reviewing this request. 
 
72.(SBU)Post has had positive results from its campaign against 
illegal work.  FPU has received e-mails from numerous Israelis 
inquiring as to whether the work opportunities that they have been 
given are legal or not; most have not been.  Also, we have received 
e-mail from informants, one of whom may crack a high-profile Dead 
Sea company wide open.  Still others have e-mailed to let us know 
they had quit their H2B jobs as they either didn't like the work or 
suspected the employer was not legitimate.  ARSO-I and FPU have 
followed up on every email and contact in the attempt to glean as 
much information as possible from those actually recruited by or 
working for these companies. 
 
73.(SBU)Phase II of the campaign is about to commence.  Included in 
this phase is the production of a second video.  Instead of having 
the Embassy produce, it will be produced by a group of students from 
a noted Israeli film school.  These students are in the same age 
demographic as Dead Sea workers, and, because of this, we hope this 
video will resonate even more strongly with post-army Israelis.  The 
November and December 2009 arrests of Israelis working at kiosks in 
Houston and Seattle also will reinforce the video's message. 
 
74.(SBU) As in phase I, Tel Aviv continues to work with our Public 
Diplomacy colleagues to alert Israelis to the consequences of 
working illegally via mainstream media outreach.  Thus far, several 
articles have been published and received wide distribution. 
Previously, journalists from papers such as the Wall Street Journal 
have reported on this industry (and quoted illegal Israelis); 
additional, mass-audience articles should also help push this 
campaign forward. 
 
-------------------------------------- 
New Mailing Address for Official Mail 
-------------------------------------- 
75.(SBU) The Department of State and the U.S. Postal Service (USPS) 
changed the unclassified Diplomatic Pouch regulations for sending 
and receiving official mail.  No longer are we to use the Diplomatic 
Post Office (DPO/APO) for sending and receiving official mail.  All 
official mail sent to Tel Aviv should use this Diplomatic Pouch 
address: 
 
Wendy Vincent, Fraud Prevention Manager 
Consular Section 
9700 Tel Aviv Place 
Department of State 
Washington, DC  20521-9700 
For security reasons, please do not write "U.S. Embassy Tel Aviv." 
For those who prefer to use express mail: 
 
Wendy Vincent, CONS 
71 Hayarkon Street 
Tel Aviv, Israel 63903 
 
 
----------- 
Conclusion 
----------- 
76.(SBU) The Dead Sea industry is continually adapting to new 
economic opportunities in addition to playing their corporate 
"games."  Prior to the establishment of the Dead Sea industry, 
Israelis were known to work illegally for moving companies.  Though 
not as widespread as the Dead Sea industry, as mentioned in reftel 
A, B1B2 locksmiths also are of concern.  Tel Aviv's dedicated, 
motivated fraud team and ARSO-I are working hard to stay on top of 
fraud trends--it is not easy.  Tel Aviv greatly appreciates its 
close ties with numerous DHS agencies and officers--together we form 
part of the "global" effort to combat fraud within this 
fraud-riddled industry.  As part of these closer ties, we thank 
those CBP and USCIS officers who contributed important text and 
statistics to this cable.  For future fraud efforts on this issue, 
Tel Aviv looks forward to working with additional partners from the 
law enforcement community. 
 
77.(SBU)Tel Aviv's FPM, Wendy Vincent, looks forward to hearing from 
others who have been working on Dead Sea industry fraud and is 
willing to share information accordingly.  As mentioned above, she 
maintains a distribution list for Tel Aviv's ad-hoc e-mails on Dead 
Sea trends, issues and data updates to her extensive Excel document 
on the Dead Sea industry.  Should you wish to join this 
e-distribution list or establish contact with Tel Aviv, please 
e-m