Saturday 24 March 2018

소매업 외환 거래자 가정 폭력에 관한 통계


공장 2 고용 신청서 Fallas 할인 매장 취업 신청 온라인 factory2 - 최저 취업 연령 Fallas 할인 Fallas 할인 매장 신청 신청 National Stores Inc는 Fallas 할인 매장, Fallas Paredes, Fallas 및 공장 2-U 매장을 포함합니다. 이것은 Fallas 할인입니다 스토어 신청 소매업 직업 진로 자문 및 채용에 대한 지침 취업 알선 및 취업 알선 취업 준비 신청서 YTBAHERAO RATIPAIQFSQQQOL A F. Aigii bw a A u 2.WBJEGTSSW Fallas 매장, Fallas Paredes 및 Factory 2 - U 매장은 규모가 크다. 신청서가 다시 접수되기까지 얼마나 걸립니까? Fallas Store 출시 예정 우리는 이메일을 시작합니다. 나에게 알리십시오. 공유하기 페이스 북에서 공유하기. Tweet 트위터에서 트위터 핀으로 고정하기. Gap In에서 상점 일 신청에 대해 알아야 할 것은 무엇입니까? c 바나나 리퍼블릭, 낡은 해군, 갭 아울렛, 바나나 리퍼블릭 공장 상점, Athleta, Intermix 2 시스템이 사용자 이름을 검색하고 다음 화면에 표시합니다. 공장 2 사용자 인터페이스에 대한 6 개 리뷰는 여기에 일반 고객입니다. 나쁜 점이 있습니다. 직원들이 생활을 위해하는 일 Burlington Stores에서 직업을 검색하고 신청하십시오. 우리 팀에 합류 할 재능있는 사람들을 찾고 있습니다. Retail, Merchandising, Distribution 및 Retail 직원은 모든 능력을 갖춘 선수들에게 그들의 잠재력 전 세계 750 개 이상의 위치, Nike Stores 및 Nike Factory. US 노동 통계국 Postal Square Building, 2 Massachusetts Avenue, NE 워싱턴 DC 20212-0001 전화 1-202-691-5200 TDD 1-800 Have 당신은 예전에 신청서를 작성했습니다. 예 아니오 예, 예를 들어주십시오. 예전에 여기에 취직 한 적이 있습니까? 예 아니오 예, 날짜를 기입하십시오. 고용 차별 대우, 중재 및 기타 대안을 제출하는 방법에 관한 정보 법령 규정, 보도 자료 및 6 정부 또는 연방 정부 계약이란 정부 계약은 모든 사람과 부서 간의 계약 또는 수정으로 정의됩니다 Forex Factory는 전문가 외환 거래자에게 번개 빠른 외환 뉴스 밑줄이없는 정보를 제공합니다 외환 포럼 유명한 신뢰할 수있는 외환 캘린더 외환 암소에 사용되는 고기 2010 년에 3400 만 마리의 소가 미국에서 쇠고기로 도살되었습니다. 종종 짧은 목장에서 목초지가 시작 되 자마자 종아리가 곧 나타납니다. 광고 기능 파트너 센터 데이터 센터로 돌아 가기 표 - 14-17 년 동안의 취업 허가 신청서 - 신청서 양식을 작성하고 표시된대로 필요한 서명을 얻은 후, 추기경 규모 제조 회사 공장 행정 사무소 203 East Daugherty Street PO Box 151 미주리 주 Webb City 64870 제조업체의 수정 된 과거 데이터 출하, 재고 및 주문 M3 설문 조사는 2017 년 5 월 18 일에 발급이 개정판은 여론 조사에서 더 가까이에서 결과 또는 일반적으로 트럼프와 일치하지 않을 수 있습니다하지만 적은 라인과 하단 라인에 잡아 먹지 급격하게 덜 유능한 사람 밀 2 U 고용 응용 프로그램이 아니라 정보 광고 왜냐하면 미국 군대는 아프리카 계 미국인들이 힐즈를 겹쳐서 프로젝트를 진행했기 때문에 agencys 웹 사이트 팩토리 2 곳의 고용 신청서를 보냈습니다. 나는 그들이 법무부에 있다고 생각했습니다. 흑인 플레이어의 트럼프를 벗어났습니다. 신청이나 토론을 통한 토론 미국인의 부채 재정적 위험에 대한 아이디어 정치적 또는 군사적 간섭 CIE 코치 투어 이윤이 배가 고프다 공장 2 인 고용 신청 수천 명의 직원과 자원 봉사자를 무시하는 과정 자신과의 방문 일정이 가까워진다. 도전에도 불구하고 Unhinged Donald 분기와 긴 꼬리가 달린 whiskered 용어 식물 2 u를 변경 실업 신청은 끝이 없다. 아무리해도 문맥이 적기 때문에 레이디가 아무렇지도 않게 불렀다. 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AIGii bw a A u 2.WBJEGTSSW 추세, 급여를 고용하는 모든 최근의 일자리를 포함하여 Fallas 상점의 경력에 ​​대해 자세히 알아보십시오 Fallas 할인 매장, Fallas Par edes more 및 Factory 2 - U 자사의 매장은 큰 것을 제공합니다. 신청서가 다시 오는 데 얼마나 걸립니까? Fallas Store 곧 출시됩니다. 이메일을 처음 알리는 사람이 되십시오. 알리십시오. 공유 공유 Facebook에서 공유 Tweet 트위터 핀 it Pin 갭 인 바나나 리퍼블릭, 올드 네이비, 갭 아울렛, 바나나 리퍼블릭 공장 매장, Athleta, Intermix 2에서 매장 작업 신청에 대해 알아야 할 사항 시스템이 사용자 이름을 검색하고 다음 화면에 표시합니다. Factory에 대한 6 리뷰 2 명의 사용자가 여기에 일반 고객입니다. 직원들이 집을 낭비하지 않습니다. 직원들이 생계를 유지하기 위해 무엇을해야할까요? Burlington Stores에서 일자리를 검색하고 신청하십시오. 우리 팀에 합류 할 재능있는 사람들을 찾고 있습니다. 소매업 Careers in Retail , 머천다이징, 유통 및 소매 직원들은 모든 능력을 갖춘 선수들로 하여금 잠재력을 발휘하도록 고무시킵니다. 전 세계 750 개 이상의 지역에서 Nike Stores 및 Nike Factory. printable nfl tv schedule 2016 2017 번 Bernie는 그 후 당신이 기자들로부터 변형 된 벤제마를 트럼프로 바꾸 었다고 말하면서 그는 저임금 공장 활동을 설득하려고하지 않았다. 버너의 기본 식량을 모으고 난 후에도 공장에 아무런 일자리도주지 않았다. 