Thursday, June 26, 2025

An Outrage of the Day -- Financial Crimes

June 30, 2025

The Justice Department today announced the results of its 2025 National Health Care Fraud Takedown, which resulted in criminal charges against 324 defendants, including 96 doctors, nurse practitioners, pharmacists, and other licensed medical professionals, in 50 federal districts and 12 State Attorneys General’s Offices across the United States, for their alleged participation in various health care fraud schemes involving over $14.6 billion in intended loss. The Takedown involved federal and state law enforcement agencies across the country and represents an unprecedented effort to combat health care fraud schemes that exploit patients and taxpayers.

Demonstrating the significant return on investment that results from health care fraud enforcement efforts, the government seized over $245 million in cash, luxury vehicles, cryptocurrency, and other assets as part of the coordinated enforcement efforts. As part of the whole-of-government approach to combating health care fraud announced today, the Centers for Medicare and Medicaid Services (CMS) also announced that it successfully prevented over $4 billion from being paid in response to false and fraudulent claims and that it suspended or revoked the billing privileges of 205 providers in the months leading up to the Takedown. Civil charges against 20 defendants for $14.2 million in alleged fraud, as well as civil settlements with 106 defendants totaling $34.3 million, were also announced as part of the Takedown.

Today’s Takedown was led and coordinated by the Health Care Fraud Unit of the Department of Justice Criminal Division’s Fraud Section and its core partners from U.S. Attorneys’ Offices, the Department of Health and Human Services Office of Inspector General (HHS-OIG), the Federal Bureau of Investigation (FBI), and the Drug Enforcement Administration (DEA). The cases were investigated by agents from HHS-OIG, FBI, DEA, and other federal and state law enforcement agencies. The cases are being prosecuted by Health Care Fraud Strike Force teams from the Criminal Division’s Fraud Section, 50 U.S. Attorneys’ Offices nationwide, and 12 State Attorneys General Offices.

https://www.justice.gov/opa/pr/national-health-care-fraud-takedown-results-324-defendants-charged-connection-over-146

June 26, 2025

Twenty-five years ago, Leo J. Govoni of Clearwater, Fla., co-founded a nonprofit organization meant to help people with special needs manage their funds. But he and an accountant were using it as a “personal piggy bank” to steal more than $100 million, federal prosecutors said on Monday.

Mr. Govoni is accused of using some of the money to fund a brewery, to travel by private jet, to buy real estate and to pay personal debts, the U.S. Attorney’s Office for the Middle District of Florida said in a statement.

In an indictment unsealed on Monday, Mr. Govoni, 67, and the accountant, John L. Witeck, 60, Tampa, Fla., were each charged with one count of conspiracy to commit wire and mail fraud, three counts of mail fraud, six counts of wire fraud and one count of conspiracy to commit money laundering.

Mr. Govoni was also charged with one count of bank fraud, one count of illegal monetary transactions and one count of making a false bankruptcy declaration. Court documents say others were also involved in the scheme.

Big Storm Brewery in Clearwater, Fla., received the stolen money to cover operating and expansion costs, according to the indictment. Mr. Govoni and some of the others controlled a small aviation company that had at least one private jet and that was funded by stolen money, court records said.

Prosecutors said Mr. Govoni had taken out a $3 million mortgage refinance loan and laundered about $205,000 in fraud proceeds to pay off a home equity line of credit on his residence.  The theft eventually led the nonprofit, the Center for Special Needs Trust Administration, to declare bankruptcy, federal prosecutors said.

“The subjects charged are accused of creating a slush fund to divert millions of dollars away from a nonprofit organization helping people with special needs,” Jose A. Perez, the assistant director for the F.B.I.’s criminal investigation division, said in the statement. “Not only were the organization’s resources drained, but the accused subjects betrayed the trust of the community .

 https://www.nytimes.com/2025/06/23/us/politics/florida-nonprofit-millions-stolen.htmlAdver


June 12, 2025

Four men, including a government contracting officer for the United States Agency for International Development (USAID) and three owners and presidents of companies, have pleaded guilty for their roles in a decade-long bribery scheme involving at least 14 prime contracts worth over $550 million in U.S. taxpayer dollars.

  • Roderick Watson, 57, of Woodstock, Maryland, who worked as a USAID contracting officer, pleaded guilty to bribery of a public official;
  • Walter Barnes, 46, of Potomac, Maryland, who was the owner and president of PM Consulting Group LLC doing business as Vistant (Vistant), a certified small business under the U.S. Small Business Administration (SBA) 8(a) contracting program, pleaded guilty to conspiracy to commit bribery of a public official and securities fraud;
  • Darryl Britt, 64, of Myakka City, Florida, who was the owner and president of Apprio, Inc. (Apprio), a certified small business under the SBA 8(a) contracting program, pleaded guilty to conspiracy to commit bribery of a public official; and
  • Paul Young, 62, of Columbia, Maryland, who was the president of a subcontractor to Vistant and Apprio, pleaded guilty to conspiracy to commit bribery of a public official.

In addition, Apprio and Vistant, both of which contracted with USAID, have agreed to admit criminal liability and enter into three-year deferred prosecution agreements (DPAs) in connection with criminal informations filed today in the District of Maryland. As part of these resolutions, both Apprio and Vistant admitted to engaging in a conspiracy to commit bribery of a public official and securities fraud. The DPAs entered into with Apprio and Vistant require each company to, among other obligations, provide ongoing cooperation with and disclosures to the Justice Department, implement a compliance and ethics program, and report to Justice Department regarding remediation and implementation of these compliance measures.

