This past year has seen an explosion of seizures of bank accounts by the Drug Enforcement Administration (DEA) and the U.S. Immigration and Customs Enforcement (ICE) or Homeland Security Investigations (HSI) for alleged trade-based, money laundering or "structuring" deposits of cash into one or more bank accounts. The funds in the bank accounts are taken when the bank is served with a Seizure Warrant signed by a Federal Court Magistrate Judge, based upon an affidavit prepared by the DEA or ICE Agent. The Seizure Warrant itself typically alleges that the money is subject to seizure because is it the proceeds of drug activity in violation of 21 U.S.C. 881 and 18 U.S.C. 1956.