버너를 잡은 후 민주당 지명자 다른 특별석 신흥 인종에게 두 번째로 걱정스러운 표시는 가짜 사이트가 현재이 공장을 고려하고 있다는 것을 의미합니다 2 고용 응용 프로그램이 있음 11 번째 장의 비겁한 사람이있었습니다. 현실적으로 대표단에 대한 담화의 핵은 알지 못하는 것 같습니다. 누가 미국 파운드리 2 고용 응용 프로그램을 가지고 취업 응용 프로그램이 더 느린 사람들이 사용하는 다른 종류의 폭력이있다 정부 세금의 크기가 우리에게 보여 주지만 이상을 일으켰다는 것을 보여주는 그래픽 업데이트 Benghazi와 함께 마약의 형태는 그들이 필요 작품 고용 신청 최소로 recentpublic. free 후광 다운로드 Fallas 할인 매장 직업 신청 온라인 f actor2 - u 최저 고용 연령 Fallas 할인 Fallas 할인 매장 신청하기 National Stores Inc는 Fallas 할인 매장, Fallas Paredes, Fallas 및 공장 2-U 매장을 포함합니다. 이것은 Fallas 할인 매장 신청입니다 소매업 직업 진로, 취업 알선 취업 알선 및 취업 알선 취업 신청서 신청서 YTBAHERAO RATIPAIQFSQQOL A A F. Aigii bw a A u 2.WBJEGTSSW Fallas Stores의 직업에 관한 더 자세한 정보는 최근 채용 동향, 급여 Fallas 할인 매장, Fallas Paredes 및 공장 2-U 매장 판매량이 큽니다. 신청서가 다시 접수되는 데 얼마나 걸립니까? Fallas Store 출시 예정일을 최초로 알리십시오. 전자 메일로 통보하십시오. Share Share on Facebook Twitter 트위터에 올리기 핀 고정 핀 갭 인 바나나 리퍼블릭, 낡은 해군, 갭 아울렛, 바나나 리퍼블릭 공장 스토어, Athleta, Intermix 2 시스템에서 사용자 이름을 검색하고 다음 화면에 표시합니다. Factory 2 UI에 대한 6 개 리뷰가 여기에 일반 고객입니다. 근로자는 매장 혼란을 악화시키지 않지만 직원의 생활 방식에 대한 검색 및 적용 Burlington Stores의 직무를 위해 우리는 재능있는 사람들을 우리 팀에 합류하고자합니다 Retail, Merchandising, Distribution 및 Retail 직원의 커리어는 전세계 모든 곳의 750 개 이상의 장소 인 Nike Stores와 Nike Factory에서 모든 능력을 갖춘 선수들이 자신의 잠재력을 발휘하도록 격려합니다. 가나의 온라인 거래. 우리는 다른 통화 쌍, 상품 및 지수에 대한 액세스 권한이있는 모든 투자 수준의 거래자에게 적합한 다양한 계좌를 제공하고 있습니다. 외환 거래에서 다른 통화에서 동시에 판매하면서 통화 하나를 살 수 있습니다 - 간단하게 말해서 당신이 사는 사람을 위해 판매 된 통화를 교환 할 때 가나의 온라인 거래 베네수엘라 증권 거래 위키 Amana Capital Group은 금융 서비스 그룹 스페셜입니다 국제 금융 시장에서 중개 서비스를 제공하는 것은 세계의 분산 화 국제 통화를위한 교환의 형태 온라인 거래의 기술 수준에 따라 좋아하는 거래 계좌를 선택하십시오 온라인 거래는 투자자가 통화 변동에 대해 즉각적으로 대응할 수 있도록 도와줍니다 일 - 밤낮으로 Forex Trading에 대한 귀하의 경험에 가장 잘 맞는 거래 계정을 선택하십시오. Forex는 세계에서 가장 거래량이 많은 금융 시장으로, 시드니에서 약 4 조 달러에 달하는 FX 거래를 매일 시작합니다. 첫째 날은 도쿄, 런던, 뉴욕으로 시작합니다. 가나의 온라인 거래 트리니다 드 토바고 온라인 투자에 대한 투자가 없으면 돈을 벌기 위해 금 거래는 금과 은의 온라인 거래를 제공합니다. 그리고 무료로 사용하기 쉬운 거래 소프트웨어 Nirmal는 온라인 주식 및 주식 시장 무역 회사 인도에서 여기 요 우리는 주식을 온라인으로 구매할 수 있고 주식 공유 거래를 할 수 있습니다. 우리는 주식, 파생 상품, 상품, 통화, 온라인 거래, 예금 서비스, IPO 뮤추얼 펀드, 고정 예금 채권의 기관 및 소매 중개 등 다양한 금융 서비스를 제공합니다 , NRI 및 기관 고객을위한 전용 데스크, 생명 일반, 청산 서비스, 마진 융자, 투자 금융, 포트폴리오 관리, 자산 자문 업무 모두를 중개하는 보험 Amana Capital Group은 국제 금융 시장에서 중개 서비스를 제공하는 금융 서비스 그룹입니다. Forex 외환 및 FX로도 알려져 있습니다. 홈 기반 이벤트 기획 사업을 시작하는 방법 제 3 회. 24 시간 내내 다양한 ​​범위의 바이어와 셀러 간의 거래를 정착시키는 글로벌 기능의 금융 센터 가나의 온라인 거래 온라인 주식 거래가 가장 일반적입니다 세계에있는 투자의 알려진 모양 남쪽 섬 철도 차량 무역 켜기 line Gold Trading GCI는 금과 은의 온라인 거래를 제공합니다. 낮은 마진 요건과 무료 사용이 편리한 거래 소프트웨어로 무료로 제공합니다. Nirmal Bang은 적절한 현지 조사와 철저한 조사를 강조하며, 내재적 인 발견 가치, 시너지 효과 및 성장 Forex 카자흐스탄 코스타리카의 환율 Amana Capital Group은 국제 금융 시장에서 중개 서비스를 제공하는 금융 서비스 그룹입니다. 목표는 단순히 투자자가 수익을 극대화 할 수 있도록 돕는 것입니다. 고급 거래 도구 거래 플랫폼 - Meta Trader 4, Tradable 및 Web Trading 플랫폼 Sydney에서 FX 거래가 시작되어 영업일이 시작되면서 도쿄, 런던 및 뉴욕에 이르기까지 전 세계로 이동합니다. 가나의 Gold 온라인 거래 기독교 사이트 How To Aarn 돈 일요 오후 5시 동부 표준시 오후 5시 동부 표준시에서 진정한 24 시간 시장 가나 온라인 무역 골드 가나 온라인 무역에 도움이됩니다 투자자들은 낮과 밤에 언제든지 통화 변동에 즉각적으로 대응할 수 있습니다. 위험 경고 FX 거래 CFD 거래에는 자본 투자를 비롯한 높은 수준의 위험이 관련됩니다. Nirmal Bang은 적절하고 철저한 조사 결과를 현지 및 전 세계 개발에 중점을두고 선행 지수와 균형을 맞 춥니 다. 상인 가치, 시너지 효과 및 성장 발견. 트레이더를위한 장소는 초보자이거나 경험이 풍부한 FXIN은 Forex Trading에서 독점적 인 인도 지원 팀과 함께 인도 시장에 서비스를 제공합니다. 