“The defendants sought to enrich themselves at the expense of American taxpayers through bribery and fraud,” said Matthew R. Galeotti, Head of the Justice Department’s Criminal Division. “Their scheme violated the public trust by corrupting the federal government’s procurement process. Anybody who cares about good and effective government should be concerned about the waste, fraud, and abuse in government agencies, including USAID. Those who engage in bribery schemes to exploit the U.S. Small Business Administration’s vital economic programs for small businesses — whether individuals or corporations acting through them — will be held to account.” 

“Watson was entrusted to serve the interests of the American people — not his own — and his criminal actions for his own personal gain undermine the integrity of our public institutions,” said U.S. Attorney Kelly O. Hayes for the District of Maryland. “Public trust is a hallmark of our nation’s values, so corruption within a federal government agency is intolerable. This office, along with our law enforcement partners, will continue to pursue and prosecute corruption at every level to ensure accountability and protect public trust.”

“The guilty pleas reflect the FBI’s unwavering commitment to holding accountable all those who abuse the authority and responsibility of public service,” said Assistant Director Joe Perez of the FBI's Criminal Division. “The actions of the defendants in this scheme serve to erode public trust. The FBI is focused on rebuilding this trust and protecting American taxpayers from corruption through investigations such as these.”

“Corruption in government programs will not be tolerated. Watson abused his position of trust for personal gain while federal contractors engaged in a pay-to-play scheme,” said Acting Assistant Inspector General for Investigations Sean Bottary of the USAID Office of Inspector General (USAID-OIG). “USAID-OIG is firmly committed to rooting out fraud and corruption within U.S. foreign assistance programs. Today’s announcement underscores our unwavering focus on exposing criminal activity, including bribery schemes by those entrusted to faithfully award government contracts. We appreciate our longstanding partnership with the Department of Justice in holding accountable those who defraud American taxpayers.”    

“Watson exploited his position at USAID to line his pockets with bribes in exchange for more than $550 million in contracts. While he helped three company owners and presidents bypass the fair bidding process, he was showered with cash and lavish gifts,” said Chief Guy Ficco of IRS Criminal Investigation (IRS-CI). “Through its financial crime investigations, IRS-CI works to protect taxpayer dollars and ensure government funds are awarded based on merit — not corruption. In close coordination with our law enforcement partners, IRS-CI helped put an end to their greed and criminal conduct. Now, Watson and his co-conspirators will face justice.”

Overview of Bribery Scheme

According to court documents, beginning in 2013, Watson, while a USAID contracting officer, agreed with Britt to receive bribes in exchange for using Watson’s influence to award contracts to Apprio. As a certified small business under the SBA 8(a) contracting program, which helps socially and economically disadvantaged businesses, Apprio could access lucrative federal contracting opportunities through set-asides and sole-source contracts exclusively available to eligible contractors without a competitive bid process.

Vistant was a subcontractor to Apprio on one of the contracts awarded through Watson’s influence. After Apprio graduated from the SBA 8(a) program and it was no longer eligible to be a prime contractor for new contracts with USAID under this program, the scheme shifted so that Vistant became the prime contractor and Apprio became the subcontractor on USAID contracts awarded through Watson’s influence between 2018 and 2022.

During the scheme, Britt and Barnes paid bribes to Watson that were often concealed by passing them through Young, who was the president of another subcontractor to Apprio and Vistant. Britt and Barnes also regularly funneled bribes to Watson, including cash, laptops, thousands of dollars in tickets to a suite at an NBA game, a country club wedding, downpayments on two residential mortgages, cellular phones, and jobs for relatives. The bribes were also often concealed through electronic bank transfers falsely listing Watson on payroll, incorporated shell companies, and false invoices. Watson is alleged to have received bribes valued at more than approximately $1 million as part of the scheme.

In exchange for the bribe payments, Watson influenced the award of contracts to Apprio and Vistant by manipulating the procurement process at USAID through various means, including recommending their companies to other USAID decisionmakers for non-competitive contract awards, disclosing sensitive procurement information during the competitive bidding process, providing positive performance evaluations to a government agency, and approving decisions on the contracts, such as increased funding and a security clearance.

Apprio and Vistant also agreed to resolve concurrently with the Justice Department in its separate Civil False Claims Act investigations relating to the bribery scheme.

Overview of Vistant Securities Fraud Scheme

According to court documents, in 2022, Barnes and Watson defrauded a licensed small business investment company (SBIC), in furtherance of the bribery scheme, by inducing it into executing a credit agreement with Vistant. Through the credit agreement, Barnes caused Vistant to issue stock warrants that, if exercised, would result in the SBIC having a 40% equity stake in Vistant. The credit agreement also provided for a $14 million loan to Vistant from which Barnes could pay himself a $10 million dividend. Prior to executing the credit agreement, Watson agreed at Barnes’s request to speak with the SBIC about Vistant’s performance as a government contractor on USAID contracts. When speaking with the SBIC, Watson omitted that Barnes had bribed Watson to obtain USAID contracts for years. Watson’s endorsement of Vistant thereafter induced the SBIC to enter into the credit agreement with Barnes.

