A U.S. judge has approved an asset freeze tied to alleged client-account mismanagement that left clients with millions of dollars in losses.
The dispute arises from assets held in U.S. bank accounts in the names of Sara Silvia Goldring Waisbiot, her business partners, and her businesses, including an account identified as JW3083094 in the name of Carinalli, S.A. at Jefferies, LLC. The United States applied for a restraining order under 28 U.S.C. § 2467(d)(3) to preserve those assets because they may be subject to forfeiture in criminal proceedings in Uruguay.
In those proceedings, Uruguayan authorities allege 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. In December 2022, a Uruguayan court ordered the restraint of assets in several of the respondents’ U.S. bank accounts and requested the assistance of the United States in enforcing its orders.
The application was filed in the United States District Court for the District of Columbia. In June 2025, the Attorney General’s designee, the Chief of the Money Laundering and Asset Recovery Section, determined that it was in the interest of justice to certify the Uruguayan restraining orders for enforcement, consistent with 28 U.S.C. §§ 2467(b)(2) and (d)(3)(B)(ii).
The district court referred the case to a magistrate judge for full case management. On October 6, 2025, Magistrate Judge Sharbaugh issued a Report and Recommendation advising that the court grant the government’s application and enter the requested restraining order. He concluded that the statutory criteria for enforcing a foreign restraining order were met and rejected the respondents’ constitutional claims. He also rejected a proposed “dual forfeitability” requirement and found that, even if such a requirement applied, the underlying conduct would satisfy the elements of wire and securities fraud.
Respondents did not challenge those determinations. Instead, as the district court summarized, they raised two main objections to the Report and Recommendation. First, they argued that the application impermissibly sought to enforce a foreign restitution order rather than a forfeiture order. Second, they argued that the government had not shown that the proceeds of a crime could be traced to the U.S. accounts at issue, relying on the D.C. Circuit’s decision in Luan v. United States.
On the first issue, U.S. District Judge Tanya S. Chutkan held that respondents had forfeited the argument. The opinion notes that they raised this contention for the first time at oral argument before Magistrate Judge Sharbaugh, not in their briefing, even though the factual predicate – whether the foreign orders were aimed at restitution or forfeiture – was “plainly apparent” when they filed their submissions. Citing D.C. precedent, the court treated the argument as waived and declined to consider it.
On the tracing issue, the court rejected respondents’ reading of Luan. The D.C. Circuit in Luan held that a court may issue a restraining order under § 2467(d)(3) when, among other requirements, the property to be restrained represents suspected proceeds of a violation of foreign law. Judge Chutkan agreed with the magistrate judge that interpreting Luan to impose a strict traceability requirement “simply reaches too far,” and pointed out that Luan did not limit the permissible scope of a restraining order under § 2467(d)(3) based on tracing specific assets.
The government argued that the respondents’ U.S. bank accounts represented suspected proceeds because they were named as the subject assets in the restraining orders entered by the Uruguayan court and were subject to forfeiture under Uruguayan law upon Goldring’s conviction. The district court described the “salient question” as whether Uruguayan law permits forfeiture absent tracing and observed that respondents had offered no argument or authority suggesting that it does not.
Having found no basis to disturb the magistrate judge’s analysis, the court adopted the Report and Recommendation in full. In a memorandum opinion dated December 17, 2025, Judge Chutkan granted the government’s application for a restraining order. She stated that a separate restraining order would accompany the opinion, granting the relief requested to preserve the identified U.S. accounts linked to Goldring, her partners, and her businesses in connection with the Uruguayan criminal proceedings.
For investment professionals, this ruling is a reminder that cross‑border cooperation on suspected client-fund misconduct can have real consequences. When foreign prosecutors pursue alleged misappropriation involving brokerage structures, U.S. courts may act to restrain assets in domestic accounts before any conviction overseas. That kind of coordination is a meaningful factor for firms that handle client money across jurisdictions.
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