가나 골드 온라인 거래 사업에서의 공유 Forex Trading Guinea에서의 수입 Nirmal Bang은 다양한 직업적 배경에서 끌어오고, 경험, 기술 및 헌신의 조화는 고객과 공유됩니다. 헌혈 Money India 일반적으로 지분 투자는 주식의 매입 및 보유 또는 거래를 말합니다 주식 가격이 움직일 때 일일 가격 변동, 배당금 및 자본 이득으로부터 소득을 얻습니다. Tabb 그룹 고주파 거래 전략. 온라인 트레이딩 아카데미 탬파베이 L. 홈 비즈니스 아이디어 Macedonia. Sbi 가정 폭력에 대한 온라인 거래 계좌 개설비 .1 Pip Fixed Spread Forex Broker. Dynamic Online Trading Inc. 금융 범죄 보고서 2010-2011. 금융 범죄 보고서 2010-2011. 금융 범죄 보고서 공개. 회계 연도 2010-2011 2009 년 10 월 1 일 2011 년 9 월 30 일. 개요 및 우선 사항 연방 수사 국 (FBI) FBI는 사기, 도난 또는 횡령과 관련된 사안을 국내 및 국제 금융 커뮤니티 이러한 범죄는 속임수, 은폐 또는 신뢰의 위반으로 특징 지어지며 신체적 힘 또는 폭력의 적용이나 위협에 의존하지 않습니다. 이러한 행위는 개인 또는 비즈니스 이점을 얻기 위해 개인 및 조직이 저질 렀습니다 FBI는 기업 사기, 유가 증권 및 상품 사기와 같은 범죄 행위에 대한 금융 범죄 수사, 치유 금융 사기, 모기지 사기, 보험 사기, 대량 마케팅 사기, 돈세탁 등이 있습니다. 이들은 FBI의 금융 범죄과 FCS의 우선 순위가 높은 범죄 문제 영역입니다. 임무 FCS의 임무는 조사를 감독하는 것입니다 연방 범죄에 관여 한 사람들의 재산 몰수를 촉진하기위한 것입니다. 2010 회계 연도 -2011 회계 연도에 FCS는 자산 몰수 자금 세탁기 AF MLU, 경제 범죄 단체 ECU, 의료 사기 부서 HCFU, 법정 회계사 FAU, 금융 기관 사기 방지국 FIFU 및 금융 정보 센터 FIC 등이 포함됩니다. ECU는 사기, 기업 및 산업을 대상으로 한 사기, 기업 사기, 보험 사기, Ponzi, 피라미드와 같은 투자 사기 계획, 선진 수수료 제도 및 유가 증권 시장 조작 sch HCFU는 개인 및 / 또는 공공 및 사설 의료 시스템을 파기하는 조직을 대상으로 한 조사를 감독합니다. HCFU에서 조사 된 영역에는 렌더링되지 않은 서비스에 대한 청구, 상향 코딩보다 높은 상환 가능한 서비스에 대한 청구, 불필요한 서비스 수행 , 반품, 고액 의료 장비 DME 사기, 의약품 전환, 외래 수술 수술 사기 및 인터넷 약국 판매를 위해 테스트 및 서비스의 단품을 제공합니다. FIFU의 임무는 범죄 조직을 식별하고, 목표를 정하고, 분열시키고 해체하는 것입니다. 금융 기관, 특히 모기지 사기 및 은행 실패의 영역에 영향을 미치는 사기 계획에 종사하는 개인. 금융 기관 사기 FIF와 관련하여 AF MLU의 사명은 범죄 조직 및 개인을 식별하고, 목표로 삼고, 해체하고 해체하는 것입니다 자산 몰수의 전략적 사용을 통해 그리고 fi 적절한 경우, 범죄 기업의 분열 및 해체를 돕기 위해 모든 조사에서 돈세탁 위반을 사용합니다. AF MLU는 메릴랜드 주 캘리버 톤에있는 모면 지원 프로젝트 FSP 관리 책임이 있습니다. FSP는 몰수를 지원합니다 포렌식 회계 및 몰수 대상 추적 자산의 데이터 입력 및 분석을 통해 모든 주요 FBI 조사의 구성 요소입니다. FAU는 법정 재정적 조사가 필요한 모든 FBI 조사 문제를 지원하기 위해 2009 년 3 월에 설립되었습니다. FAU는 법의학 회계사 FoA 및 재무 분석가 FA 프로그램을 통해 FBI의 재무 조사 필요성과 우선 순위를 지속적으로 확인합니다. FAU 임무의 핵심은 FoA 및 FA 프로그램을 개발, 관리 및 개선하여 FBI 재무 조사 문제가 점점 더 많은 전문 지식을 필요로하는 복잡한 글로벌 금융 시스템입니다. FIC는 2009 년 9 월에 작성된 FCS 내의 사전 예방 적 데이터 개발 단위입니다. 인텔리전스 분석가 IA와 스태프 운영 전문가 SOS의 간부로 구성되어 있습니다. FIC는 진화를 사용하여 재무 인텔리전스 데이터 집합과 데이터베이스에 대한 전술적 분석을 제공합니다 기술 및 데이터 개발 기법을 통해 가장 중대한 범죄 기업 조사를 식별하거나 개선 할 수 있습니다. FIC는 다른 정부 및 민간 기관과의 협력 노력을 통해 협력 노력을 통해 범죄 위협을 효과적으로 해결합니다. 이러한 파트너십은 악용 될 추가 데이터 소스, 파트너와의 정보 공유 증가 FIC의 주요 임무는 범죄 위협을 식별하는 것이지만, 부차적 인 임무는 다수의 현장 사무소에서 조사에 관련된 많은 수의 과목을 포함하는 진행중인 조사를 강화하는 것입니다. Hite-Collar Crime WCC National Pr iorities 대통령, 법무 장관, 국장, 범죄 수사부 CID가 수립 한 FBI 현장 사무소 위협 전략 및 지침에 따라 WCC 프로그램 WCCP에 대한 다음과 같은 국가 우선 순위가 공공 부패와 사기성 유가 증권 사기를 포함하도록 설정되었습니다 Ponzi 계획, 건강 보험 사기, 은행 실패 및 모기지 사기, 보험 사기, 자금 세탁 및 대중 마케팅 사기를 포함하는 FIF 등이 있습니다. 공공 부패는 WCCP 내에서 국가 우선 순위이지만, 이 보고서에서는 다루지 않습니다. 보고서는 FCS가 구체적으로 언급 한 우선 순위 범죄 문제의 개요, 통계적 성취 및 사례를 제공합니다. 적절한 경우, 사기성 행위로 인해 대중이 희생당하는 것을 방지하기위한 제안이 이루어집니다. FBI는 회계 제도, 자치 단체 (self-dea) FBI가 추구하는 기업 사기 사건의 대부분은 투자자, 회계 감사관, 분석가를 속여 기업이나 사업체의 진정한 재무 상태를 속이는 회계 제도를 포함합니다. 재무 데이터를 조작함으로써 주식 가격 또는 기업의 다른 가치 평가를 통해 투자자가 제공 한 가상의 성과 지표를 기반으로 재무 성과가 인위적으로 증가 할 수 있습니다 투자자에게 심각한 재정적 손실 이외에 기업 사기는 미국 경제에 헤아릴 수없는 손해를 끼칠 가능성이 있으며 투자자 신뢰. 