Overview of Apprio Securities Fraud Scheme

According to court documents, in 2023, Apprio, acting through Britt, engaged in a scheme in which Apprio fraudulently induced a private equity firm, which had an investment pool that was licensed as a SBIC, to purchase from Apprio’s parent company a 20% equity stake in the company for $4 million and simultaneously extend it a $4 million loan secured by shares of Apprio stock. In addition to making false material representations in the stock purchase and loan agreements, Britt intentionally omitted during his negotiations the material fact that he had bribed Watson for years, which was intended to deceive and induce the private equity company into executing the agreements.

https://www.justice.gov/opa/pr/usaid-official-and-three-corporate-executives-plead-guilty-decade-long-bribery-scheme

“Watson exploited his position at USAID to line his pockets with bribes in exchange for more than $550 million in contracts,” Guy Ficco of IRS Criminal Investigation said in a statement. “While he helped three company owners and presidents bypass the fair bidding process, he was showered with cash and lavish gifts.”

The scheme was possible because of the federal government’s racial “set-aside” laws known as 8(a) contracting, which allow contracting officers to give contracts to companies owned by minorities, women, or veterans without the usual competitive process.

Walter Barnes III, the founder of a Baltimore-area company predicated on taking advantage of those laws, admitted to paying bribes, including a country-club wedding, cash, and a trip to Martha’s Vineyard.


https://www.dailywire.com/news/usaid-official-three-contractors-plead-guilty-to-half-billion-dollar-bribery-scheme


Watson and Barnes



June 5, 2025

HOUSTON – A former Social Security employee has admitted to conspiracy and aggravated identity theft, announced U.S. Attorney Nicholas J. Ganjei. 

David Lam, 45, Pearland, was an operations supervisor and claims specialist for the Social Security Administration (SSA) office in Houston.

As part of his plea, Lam admitted to stealing the personally identifying information (PII) of recently deceased men and then using that PII to facilitate fraudulent benefits applications. 

Lam admitted to working with various coconspirators—typically, women with children—to file fraudulent survivor benefits applications listing the deceased men as the children’s fathers or stepfathers. If true, this would have entitled the women to receive benefits while raising their children as widows. However, the women had no connection to the men listed on the applications and the deceased men did not father the children. To facilitate his scheme, Lam would utilize the deceased men’s names, dates of birth and death and Social Security numbers. 

He would also instruct the coconspirators to split the stolen funds with him. The women would transfer funds via applications like Zelle, CashApp or Chime. Lam agreed to take responsibility for causing $3,346,280 in loss to the SSA and has agreed to pay that amount in restitution.   

U.S. District Judge Sim Lake will impose sentencing Sept. 12. At that time, Lam faces up to five years in federal prison for conspiracy to defraud the United States on the conspiracy charge and a $250,000 maximum fine. He will also face two years for aggravated identity theft which must run consecutively to any sentence imposed. 

https://oig.ssa.gov/news-releases/2025-06-06-social-security-employee-pleads-guilty-to-multimillion-dollar-fraud-scheme/


May 30, 2025 

(Again not quite an outrage but very aggravating)

Three men have entered guilty pleas in what the U.S. Attorney's Office has labeled a "classic insider trading scheme," involving the trading of Kaman Corp.'s securities based on confidential information about an upcoming acquisition. The individuals involved, Jonathan Whitesides, Daniel McCormick, and Brent Cranmer, utilized nonpublic information to make trades that would earn them over a million dollars in illegal profits, as stated by the U.S. Attorney for the Southern District of New York, Jay Clayton, in an announcement today.

The three defendants engaged in a classic insider trading scheme—buying call options on the stock of a company where insiders know the trading price is about to increase substantially, but the market does not know yet," Clayton said. This type of deception not only breaches the trust between a company and it's shareholders, but also undermines the fair playing field essential to the integrity of financial markets. Statements made in court proceedings outlined that Cranmer, an executive at a Kaman subsidiary, tipped off Whitesides about the acquisition, who then passed the information to McCormick, leading to strategic buying of call options and stocks prior to the public announcement, as per the U.S. Attorney for the Southern District of New York. 

May 23, 2025

(Again not quite an outrage but aggravating)

A North Carolina councilwoman and her two daughters were indicted Thursday and accused of defrauding COVID-19 relief programs to obtain over $124,000.  According to the United States Attorney's Office, a member of Charlotte City Council Tiawana Brown, 53; Tijema Brown, 30; and Antionette Rouse, 33, are charged with wire fraud conspiracy and wire fraud. All three allegedly conspired to execute a scheme to defraud the Small Business Administration's Economic Injury Disaster Loan (EIDL) program and the Paycheck Protection Program (PPP) to get COVID relief funds.

Brown was elected into office in 2023. These accusations stem from before she was elected.  Between April 2020 and September 2021, all three woman are accused of submitting loan applications with false information or fake documents, the United State Attorney's Office said, which includes fraudulent tax forms, to secure COVID relief funds for their businesses. It's also alleged that they submitted false statements to get their PPP loans forgiven. In total, they are said to have submitted at least 15 applications and fraudulently obtained $124,165 through this scheme.

Councilwoman Brown used $15,000 of those funds on a personal birthday party, according to the indictment.  Brown has already spent time in prison for fraud. She is the only person to have been elected to the Charlotte City Council with that background.  In a news conference on Thursday, ABC affiliate WSOC reported that Brown said this is an effort to stop her from getting reelected. Once she learned the feds were looking for her, she had already paid the money back.  "So, if it's about justice and I paid it back, why are we here? Why are we here? I paid it back on my own. No one had to tell me to do that," she said.  When asked about using the funds on a birthday party, Brown said: "I paid it back; the funds that I got were $20,833, and I paid it back."



https://abc11.com/post/tiawana-brown-north-carolina-councilwoman-2-daughters-indicted-allegedly-defrauding-covid-19-relief-programs-124k/16517610/

May 30, 2025 

(see Dec. 2024 for more info about the charges)

HARRISBURG — Attorney General Dave Sunday announced that the two leaders of a $12 million Medicaid Fraud scheme involving Broad Street Pharmacy in South Philadelphia have pleaded guilty and were sentenced this week to state prison.

