· NextMigrate Team
Notario Fraud: How Fake Immigration Lawyers Get You Deported
Notario fraud is when someone who is not a lawyer, often a notary public calling themselves a "notario público", takes money to give immigration advice or file immigration papers they are not allowed to handle. USCIS puts it plainly: "A notario público is not authorized to provide you with any legal services related to immigration" (USCIS, updated 4 August 2026). The damage goes far beyond lost fees. In September 2025 a San Francisco court ordered notary Leonard Lacayo to pay over $600,000 after finding he kept providing immigration services in breach of a 2017 court order (San Francisco City Attorney, 23 September 2025). And in February 2025 a disbarred Bronx lawyer was sentenced to 70 months in prison after filing thousands of immigration documents that falsely said his clients had been abused, often without telling them (US Attorney, SDNY, 26 February 2025).
That is the short answer. If someone who is not a licensed attorney or an accredited representative is handling your case, read the rest before you sign anything else.
Imagine you are a builder in Houston. You came from Guatemala eleven years ago. Your daughter was born here. A friend tells you about an office on the corner with a sign: "Notario Público. Inmigración. Taxes." The man inside speaks your language and knows your town. He says there is a law: after ten years in the country, with an American child, you can get a work permit and then a green card. The fee is $4,000. You pay in cash.
He gives you a form to sign. It is in English. He says it is the application for the work permit.
Months later a letter arrives. You missed an interview you never knew about. Then a notice to appear in immigration court. The form you signed was an asylum application. You never asked for asylum. Now a judge will decide if you can stay.
That story is not one person's case. It is a pattern the US Justice Department's immigration courts have warned about by name. This page explains how notario fraud works, what courts and regulators have found in named cases, who is allowed to help you, and how to check and report.
Key facts about notario fraud
| What a notary public can do in the US | Witness signatures and administer oaths. Notaries "are not authorized to provide legal services" (USCIS, 4 August 2026) |
| Who can represent you | A licensed attorney in good standing, or an accredited representative working for a Justice Department recognized organization (USCIS, Legal Services, updated 4 August 2026) |
| The "10-year green card" scam | Clients sign what they think is a work permit form. It is an asylum application, and they end up in removal proceedings (EOIR Fraud and Abuse Prevention Program) |
| Named case: notary | Leonard Lacayo, San Francisco: $503,500 in civil penalties plus $110,581 in fees, September 2025, after violating a 2017 injunction |
| Named case: lawyer | Kofi Amankwaa, Bronx: 70 months in prison, $13.4 million forfeiture and $16.5 million restitution agreed, February 2025 |
| Named case: copycat sites | Forms Direct, also called American Immigration Center: $2.2 million FTC settlement over websites that looked like government sites (FTC, 16 October 2018) |
| Where to report | EOIR Fraud Program (EOIR.Fraud.Program@usdoj.gov), the FTC, your state attorney general, and USCIS for fraud in USCIS filings |
Notario or notary? The word that does the damage
In much of Latin America, a notario is a senior legal professional. USCIS explains: "In many Spanish-speaking nations, 'notarios' are attorneys with special legal credentials. In the United States, however, notary publics are not authorized to provide legal services; they are authorized by state governments to witness the signing of important documents and to administer oaths."
So a sign that says "Notario Público" means one thing to a person who grew up in Mexico or El Salvador, and something very different under US law. Fraudsters use that gap.
Some states have made the word itself illegal for notaries who are not lawyers. In Virginia, a notary "shall not assume, use, or advertise the title of 'notario,' 'notario publico,' or 'licenciado'" unless licensed to practice law in the state, and must not give immigration advice unless licensed or accredited (Code of Virginia § 47.1-15.1, 2026 update). The Virginia Attorney General's office says this has been illegal "since 2014" (Virginia Attorney General, 2026).
Three documented cases, and what each one teaches
1. The notary who would not stop: Leonard Lacayo, San Francisco
According to the San Francisco City Attorney, Lacayo & Associates has operated in the city since 1986. "Leonard Lacayo is a notary public, but has never been licensed to practice law nor registered with the state as an immigration consultant. For years, Lacayo had falsely portrayed himself as an attorney and either provided services he was not qualified to provide or simply failed to provide any service at all" (San Francisco City Attorney, 23 September 2025).
The legal record, step by step:
- 2017. The City secured an injunction banning Lacayo and his firm from providing immigration-related services. He was ordered to pay restitution and civil penalties.
- 2022. A court found he had violated the injunction, extended it by five years and fined him $5,000.
- After 2022. The City's investigation found he kept meeting clients and offering immigration services "through attorneys and consultants embedded within his office." The State Bar of California sent him three cease and desist letters.
- 19 September 2025. The court granted the City's motion again. Its order says: "Defendant's conduct is egregious and ongoing and more restrained corrective actions have not been effective." It imposed $500 a day in penalties, $503,500 in total, plus $110,581 in attorney's fees, and extended the injunction to September 2032.
The City Attorney's release does not include a response from Lacayo.
The lesson. A court order does not make a notario disappear. The same office, the same sign and the same friendly manner can keep going for years. You have to check the person yourself, every time.