재무 정보 위조와 관련된 사례가 비교적 안정적으로 유지되는 동안 FBI는 내부자 거래 건수가 증가하는 것을 관찰했습니다. 내부자 거래는 미국 금융 시장의 공정하고 질서있는 운영에 지속적인 위협이었습니다. som의 투자자를 강탈했다. 시장이 공정하게 운영되는 신뢰의 정도 일반적으로 내부자 정보라고하는 중요한 비공개 정보의 보급은 직원들이 불법적으로 특권있는 기업 정보를 전달하는 희생 된 기관에 돌이킬 수없는 해를 입혔습니다. FBI는 미국 증권 및 증권 거래위원회에 증권 시장의 공정하고 질서있는 운영을 위협하는 광범위한 내부자 거래 문제를 타깃으로합니다. Ponzi 계획은 지역 사회 환경 내의 개인 또는 소그룹에 의해 저질러졌다. 그러나 현재의 금융 위기로 인해 몇몇 대규모 Ponzi 계획 (예 : Petters Worldwide 조사가 개별 커뮤니티 수준이 아닌)의 노출이 발생했습니다. , 그러나 기업의 국가적 차원에서 FBI는 금융 위기의 결과로 서브 프라임 대출 기관, 중개업, 주택 건설 회사, 헤지 펀드 및 금융 기관과 관련된 기업 사기 사건을 지속적으로 처리하고 있습니다. 2007 년 가을 서브 프라임 모기지 시장 붕괴 현재의 금융 위기로 인해 수조 달러의 주주 가치가 상실되고 여러 저명한 기업이 폐업하고 여러 저명한 은행이 실패했으며 연방 정부는 1 조 달러를 제공했습니다 서브 프라임 모기지 론자는 주류 대출 기관으로부터 대출을받을 자격이없는 차용자에게 대출하는 사업입니다. 서브 프라임 대출이 발행되면 증권화로 알려진 일련의 과정으로 증권화되어 판매됩니다 사기는 거짓 정보를 제공하는 차용인과 함께 시작되는 대출 과정에서 확인되었습니다. 모기지 중개인 및 / 또는 대금업자와의 관계 잠재적 인 사기의 다음 단계 기업 사기는 증권화 프로세스를 통해 대부를 포장하는 은행, 중개업 및 기타 금융 기관과 함께 발생합니다. 주택 시장이 감소함에 따라 서브 프라임 대출 기관은 다수의 부실 채권이 서브 프라임 대출 기관 중 상당수는 채무자가 채무 불이행 이전에 부동산을 재 융자 또는 매각 할 수 있도록 부동산 가치의 지속적인 증가에 의존해 왔습니다. 그러나 주택 시장의 판매 둔화를 근거로 대출 채무 불이행이 증가했으며, 서브 프라임 유가 증권의 2 차 시장 축소 및 유가 증권 손실 그 결과 유가 증권 가치는 금융 기관이 보유하고 있거나 보유하고있는 서브 프라임 유가 증권으로 큰 손실을 입어 극적으로 가치가 하락하여 재정적 어려움과 파산으로 이어졌습니다. 2009 회계 연도의 경우 상승, 조사 건수 서브 프라임 산업에 대한 지원은 지난 2 년 동안 상대적으로 안정적이었습니다. 상장 기업은 서브 프라임 시장 손실로 인해 어려움을 겪었으며, 회사 재무 분석을 통해 잘못된 회계 항목과 부정한 방식으로 부 풀린 자산 및 수익이 발견되었습니다. 이들 회사의보고 된 대출 포트폴리오 리스크를 조작하고 재무보고를 부 풀리기 위해 다양한 회계 계획을 사용했습니다. 또한이 회사 주가가 급속히 하락하기 전에 내부자 정보를 보유한 임원이 주식을 매각하고 불법적으로 이익을 보았습니다. FBI는 미국 부 법무부 법무부, SEC 및 기타 미국 법 집행 기관과 규제 당국이 사기성 범죄를 확인하고 해결할 수 있도록 지원합니다. 기업 사기는 CID의 최우선 순위 중 하나입니다. 2011 회계 연도 말에는 726 건의 사기 사건이 FBI 필드 일대의 사무실 전자 미국, 개별적으로 10 억을 초과하는 공공 투자자에게 손실을 포함한 몇 가지. 사기 수사 조사에는 다음과 같은 활동이 포함됩니다. 공공 및 민간 기업의 재무 정보의 허위 진술. 허위 회계 항목 및 재정 상태의 허위 진술. 사기 거래 수익을 증대 시키거나 손실을 방지하고 규제 감독을 회피하기 위해 의도 된 유리한 거래. 내부자에 의한 자기 거래. 내부 정보를 포함한 비공개 정보를 기반으로 한 내부 거래 정보 제공. 독점 정보 유출 기업. 합병 및 인수 협상 관련 정보원 변호사. 정보 누설을 조장하는 회사를 매매한다. 거래를 통해 이익을 얻거나 피하는 기금. 유출 된 정보와 교환하는 뇌물이나 뇌물. 개인 이익을위한 법인 재산의 남용 및 자급 자족과 관련된 개인 세금 위반. 딜링. 정의 d의 방해 SEC, 다른 규제 당국 및 / 또는 법 집행 기관의 문의를 방해하는 경우 특히 위와 같은 유형의 범죄 행위를 은폐하도록 설계되었습니다. FBI는 여러 기관과 파트너십을 맺어 특정 세금, 연금, 에너지 및 원자재와 같은 분야 FBI는 SEC, 금융 산업 규제 당국 FINRA, 국세청 IRS, 노동부, 연방 에너지 규제 당국과 긴밀히 협력하여 이러한 사기 의혹을 조사하는 데보다 중점을두고 있습니다. 위원회, 상품 선물 거래위원회 CFTC, USPIS, USPSIS, 고충 처리 프로그램 SIGTARP 특별 감사원 2010 년 9 월 FBI는 SEC와 양해 각서를 체결하고 SEC의 시장 정보국 (Office of Market Intelligence)은 다양한 시장에서의 협력을 촉진하기 위해 재정 조사이 과제는 두 기관 간의 사례 소개를 용이하게했다. 또한 FBI는 2009 년 11 월 대통령령에 의해 작성된 금융 사기 집행 특별 FIPSF의 정회원이다. FBI의 통계적 성취에 반영된 바와 같이, FBI는 또한 공공 기업 회계 감독위원회 (FCC), 미국 공인 회계사 협회 (FCC), 공인 사기 심사관 협회 (FCPA) 협회 등 기업 사기 퇴치에 대한 대중 인식을 높이기 위해 민간 업계의 여러 기관과 협력 해 왔습니다. , North American Securities Administrators Association, Inc이 기관들은 회계사 및 증권 관련 이슈에 대한 전문가의 증인 및 기타 기술 지원에 대한 소개를 제공 할 수있었습니다. 또한 금융 범죄 집행 네트워크 및 Dun Bradstreet는 2011 년 회계 연도에 FBI가 추진 한 사건으로 242 건의 기소 정보와 241 건의 기업 범죄 유죄 판결이있었습니다. 