An Office of Attorney General-led collaborative investigation resulted in prison sentences for Peter Dello Buono — who managed daily operations — and Frank Bengermino, the in-store pharmacist.

Dello Buono, 70, will serve 2 to 5 years in state prison; is prohibited from owning, operating or working at a pharmacy; and is excluded from the Medicaid and Medicare programs.

Bengermino, 70, will serve 1½ to 5 years in state prison, and abide by the same other conditions as Dello Buono.

The scheme was based on billing expensive medications to Medicaid and Medicare, even though very little of the medications were actually acquired and disbursed at the pharmacy.

https://www.attorneygeneral.gov/taking-action/ag-sunday-announces-guilty-pleas-in-12-million-medicaid-fraud-scheme-at-philadelphia-pharmacy-two-scheme-leaders-jailed/


Thompson and Dello Buono


May 22, 2025

(again not quite an outrage but aggravating)

An ex-cop in California collected $600,000 on full disability leave, all while living an active lifestyle that included multiple ski trips, a vacation to Disneyland, pursuing an advanced degree and partying at a music festival, prosecutors alleged.  Nicole Brown, 39, suffered a minor head abrasion during an arrest in 2022 and used the injury to take a several-year-long leave while partying it up — and now faces 15 felony charges for an alleged fraudulent worker’s compensation scheme, according to a release from the Orange County District Attorney’s Office.

While supposedly suffering from “post-concussion syndrome,” the former Westminster Police Department cop was spotted drinking and partying at the Stagecoach music festival, prosecutors said.


April 9, 2025

A Florida man was sentenced yesterday to 30 months in prison for evading more than $5.5 million in taxes, interest, and penalties that he owed the IRS.

According to court documents and statements made in court, David Albert Fletcher, of Deltona, owned and operated furniture liquidations businesses, including Century Liquidators. For tax years 2004 through 2013, Fletcher did not timely file his federal income tax returns or pay the taxes he owed. After an audit, the IRS assessed a total of $1.7 million in taxes, interest, and penalties against him.

To evade collection of these taxes, Fletcher concealed his income and assets from the IRS. For example, Fletcher used nominees to hide his purchases of luxury vehicles, including Rolls Royces. Fletcher also filed false income tax returns that understated his income by several million dollars, and when an IRS special agent interviewed him, Fletcher falsely represented the amount of income he earned.

In addition to his prison sentence, U.S. District Judge Wendy Berger for the Middle District of Florida ordered Fletcher to serve three years of supervised release and to pay approximately $7,112,689 in restitution to the United States.

https://www.justice.gov/opa/pr/florida-businessman-sentenced-prison-tax-evasion

December 19, 2024

HARRISBURG — Attorney General Michelle Henry announced charges against nine individuals regarding a $20 million Medicaid and Medicare fraud scheme stemming from a South Philadelphia neighborhood pharmacy.

Elizabeth Thompson, the registered owner of Broad Street Family Pharmacy, and her husband, Peter Dello Buono — who oversaw daily operations along with pharmacist Frank Bengermino — are charged with engineering the scheme, from 2016 to 2021, which involved fraudulent claims to the federal benefits programs for expensive medications. In reality, the pharmacy allegedly filled very few of the prescriptions and instead paid their customers cash in exchange for bringing their prescriptions to the pharmacy.

The conspiracy also involved paying kickbacks to consumers selling back pills to the pharmacy in exchange for cash and other medications.

The total amount of fraudulent claims — primarily for the antipsychotic, Latuda, and high-reimbursement HIV medications — exceeded $20 million.

“The owner and operator of this pharmacy were essentially pretending to fill prescriptions for expensive medications, while defrauding the Medicaid and Medicare programs of millions of dollars with a sophisticated scheme involving nearly a dozen co-conspirators,” Attorney General Henry said. “The alleged crimes involved here diverted funding from Pennsylvanians in need into the pockets of the defendants.”

The Fiftieth Statewide Investigating Grand Jury issued a presentment for the charges following a joint investigation conducted by the Pennsylvania Office of Attorney General Medicaid Fraud Control Section and the U.S. Department of Health and Human Services Office of Inspector General.

Charged are: Peter Dello Buono, 70; Elizabeth Thompson, 70; Frank Bengermino, 70; Berry Davis, 59; Brian O’Hara, 52; Michael McCue, 68 — all of Philadelphia; Christian Bengermino, 36, of Folsom; and Evan Gusz, 54, of Glenside, with Medicaid fraud, dealing in unlawful proceeds, theft by deception, conspiracy, and other offenses. Angelo Amorosi, 62, of Philadelphia, is charged with dealing in unlawful proceeds and conspiracy.

Oct 13, 2024 (but not posted until later)

WASHINGTON — TD Bank N.A. (TDBNA), the 10th largest bank in the United States, and its parent company TD Bank US Holding Company (TDBUSH) (together with TDBNA, TD Bank) pleaded guilty today and agreed to pay over $1.8 billion in penalties to resolve the Justice Department’s investigation into violations of the Bank Secrecy Act (BSA) and money laundering. 