2. The licensed lawyer who filed false abuse claims: Kofi Amankwaa, the Bronx
Notario fraud is not only about notaries. The most damaging case of recent years involved a man who was a licensed attorney.
According to federal prosecutors, from September 2016 to November 2023 Kofi Amankwaa and people working for him "instructed [clients] to sign fraudulent Form I-360 VAWA Petitions falsely stating that the clients were abused by their U.S. citizen children." VAWA, the Violence Against Women Act, gives real abuse victims a path to a green card. He then used those filings to get travel permits and green card applications for clients. He typically charged "between $3,000 and $6,000" plus fees (US Attorney, SDNY, 26 February 2025).
The prosecutor said Amankwaa "repeatedly filed these false applications without telling his clients that he was doing so." Many applications were "denied on the basis of fraud." New York Attorney General Letitia James, who filed a parallel civil suit the day he was charged, said: "This cruel and illegal scheme led to them being separated from their families and deported" (New York Attorney General, 22 January 2024). The AG's suit also alleged that a person working with the firm claimed to be an attorney when she was not.
The outcome: his New York law license was suspended in November 2023 and he was disbarred in August 2024. He pleaded guilty to immigration fraud on 17 September 2024. On 26 February 2025 he was sentenced to 70 months in prison, ordered to forfeit $13,389,000, and had agreed to pay $16,503,425 in restitution to victims.
The lesson. A license is the first check, not the last. Ask to see every form before it is filed, read the basis of your application, and keep copies. A real lawyer will explain what you are claiming and why.
3. The websites that looked like the government: Forms Direct
Some notario-style fraud happens online. In 2018 the FTC settled with Forms Direct, Inc., also known as American Immigration Center. According to the FTC, it ran websites with names like "us-immigration.com" and "uscitizenship.info", showed American flags and the Statue of Liberty, and used search ads that showed the name "USCIS". It charged $120 to $300 to help file forms (FTC, 16 October 2018).
"But these were not government websites. Fees went directly to the company. Plus, you still had to pay the government filing fees." Under the settlement, the company had to say clearly that it is not affiliated with the government, and pay $2.2 million to go back to consumers.
The lesson. USCIS forms are free. If a site charges you for a blank form, or for "processing" before the government fee, you are paying a middleman.
The "10-year green card" trick, step by step
The Justice Department's immigration court system, EOIR, describes this scam on its fraud page:
- The pitch. Someone says they "can get work authorization for them because the individual has been in the United States for ten years or because the individual has a United States citizen child or spouse."
- The signature. The client is "asked to sign a form" and "is not told that this form is really the signature page for an asylum application."
- The missed interview. "When the individual does not appear for their asylum interview before the Asylum Office, the individual is placed into removal proceedings before the immigration court."
- The switch. "Sometimes, the attorney will then withdraw the asylum application and file for a form of relief called Cancellation of Removal for Non-Lawful Permanent Residents."
Cancellation of removal is a real form of relief, but it is decided by a judge in deportation proceedings, and it is hard to win. A person who had no case open with the government now has a deportation case. That is why notario fraud can end in deportation even when the client did nothing but trust the wrong person.
EOIR lists two other tricks it has seen: practitioners who take the filing fee, file a fee waiver without telling the client and keep the money, and people who sell EOIR and USCIS forms that are free online.
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Who is allowed to help you with US immigration?
| Person | Can they give legal advice and represent you? | How to check |
|---|---|---|
| Licensed attorney in good standing | Yes | Your state bar's lawyer search, and EOIR's list of disciplined practitioners |
| Accredited representative at a recognized organization | Yes | EOIR's Recognition and Accreditation roster |
| Supervised law student or graduate | Yes, under a supervising attorney or accredited representative who files Form G-28 | Ask who the supervisor is, then check them |
| Notary public | No. Can witness signatures and give oaths | State notary rules |
| Immigration consultant, "form preparer", travel agent | No legal advice. May give "limited help filling out USCIS forms" for a "nominal fee", depending on state law (USCIS) | Your state's consumer protection rules |
| Friend or relative | Can help you fill in forms, but cannot represent you | Not applicable |
Source: USCIS Legal Services page, updated 4 August 2026.
How to check your helper in ten minutes
- Ask the question directly. "Are you a licensed attorney, or an accredited representative? In which state, or for which organization?" A real one will answer at once.
- Look them up. For an attorney, search the state bar named on their card. For an accredited representative, search the EOIR roster. Then check EOIR's list of disciplined practitioners.
- Ask for Form G-28. A representative before USCIS must file a G-28, which you sign. If they will not put their name on your case, ask why.
- Read before you sign. USCIS says: "Do not sign a blank form" and "Do not sign any forms that have false information."
- Get copies and receipts. Keep a copy of every form, every receipt and every notice. Ask for your USCIS receipt numbers so you can track the case yourself.
- Ask what you are claiming. Every application is based on facts about you. If you cannot explain the facts in your own application, you are not ready to sign.
If a notario has already filed something for you
- Find out what was filed. Ask the notario for copies of everything. Use your receipt numbers to check case status with USCIS. If you got a court notice, check your case with the immigration court.