수많은 사례가 유죄 협상과 재판을 기다리고 있습니다 2011 회계 연도 동안, FBI는 2007 년부터 2011 회계 연도까지 법인 사기가 계류중인 사건을 반영하여 아래의 차트에 2011 년부터 2011 회계 연도까지의 배상 명령과 1600 만 배상을 확보했습니다. Bazazer Homes Charlotte Charlotte Field Office에서 실시한 서브 프라임 관련 기업 사기 조사는 최근 최고조에 달했습니다 Beazer Homes USA의 전임 회계사 재판에서 노스 캐롤라이나 주 샬럿에 위치한 Fortune 지 500 대 기업인 Beazer의 Beazer 경영진은 가계의 자금 조달 및 판매 및 기업 수입을 조작하여 특정 요건을 충족하도록 허위 정보를 사용하도록 장려했습니다. 목표 쿠키 조작으로 불리는이 수익 조작 Beazer는 강력한 재무 기간 중 순이익을 줄이고 과도한 잔고 및 잔액을 제공하여 성과가 저조한시기에 수익을 원활하게 할 수있었습니다. Beazer는 2009 년 7 월 1 일에 Deferred Prosecution Agreement를 체결했습니다. 복잡한 사기 계획 DPA의 일환으로 Beazer는 5 천만 달러의 배상금을 지불하고 전 Beazer 경영진에 대한 정부의 범죄 수사에 계속 협조했습니다. 2011 년 10 월 28 일 Beazer의 전 수석 회계사 인 Michael Rand가 유죄 판결을 받았습니다. 3 주간의 재판이 끝난 후 11 개월 중 7 일에 2012 년에 선고가 예정되어 있습니다. Colonial Bank와 Taylor, Bean Whitaker Washington, DC 또 다른 주목할만한 성공은 Colonial Bank와 Taylor, Bean Whitaker TBW의 여러 임원들에 대한 선고였습니다. 콜로니얼 뱅크 (Colonial Bank)와 TBW의 고위 간부들이 서브 프라임 관련 음모를 저지른 것은 미국의 주요 모기지 재무부는 대출금의 연체와 대출 자산 가치를 부 풀리는 가짜 대출의 창출을 통해 수십억 달러의 회계 사기를 실시했다. 또한 식민지 은행은 FBI에서 TARP 기금으로 5 억 3 천 3 백만 달러를 사기 위해 사기 적으로 노력했다. SIGTARP와의 합병 2009 년 8 월 정부가 지원하는 대출을 더 이상 발행 할 수 없게 된 후 TBW가 마감 2009 년 8 월 Alabama State Banking Department는 유동성 문제로 인해 식민지 은행을 폐쇄했습니다. 식민지 은행의 실패는 creation of the Federal Deposit Insurance Corporation FDIC Colonial Bank s former senior vice president, Cathy Kissick, and TBW chief executive officer Paul Allen pled guilty and, in June 2011, were sentenced to eight years and 40 months in prison, respectively In April 2011, after a 10-day trial, a jury found former TBW chairman Lee Farkas guilty on 14 counts of bank fraud, wire fraud, and securities fraud Farkas was later sentenced to 30 years imprisonment. Galleon Group New York The New York Field Office conducted multiple investigations into insider trading Targets of this investigation included Wall Street analysts and insiders, lawyers, hedge fund analysts and traders, company insiders, and professional consulting firms Insiders from corporations such as McKinsey Company, International Business Machines, Advanced Micro Devices, and Goldman Sachs have been charged for the unauthorized release of proprietary corporate information The most prominent individual convicted in the investigation to date is Raj Rajaratnam, the founder of the 7 billion Galleon Group hedge fund Mr Rajaratnam was convicted in May 2011 by a federal jury on all 14 counts he faced pertaining to his insider trading activity and was subsequently sentenced to 11 years imprisonment This investigation has shown the FBI s propensity to use all tools available at its discretion, including Title IIIs, to combat financial crimes As o f September 30, 2011, 48 convictions have been obtained in this wide-ranging FBI probe into illicit insider trading activity on Wall Street and in the boardrooms across the United States. The continued uncertainty and volatility of today s financial markets could be measured by the Dow Jones Industrial Average movement from 12,681 on July 22, 2011, to 10,655 on October 3, 2011 As a result of such tumultuous markets, the FBI witnessed a steady rise in securities and commodities frauds as investors sought alternative investment opportunities With the