TDBNA pleaded guilty to conspiring to fail to maintain an anti-money laundering (AML) program that complies with the BSA, fail to file accurate Currency Transaction Reports (CTRs), and launder money. TDBUSH pleaded guilty to causing TDBNA to fail to maintain an AML program that complies with the BSA and to fail to file accurate CTRs.

TD Bank’s guilty pleas are part of a coordinated resolution with the Board of Governors of the Federal Reserve Board (FRB), as well as the Treasury Department’s Office of the Comptroller of the Currency (OCC) and Financial Crimes Enforcement Network (FinCEN).

“By making its services convenient for criminals, TD Bank became one,” said Attorney General Merrick B. Garland. “Today, TD Bank also became the largest bank in U.S. history to plead guilty to Bank Secrecy Act program failures, and the first US bank in history to plead guilty to conspiracy to commit money laundering. TD Bank chose profits over compliance with the law — a decision that is now costing the bank billions of dollars in penalties. Let me be clear: our investigation continues, and no individual involved in TD Bank’s illegal conduct is off limits.”

“For years, TD Bank starved its compliance program of the resources needed to obey the law. Today’s historic guilty plea, including the largest penalty ever imposed under the Bank Secrecy Act, offers an unmistakable lesson: crime doesn’t pay — and neither does flouting compliance,” said Deputy Attorney General Lisa Monaco. “Every bank compliance official in America should be reviewing today’s charges as a case study of what not to do. And every bank CEO and board member should be doing the same. Because if the business case for compliance wasn’t clear before — it should be now.”

“For nearly a decade, TD Bank failed to update its anti-money laundering compliance program to address known risks. As bank employees acknowledged in internal communications, these failures made the bank an ‘easy target’ for the ‘bad guys.’ These failures also allowed corrupt bank employees to facilitate a criminal network’s laundering of tens of millions of dollars,” said Principal Assistant Attorney General Nicole M. Argentieri, head of the Justice Department's Criminal Division. “U.S. financial institutions are the first line of defense against money laundering and illicit finance. When they participate in crime rather than prevent it, we will not hesitate to hold them accountable to the fullest extent of the law.” 

“TD Bank prioritized growth and convenience over following its legal obligations,” said U.S. Attorney Philip R. Sellinger for the District of New Jersey. “As a result of staggering and pervasive failures in oversight, it willfully failed to monitor trillions of dollars of transactions – including those involving ACH transactions, checks, high-risk countries, and peer-to-peer transactions – which allowed hundreds of millions of dollars from money laundering networks to flow through the bank, including for international drug traffickers. The bank was aware of these risks and failed to take steps to protect against them, including for two networks prosecuted in New Jersey and elsewhere – one that dumped piles of cash on the bank’s counters and another that allegedly withdrew amounts from ATMs 40 to 50 times higher than the daily limit for personal accounts.”

According to court documents, between January 2014 and October 2023, TD Bank had long-term, pervasive, and systemic deficiencies in its U.S. AML policies, procedures, and controls but failed to take appropriate remedial action. Instead, senior executives at TD Bank enforced a budget mandate, referred to internally as a “flat cost paradigm,” requiring that TD Bank’s budget not increase year-over-year, despite its profits and risk profile increasing significantly over the same period. Although TD Bank maintained elements of an AML program that appeared adequate on paper, fundamental, widespread flaws in its AML program made TD Bank an “easy target” for perpetrators of financial crime.

Over the last decade, TD Bank’s federal regulators and TD Bank’s own internal audit group repeatedly identified concerns about its transaction monitoring program, a key element of an appropriate AML program necessary to properly detect and report suspicious activities. Nonetheless, from 2014 through 2022, TD Bank’s transaction monitoring program remained effectively static, and did not adapt to address known, glaring deficiencies; emerging money laundering risks; or TD Bank’s new products and services. For years, TD Bank failed to appropriately fund and staff its AML program, opting to postpone and cancel necessary AML projects prioritizing a “flat cost paradigm” and the “customer experience.”

Throughout this time, TD Bank intentionally did not automatically monitor all domestic automated clearinghouse (ACH) transactions, most check activity, and numerous other transaction types, resulting in 92% of total transaction volume going unmonitored from Jan. 1, 2018, to April 12, 2024. This amounted to approximately $18.3 trillion of transaction activity. TD Bank also added no new transaction monitoring scenarios and made no material changes to existing transaction monitoring scenarios from at least 2014 through late 2022; implemented new products and services, like Zelle, without ensuring appropriate transaction monitoring coverage; failed to meaningfully monitor transactions involving high-risk countries; instructed stores to stop filing internal unusual transaction reports on certain suspicious customers; and permitted more than $5 billion in transactional activity to occur in accounts even after the bank decided to close them.

TD Bank’s AML failures made it “convenient” for criminals, in the words of its employees. These failures enabled three money laundering networks to collectively transfer more than $670 million through TD Bank accounts between 2019 and 2023. Between January 2018 and February 2021, one money laundering network processed more than $470 million through the bank through large cash deposits into nominee accounts. The operators of this scheme provided employees gift cards worth more than $57,000 to ensure employees would continue to process their transactions. And even though the operators of this scheme were clearly depositing cash well over $10,000 in suspicious transactions, TD Bank employees did not identify the conductor of the transaction in required reports. In a second scheme between March 2021 and March 2023, a high-risk jewelry business moved nearly $120 million through shell accounts before TD Bank reported the activity. In a third scheme, money laundering networks deposited funds in the United States and quickly withdrew those funds using ATMs in Colombia. Five TD Bank employees conspired with this network and issued dozens of ATM cards for the money launderers, ultimately conspiring in the laundering of approximately $39 million. The Justice Department has charged over two dozen individuals across these schemes, including two bank insiders. TD Bank’s plea agreement requires continued cooperation in ongoing investigations of individuals.