- See a real attorney or accredited representative quickly. Deadlines in immigration court are strict. EOIR publishes a list of pro bono legal service providers, and many recognized organizations have accredited representatives.
- Do not ignore a notice to appear. Missing a court date can lead to an order of removal.
- Keep your evidence. Receipts, texts, business cards, photos of the office sign, and the names of anyone else who used the same office.
Our guide to when you need an immigration lawyer, not a consultant explains which situations need a lawyer at once, and an agent took your money covers getting money back.
How to report notario fraud
- EOIR Fraud and Abuse Prevention Program: email EOIR.Fraud.Program@usdoj.gov. It takes complaints about "fraud, immigration scams, and the unauthorized practice of immigration law (frequently committed by notarios, immigration consultants, or so-called 'travel agents')."
- USCIS: for fraud in applications filed with USCIS, use the USCIS tip form (EOIR).
- Federal Trade Commission: the FTC asks people who spot an immigration scam to "report it to the FTC or the Attorney General in your state" (FTC, 16 October 2018).
- Your state attorney general or city attorney. The Lacayo case came from the San Francisco City Attorney. From 1 July 2026, the Virginia Attorney General can issue civil investigative demands in notario cases, with civil penalties increased "by five times", injunctions and restitution (Virginia Attorney General, 2026).
Reporting a fraudster is not the same as confessing to immigration fraud yourself. If you are worried about your own status, talk to an attorney or accredited representative before you report, and ask them to help.
Red flags you can spot from the street
| Red flag | Why it matters |
|---|---|
| A sign that says "Notario Público" next to "Inmigración" | Notaries cannot give immigration advice (USCIS) |
| "There is a new law" or "a special program" only they know about | Real programs are on uscis.gov |
| "After ten years you can get papers" | The exact pitch in EOIR's 10-year green card warning |
| A form in English they will not explain | You may be signing an asylum or other application you never chose |
| They keep your original passport or documents | You need them, and you lose control of your case |
| No receipts, no copies, cash only | You cannot prove what you paid or what was filed |
| They promise a result | Only the government decides |
| They charge for blank forms | USCIS forms are free |
The honest lesson
The people hurt by notario fraud usually did the responsible thing. They went to someone who spoke their language, was recommended by family, and had an office and a sign. That trust is exactly what notarios sell.
The fix is simple and a little uncomfortable: ask for proof. A license number, an accreditation, a G-28, a copy of every page. Honest helpers expect those questions. Notarios avoid them.
We are not lawyers either, and we do not file US immigration cases. If you are in the US and in proceedings, you need an attorney or an accredited representative. If you are still deciding where to move, our tools and guides can help you compare routes before anyone takes your money. For the same scam in other countries, see ghost consultants and how to check a migration agent is licensed.
Frequently asked questions
What is notario fraud?
Notario fraud is when a notary public, consultant or other unlicensed person takes money to give immigration legal advice or prepare immigration applications they are not authorized to handle. USCIS says a notario público "is not authorized to provide you with any legal services related to immigration." It often leads to lost money, missed deadlines or false applications.
Can a notario help with immigration in the US?
No. In the US, notaries can witness signatures and administer oaths. Only a licensed attorney, an accredited representative at a recognized organization, or a supervised law student can give you immigration legal advice and represent you. Others may only give limited help filling in forms for a nominal fee, depending on state law.
How do I report notario fraud?
Email the Justice Department's EOIR Fraud and Abuse Prevention Program at EOIR.Fraud.Program@usdoj.gov, report to the FTC, and contact your state attorney general. Use the USCIS tip form for fraud in USCIS filings. Keep receipts, messages and copies of anything filed in your name.
What is the 10-year green card scam?
EOIR describes it on its fraud page. Someone promises a work permit because you have lived in the US for ten years or have a US citizen child. You sign a form that is really an asylum application. When you miss the asylum interview you never knew about, you are placed in removal proceedings before an immigration judge.
How can I check if an immigration lawyer is real?
Ask which state bar licensed them, then search that bar's lawyer directory. Check EOIR's list of disciplined practitioners. For a non-lawyer, ask for their organization and search EOIR's roster of accredited representatives. A real representative files Form G-28 with your case and gives you copies of everything.
Can I get deported because of a notario?
It can happen. Under the scheme EOIR describes, an unauthorized asylum filing can put you into removal proceedings. In the Amankwaa case, New York's attorney general said clients were "separated from their families and deported" after false filings. If you got a court notice, see an attorney or accredited representative right away.
Can I get my money back from a notario?
Sometimes. Courts can order restitution, as in the Lacayo injunction in 2017 and the $16.5 million Amankwaa restitution agreement. Report the case to your state attorney general, keep every receipt, and ask a legal aid organization about small claims or other options.
Is a "licenciado" a lawyer in the US?
Not necessarily. In the US, only a license from a state bar lets someone practice law, whatever title is on the sign. Virginia law treats "licenciado" as a title that suggests legal authority, and bans notaries from using it, or "notario" and "notario publico", unless they are licensed to practice law in the state. Ask for the bar number and check it.