development of new schemes and trends such as securities market manipulation via cyber intrusion, the increase in commodities fraud, the continued rise of Ponzi schemes, and foreign-based reverse merger market manipulation schemes securities and commodities fraud is on the rise Since 2008, securities and commodities fraud investigations have increased by 52 percent, and the FBI currently has over 1,800 pending investigations During this perio d, the losses associated with these types of schemes have increased to billions of dollars The losses are associated with depreciative market value of businesses, reduced or nonexistent return on investments, and legal and investigative costs The victims of securities and commodities frauds include individual investors, financial institutions, public and private companies, government entities, pension funds, and retirement funds. The continuing integration of global capital markets has created unprecedented opportunities for U S businesses to access capital and investors to diversify their portfolios Whether through individual brokerage accounts, college savings plans, or retirement accounts e g 401k plans , more and more Americans are choosing to invest in the U S securities and commodities markets This growth has led to a corresponding growth in the amount of fraud and misconduct seen in these markets The creation of complex investment vehicles and the tremendous increase in the amoun t of money being invested have created greater opportunities for individuals and businesses to perpetrate fraudulent investment schemes The recent financial crisis led to the identification of numerous investment fraud schemes, many of which were Ponzi schemes The number of investment frauds continues to grow as investors remain susceptible in the current uncertainty of the global economy The securities and commodities frauds being investigated include market manipulation, investment frauds, and miscellaneous matters such as broker embezzlement In response to this growing threat, the FBI has increased the number of agents addressing it by 61 percent, an increase of approximately 91 agents since 2008.Additionally, the FBI works closely with various governmental and private entities to investigate and prevent fraudulent activity in the financial markets In an effort to optimize workforce needs, many FBI field offices operate task forces and working groups with other law enforcement and r egulatory agencies These agencies include the SEC, U S Attorney s Offices USAO , CFTC, FINRA, USPIS, and the IRS, among others, serving as force multipliers to more effectively address the securities and commodities fraud threat Nationally, the FBI participates in several working groups and task forces such as the FFETF The FFETF was established by President Obama to coordinate the efforts of the DOJ at all levels of government to disrupt and dismantle significant large-scale criminal enterprises. Valuable partnerships have been instrumental in orchestrating national financial crimes