As part of the plea agreement, TD Bank has agreed to forfeit $452,432,302.00 and pay a criminal fine of $1,434,513,478.40, for a total financial penalty of $1,886,945,780.40. TD Bank has also agreed to retain an independent compliance monitor for three years and to remediate and enhance its AML compliance program. TD Bank has separately reached agreements with the FRB, OCC, and FinCEN, and the Justice Department will credit $123.5 million of the forfeiture toward the FRB’s resolution.

The Justice Department reached its resolution with TD Bank based on a number of factors, including the nature, seriousness, and pervasiveness of the offenses, as a result of which TD Bank became the bank of choice for multiple money laundering organizations and criminal actors and processed hundreds of millions of dollars in money laundering transactions. Although TD Bank did not voluntarily disclose its wrongdoing, it received partial credit for its strong cooperation with the Department’s investigation and the ongoing remediation of its AML program. TD Bank did not receive full credit for its cooperation because it failed to timely escalate relevant AML concerns to the Department during the investigation.

https://www.justice.gov/archives/opa/pr/td-bank-pleads-guilty-bank-secrecy-act-and-money-laundering-conspiracy-violations-18b

June 28, 2024

A federal grand jury in the District of Maryland returned an indictment yesterday charging a Pennsylvania man for defrauding the U.S. National Institutes of Health (NIH) of approximately $16 million in federal grant funds.

According to court documents, Hoau-Yan Wang, 67, was a tenured medical professor at a public university’s medical school, as well as a paid advisor and consultant to a publicly traded Texas biopharmaceutical company. From approximately May 2015 through approximately April 2023, Wang allegedly engaged in a scheme to fabricate and falsify scientific data in grant applications made to the NIH on behalf of himself and the biopharmaceutical company. As alleged, the fraudulent grant applications to the NIH sought funding for scientific research of a potential treatment and diagnostic test for Alzheimer’s disease and resulted in the award of approximately $16 million in grants from approximately 2017 to 2021, part of which funded Wang’s laboratory work and salary. 

The indictment alleges that Wang’s work under these grants was related to the early developmental phases of the proposed drug and diagnostic test, typically referred to by the U.S. Food and Drug Administration as Phase 1 and Phase 2. Wang’s alleged scientific data falsification in the NIH grant applications related to how the proposed drug and diagnostic test were intended to work and the improvement of certain indicators associated with Alzheimer’s disease after treatment with the proposed drug. 

Wang is charged with one count of major fraud against the United States, two counts of wire fraud, and one count of false statements. If convicted, he faces a maximum penalty of 10 years in prison for the count of major fraud, 20 years in prison for each count of wire fraud, and five years in prison for the count of false statements.  



May 20, 2024 

(not quite an outrage but aggravating)

WASHINGTON— Stephen Paul Edmund Sutton, 53, a United Kingdom citizen, pleaded guilty and was sentenced today for his participation in a fraud scheme, perpetrated when he was employed by a  contracting firm that implemented a U.S. Agency for International Development-funded (USAID) power distribution program (PDP) in Pakistan, announced U.S. Attorney Jeanine Ferris Pirro and Acting Assistant Inspector General for Investigations Sean Bottary.

            Sutton pleaded guilty to conspiring to commit theft concerning a program receiving federal funds, which is a felony. In his role as a Logistics Operations Manager, Sutton took kickbacks of USAID-funds used to pay for the services rendered. After fighting extradition for more than two years, Sutton was extradited to the United States. District Court Judge Amit P. Mehta sentenced Sutton to time-served and ordered that Sutton be turned over to immigration authorities.

            He pleaded guilty to one count of conspiracy to commit theft concerning a program receiving federal funds. He was sentenced to time-served and one day of supervised release.

            According to court documents, PDP was a component of U.S. government assistance to the government of Pakistan to support its energy sector. Launched in September 2010, the five-year program was designed to facilitate improvements in Pakistan’s government-owned electric power distribution companies through interventions and projects addressing governance issues, technical and non-technical losses, and low revenue collection. The main goal of the PDP was to improve the commercial performance of the participating distribution companies through technology upgrades and improvements in processes, procedures, and practices, as well as training and capacity building. Under the PDP contract, Sutton’s employer subcontracted through purchase orders with vendors in Pakistan for certain goods and services.

            From May through November 2015, Sutton and his co-conspirator, an employee supervised by Sutton, participated in a kickback scheme by creating two companies, obtaining PDP purchase orders for forklift and crane services for the companies, and distributing the profits to themselves. As part of the scheme, his co-conspirator arranged for low-grade local vendors to provide the services for at least half the contract rates, and Sutton ensured that the company paid the invoices despite suspicions raised by an accounts payable officer. U.S. government sentencing documents indicate the agency was defrauded of almost $100,000 and that for his part, Sutton received at least $21,000 in kickbacks.


May 19, 2024

(conviction from last year)

$100 million Army grant fraud: Janet Yamanka Mello sentenced

Mello, a former Army civilian employee, was sentenced to 15 years in federal prison for stealing over $100 million in youth program grant funds. She used a fake business to receive fraudulent grant checks, then diverted the funds for personal luxuries.



