UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

IN RE: ALL ASSETS HELD IN ACCOUNT JW3083094 IN THE NAME OF No. 25-mc-96-TSC-MJS CARINALLI, S.A. AT JEFFERIES, LLC, et al.

MEMORANDUM OPINION

The United States applied for a restraining order under

(d)(3) to preserve

assets held in U.S. bank accounts in the names of Respondents Sara Silvia Goldring Waisbiot

(“Goldring”), her business partners, and her businesses, that may be subject to forfeiture in

Uruguayan criminal proceedings. See Appl. at 2−4, ECF No. 1. The Uruguayan proceedings

involved allegations that Goldring misappropriated and fraudulently managed client accounts and

investments through brokerage companies she controlled, resulting in millions of dollars of losses

to her clients. See

. In December 2022, a Uruguayan court ordered restraint of assets in

several of Respondents’ U.S. bank accounts and requested the United States’ assistance in

enforcing its orders. See

at 2−3. In June 2025, the Attorney General’s designee, the Chief of

the Money Laundering and Asset Recovery Section, found it in the interest of justice to certify the

Uruguayan restraining orders for enforcement. See

;

(b)(2),

(d)(3)(B)(ii).

The court referred the case to a Magistrate Judge for full case management up to and

including issuance of a Report and Recommendation on any dispositive issues. July 23, 2025 Min.

Order. The case was assigned to Magistrate Judge Sharbaugh, and on October 6, 2025, he issued

a Report and Recommendation recommending that the court grant the Government’s Application

and enter the requested restraining order. R. & R. at 22, ECF No. 14.

Page 1 of 5 Respondents timely objected to the Report. Objs., ECF No. 16. Having considered the

parties’ briefing on the Government’s application for a restraining order, the Report and

Recommendation, Respondents’ objections, the Government’s response, and the record, the court

adopts in full the Report’s recommendations.

I. LEGAL STANDARD

“District courts must apply a de novo standard of review when considering objections to,

or adoption of, a magistrate judge’s Report and Recommendation.” Means v. District of

Columbia,

(D.D.C. 2013). The court may then “accept, reject, or modify

the recommended disposition; receive further evidence; or return the matter to the magistrate judge

with instructions.” Fed. R. Civ. P. 72(b)(3); see

(b).

Five criteria must be met for a court to enforce a foreign restraining order: (1) the United

States and the foreign government that issued the restraining order must be parties to a formal

international agreement providing for mutual forfeiture assistance,

(a)(1); (2) the

Attorney General or her designee must certify that it is in the interest of justice to enforce the

foreign order, see

§ 2467(b)(2); (3) the foreign order must be issued in a manner consistent with

due process, see id. §§ 2467(d)(1)(A), (d)(3)(A)(ii); (4) the foreign court must have subject matter

jurisdiction, see id. §§ 2467(d)(1)(C), (d)(3)(A)(ii); and (5) the foreign order must not be

fraudulently obtained, see id. §§ 2467(d)(1)(E), (d)(3)(A)(ii).

II. ANALYSIS

Respondents do not challenge the Report’s determination that the Government has satisfied

the statutory criteria listed above or its rejection of their constitutional claims. See R. & R. at 6−9,

20−21. Respondents also omit any challenge to the Report’s rejection of a “dual forfeitability”

requirement—i.e., that the foreign-law violation must also trigger forfeiture under U.S. law—

Page 2 of 5 under § 2467(d)(3), or its conclusion that even if such a requirement applied, it would be satisfied

because the underlying conduct would satisfy the elements of wire and securities fraud. Id. at

12−17. Having considered the relevant materials, the court adopts the Report’s recommendation

as to those issues. Respondents raise two main objections to the Report: they argue “that the

Application impermissibly seeks to enforce a foreign restitution order” and “that the government

failed to show . . . that the proceeds of a crime can be traced to the Subject Accounts.” Objections

at 2. Judge Sharbaugh addressed and rejected each argument in his Report, and reviewing them

de novo, the court concurs with the Report.

First, Respondents argue that the Application impermissibly seeks to enforce a foreign

restitution order as opposed to a forfeiture order. Objections at 3. But as the Report notes, and as

Respondents concede, Respondents forfeited this argument by raising it for the first time at oral

argument before Judge Sharbaugh. See R. & R. at 9; Objs. at 19; U.S. ex rel. Davis v. D.C.,

(D.C. Cir. 2015). Respondents’ contention that they “did not realize it was a distinct

argument” until reading portions of “the English translations of Uruguayan Criminal Procedure

Code,” Objections at 20, does not provide sufficient “explanation, much less exceptional

circumstances, to excuse [their] failure to” raise the argument, Davis,

. As Judge

Sharbaugh explained, “the factual predicate for this point—whether the underlying foreign orders

were aimed at restitution or forfeiture—was plainly apparent to Respondents when they filed their

brief.” R. & R. at 10. Raising the argument in their Objections to the Report does not cure their

failure to preserve it before Judge Sharbaugh. See Taylor v. D.C.,

, 89 (D.D.C.

2016) (“[F]ailure to present an argument to the Magistrate Judge constitutes a waiver of that

argument.”); Brown v. D.C.,

(D.D.C. 2018) (explaining that “objections

cannot ‘present new initiatives’ that were not put before the magistrate judge” (quoting Taylor,

Page 3 of 5 205 F.Supp.3d at 79)); Bulovic v. Kijakazi,

, at *3 (D.D.C. Nov. 27, 2023)

(holding argument forfeited when raised for first time in reply brief before Magistrate Judge).

Accordingly, the court declines to consider this argument.

Second, Respondents argue that under Luan v. United States,

(D.C. Cir.

2013), the Government must show that the U.S. bank accounts at issue contain the proceeds of a

crime. See Objs. at 23; Opp’n to Appl. at 22–23, ECF No. 5. In Luan, the D.C. Circuit held that

a federal court may issue a restraining order under § 2467(d)(3) when, among other requirements,

“the property to be restrained represents the suspected proceeds of a ‘violation of foreign law.’”

Luan,

(quoting

(a)(2)(A)). The court agrees with the Report that

reading Luan to adopt a traceability requirement “simply reaches too far,” especially given that the

Luan court “did not limit the permissible scope of a restraining order under Section 2467(d)(3)

based on traceability to specific assets.” R. & R. at 19 n.11; see Resp. to Objs. at 24, ECF No. 17

(distinguishing property that “‘represents’” the “‘suspected proceeds’” from “actual proven

criminal proceeds” and arguing that Respondents’ U.S. bank accounts “‘represent[] suspected

proceeds’ . . . because they are named as the subject assets in the restraining orders entered by the

Uruguay Court and are subject to forfeiture under Uruguayan law upon Ms. Goldring’s conviction”

(emphasis in original) (quoting Luan,

)). Respondents’ reliance on email

correspondence from Jesse Ormsby, a DOJ prosecutor, see Objs. at 24; ECF No. 5-23 at 2, merely

distracts from the “the salient question,” which is “whether Uruguayan law permits forfeiture

absent tracing, and Respondents present no argument—let alone authority—to suggest that it does

not,” R. & R. at 18 (emphasis added).

III. CONCLUSION

For the reasons stated above, the court ADOPTS the report and ACCEPTS the

Page 4 of 5 recommendations of the Magistrate Judge. ECF No. 14. Accordingly, the court GRANTS the

Government’s Application. ECF No. 1. A separate restraining order will accompany this

Memorandum Opinion.

Date: December 17, 2025

Tanya S. Chutkan TANYA S. CHUTKAN United States District Judge

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