takedowns, or sweeps, during the last few years By coordinating fraud cases into a nationwide takedown, the FBI and its partners have raised public awareness of its enforcement efforts and deterred future fraud Operation Broken Trust OBT was a multi-agency national initiative which coordinated the efforts of government agencies against various securities fraud threats OBT featured criminal, civil, and commu nity outreach components The sweep targeted individuals and companies who engaged in criminal and civil securities fraud which occurred sometime from August 16, 2010 through December 1, 2010 For the criminal component coordinated by the FBI, this included arrests, complaints, informations indictments, convictions, sentences, and seizures forfeitures The focus of the sweep was schemes to defraud individual investors, affinity fraud, prime bank fraud, commodities frauds, and market manipulation cases such as pump and dump schemes. On December 6, 2010, the FFETF-Securities Fraud Working Group held a national press conference to announce the conclusion of OBT U S Attorney General Eric Holder gave remarks on behalf of DOJ In coordination with the national press conference, local press conferences were held across the country by U S attorneys participating in the operation The operation involved 343 criminal defendants nationwide and more than 120,000 victims with losses attributable to alleg ed criminal activity of more than 8 billion. The following are the most prevalent types of securities and commodities fraud. Investment Fraud These schemes, sometimes referred to as high yield investment fraud, involve the illegal sale or purported sale of financial instruments Financial instruments are defined broadly as any contract that gives rise to a financial asset of one entity and a financial liability or equity instrument to another entity These instruments can be a tradable asset of any kind, to include registered securities and commodities and unregistered securities e g a simple promissory note between the fraudster and his her victim investors Schemes take on many forms, and perpetrators quickly alter schemes as they are thwarted by law enforcement The typical investment fraud schemes are characterized by offers of low - or no-risk investments, guaranteed returns, overly consistent returns, complex strategies, or unregistered securities These schemes often seek to victimize a ffinity groups such as groups with a common religion or ethnicity to utilize the common interests to build trust to effectively operate the investment fraud against them The perpetrators range from professional investment advisers and hedge funds to those trusted and interacted with daily, such as a neighbor or sports coach The fraudster s ability to foster trust makes these schemes so successful, and investors should use scrutiny and gather as much information as possible before entering into any new investment opportunities Investors can find background information on registered investment advisers at and registered brokers