May 19, 2025

Retired four-star Navy Admiral Robert P. Burke, aged 63, has been found guilty on federal charges including bribery, conspiracy to commit bribery, acts affecting a personal financial interest, and concealment of material facts. The conviction stems from a scheme where Burke, while serving as a four-star admiral in 2021, awarded a $355,000 sole-source contract to a New York-based company, Next Jump, for workforce training in Italy and Spain. In exchange, he secured a post-retirement job with Next Jump starting in October 2022, with a $500,000 annual salary and 100,000 stock options. Burke, who retired in August 2022 as commander of U.S. Naval Forces Europe and Africa, was the Navy’s former vice chief of naval operations (2019–2020) and chief of naval personnel (2016–2019). The bribery scheme involved Burke allegedly steering contracts to Next Jump’s co-CEOs, Yongchul “Charlie” Kim and Meghan Messenger, who were also charged.


March 3, 2024

An academic equity official has pleaded guilty to embezzling millions from New York University and using the money for personal expenses and an $80,000 pool at her luxe Connecticut home from funds that were supposed to go to women and minority businesses. Cindy Tappe, 57, pleaded guilty Monday, according to Manhattan prosecutors.  After stealing the funds, she landed a new job as operations director at the Yale School of Medicine. The Ivy League school fired her after the charges became public.


Additional :  4/26/2024

The former finance director at New York University who committed $3.5 million worth of fraud targeting minority and women-owned businesses has been sentenced to five years probation.

Cindy Tappe, of Westport, used her position at the Manhattan school to divert money intended for businesses with the fraudulent scheme.

The 57-year-old pleaded guilty to grand larceny on February 26 and has paid back $663,209 in restitution, with the final check for $180,000 received on Friday ahead of her court appearance.  Tappe's defense attorney Deborah Colson previously said her client has accepted responsibility, 'strongly regrets her misconduct' and planned to pay the required restitution in full prior to her sentencing. (But she did not.)

Commenters noted that even if she pays everything back, she received an interest fee loan.  Why no penalty?  She stole money.  https://www.dailymail.co.uk/news/article-13354659/NYU-finance-director-Cindy-Tappe-sentenced-five-years-probation-fraud.html

Feb. 7, 2024

Tampa, Florida – United States Attorney Roger B. Handberg announces that a federal jury has found Shirin Marshall (55, Tampa) guilty of four counts of mail fraud. Marshall faces a maximum penalty of 20 years in federal prison on each count. Her sentencing hearing is scheduled for April 30, 2024. A grand jury had returned an indictment against Marshall on February 24, 2022.

According to the testimony and evidence presented at trial, in August 2000, Marshall claimed a back and shoulder injury while working as a U.S. Postal Service letter carrier. In July 2001, she filed a subsequent claim related to workplace stress. Marshall later began receiving disability benefits and wage compensation from the Department of Labor’s Office of Workers’ Compensation Program (“DOL-OWCP”) mailed to her in monthly checks. An investigation by the U.S. Postal Service - Office of Inspector General revealed that Marshall concealed her physical capabilities, emotional state, and employment activities from the DOL-OWCP to continue receiving federal workers’ compensation benefits. Marshall also misrepresented her true medical condition to her treating physicians and made false representations on forms she annually submitted to DOL-OWCP. As result of Marshall’s fraudulent scheme, the DOL-OWCP provided her at least $500,000 in wage compensation she was not entitled to receive.  

This case was investigated by the U.S. Postal Service - Office of Inspector General. It is being prosecuted by Assistant United States Attorney Greg Pizzo.

Updated February 1, 2024

Sept. 11, 2023 LAPD Officer Takes Debit Card When Used at Police Station.  Later Videoed Using Card

The Los Angeles Police Department arrested one of their own for allegedly stealing a woman's debit card and using it at a home improvement store. Internal Affairs detectives started their investigation after a woman raised concerns about her missing debit card. While she recalled having it while inside a station, she later noticed unauthorized transactions on her bank statement. (She had used the card to bail someone out?)

The woman did her own investigating and obtained photos of a man buying items with her debit card at a home improvement store. She later forwarded the photos to LAPD.  Internal Affairs identified the suspect as Officer Edmond Babains, who spent 16 years with the department. He was most recently assigned to the Custody Services Division of the department.  "The allegations of an officer breaking public trust are extremely troubling and there must be accountability," This Department will fully cooperate with the Los Angeles District Attorney's Office in this matter."  

Babians was booked into jail but was released on "Own Recognizance" in accordance with the Los Angeles Superior Court bail policy, the department stated. Following his arrest, Babaians was stripped of his police powers and "assigned home" as he waits for the department to finish their administrative and criminal investigation.

https://www.cbsnews.com/losangeles/news/lapd-officer-arrested-for-stealing-residents-debit-card/

Jan 23, 2024  Indian American Uses Position in Community to Attract Fellow Indians to a Ponsi Investment Scheme

A former Chapel Hill transportation engineer was sentenced to nearly four years in prison and was ordered to pay almost $1 million to his victims Tuesday after pleading guilty in federal court to a Ponzi investment-fraud scheme.  Kumar Arun Neppalli, 57, pleaded guilty in September to 17 counts of wire fraud, committed between December 2017 and May 2021, according to court documents. He resigned from his traffic planning job with the town of Chapel Hill in November 2021, after filing for Chapter 7 bankruptcy.

“Neppalli was a conman running a classic ‘affinity fraud,’ targeting Indian-American investors in the Triangle for their hard-earned savings,” U.S. Attorney Michael Easley said. “It was a pure Ponzi scheme — stoking false hopes of financial success, but using new investor money to pay off earlier investors, while masquerading those payments as legitimate profits.”

Neppalli had worked for the town since 2000 and was a widely regarded member of the Triangle’s Indian American community, previously serving as vice president and president of the Triangle Area Telugu Association, and as a former board member with the Hindu Society of North Carolina. He also served for 11 years as president of his Twin Lakes Master Association in Cary.  Federal investigators said Neppalli, who lived in Cary, used his position in the community to defraud his victims, telling them that he had connections to real estate developers in the Orange County area through his job with the town and that he would invest their money in real estate projects.

A News & Observer investigation in 2021 revealed that Neppalli, a native of India, was accused of bilking 15 investors out of $1.9 million in business loans that he acquired through his connections with the Triangle’s Indian community.  Federal investigators said Neppalli would ask interested investors to provide money in a short amount of time, sometimes on the same day, to help close the transaction, according to a news release.

Neppalli promised to return their principal investment plus a profit within a few months, and often asked his victims not to discuss the transaction with other members of the Indian American community, they said, sometimes mentioning a non-disclosure agreement.  He used money from subsequent victims to repay earlier investors, investigators said.

A town spokesman told The N&O that Chapel Hill staff investigated Neppalli’s work but did not find any irregularities.










Feb 1, 2024  Experienced Anti-Money Laundering Specialist Violates Law

A man described as an “experienced anti-money laundering specialist” pleaded guilty on Wednesday to illegally funneling more than $1 billion in lucrative, high-risk transactions through small financial institutions, the U.S. Department of Justice said.  The massive transfer, which included hundreds of millions of dollars from foreign jurisdictions, occurred without proper oversight and without any Suspicious Activity Reports being filed, as the law requires, the DOJ said.  The man, 56-year-old Gyanendra Asre of Greenwich, Connecticut, pleaded guilty in Brooklyn federal court to one count of failing to maintain an anti-money laundering program in violation of the Bank Secrecy Act. He faces up to 10 years in prison when he is sentenced May 3.

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network, meanwhile, on Wednesday assessed a $100,000 civil penalty on Asre and banned him from participating in any financial institution’s affairs for five years. “Asre was an experienced anti-money laundering specialist well-versed in the Bank Secrecy Act’s provisions and deliberately ignored these protections, exposing financial institutions to the risk of illicit criminal activity,” U.S. Attorney Breon Peace said in a press release.  The scheme occurred from 2014 to 2016, when Asre was a member of the supervisory board of the New York State Employees Federal Credit Union, which the DOJ called a “small, unsophisticated” financial institution.

He had previously been employed as a senior vice president at a domestic bank, and was “experienced in international banking and trained in anti-money laundering compliance and procedures,” the DOJ said.  Asre “represented to the NYSEFCU that he and his businesses would conduct appropriate anti-money laundering oversight as required by the Bank Secrecy Act,” according to the DOJ.  Based on that, the NYSEFCU allowed Asre to conduct high-risk transactions, and he subsequently steered more than $1 billion through it and other entities.

Some of that money allegedly came from Mexican banks, which are not named in an indictment in U.S. District Court in Brooklyn.  But “contrary to his representations, Asre willfully failed to implement and maintain an anti-money laundering program at the NYSEFCU,” the DOJ said. “This failure caused the NYSEFCU to process the high-risk transactions without appropriate oversight and without ever filing a single Suspicious Activity Report, as required by law,” according to the DOJ.  The National Credit Union Administration liquidated the NYSEFCU in October 2017 after finding “significant deficiencies” in the credit union’s regulatory compliance, according to FinCEN’s consent order with Asre.

Asre’s actions “were a major contributing factor to the dissolution” of the credit union, the consent order said.  Erin Keegan, the acting special agent-in-charge at the Department of Homeland Security’s investigative division in New York, said Asre was specifically trained in the right procedures and “took advantage of a small New York financial institution.”

“I commend HSI New York and our law enforcement partners for their dedication to ensuring vitally integral regulations — the foundation of our banking system — are upheld,” Keegan said.

Nov 4, 2023 Durham County Employee Steals Co-worker's Retirement Benefits

DURHAM, N.C. (WTVD) -- A now-former Durham County employee has been arrested and charged with stealing Investigators believe Blake contacted Empower, a company contracted to administer employee retirement benefits, and pretended to be nine different employees on 16 separate occasions between August 2019 and January 2023. One account was for a deceased person. Blake then submitted Hardship Withdrawal Requests and transferred more than $18,000 from the accounts to herself.

Deputies said the withdrawals were initially flagged by Empower which conducted an internal investigation. During their investigation, Blake allegedly attempted to continue the scheme but the transactions were denied.

Blake was arrested Friday and charged with nine counts of ID theft, nine counts of accessing computers, eight counts of forgery of instrument, six counts of obtaining property false pretense.  She is being held under a $20,000 secured bond.more than $18,000 from employee 401k accounts.  According to the Durham County Sheriff's Office, Durham County administrators told investigators about an employee suspected of fraudulently accessing funds in county retirement accounts.  Deputies said at the time of the incident, Tiffany Diane Blake, 40, of Durham, was an employee in the Social Services Department of Durham County.

https://abc11.com/durham-employee-charged-theft-retirement-accounts/14010167/p










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