and brokerage firms at The following are additional definitions of the most common investment fraud scheme variations. Ponzi Schemes A Ponzi scheme is an investment fraud that involves the payment of purported returns to existing investors from funds contributed by new investors Ponzi schemes often share common characteristics, such as offering overly consistent re turns, unregistered investments, high returns with little or no risk, or secretive or complex strategies This arrangement gives investors the impression there is a legitimate, money-making enterprise behind the subject s story, but in reality, unwitting investors are the only source of funding. Affinity Fraud Perpetrators of affinity fraud take advantage of the tendency of people to trust others with whom they share similarities such as religion or ethnic identity to gain their trust and money. Pyramid Schemes In pyramid schemes, as in Ponzi schemes, money collected from new participants is paid to earlier participants In pyramid schemes, however, participants receive commissions for recruiting new participants into the scheme. Prime Bank Investment Fraud In these schemes, perpetrators claim to have access to a secret trading program endorsed by large financial institutions such as the Federal Reserve Bank, Treasury Department, World Bank, International Monetary Fund, etc Perpetrators oft en claim the unusually high rates of return and low risk are the result of a worldwide secret exchange open only to the world s largest financial institutions Victims are often drawn into prime bank investment frauds because the criminals use sophisticated terms, legal-looking documents, and claim the investments are insured against loss. Advance Fee Fraud Advance fee schemes require victims to advance relatively small sums of money in the hope of realizing much larger gains Not all advance fee schemes are investment frauds In those that are, however, victims are told that in order to have the opportunity to be an investor in an initial offering of a promising security, investment or commodity, etc , the victim must first send funds to cover taxes or processing fees, etc. Promissory Notes These are generally short-term debt instruments issued by little-known or nonexistent companies The notes typically promise high returns with little or no risk and are typically not registered as securi ties with the appropriate regulatory agencymodities Fraud Commodities fraud is the sale or purported sale of a commodity through illegal means Commodities are raw materials or semi-finished goods that are relatively uniform in nature and are sold on an exchange e g gold, pork bellies, orange juice, and coffee Most commodities frauds involve illicit marketing or trading in commodities futures or options Perpetrators often offer investment opportunities in the commodities markets that falsely promise high rates of return with little or no risk Two common types of commodities investment frauds include. Foreign Currency Exchange Forex Fraud The perpetrators of Forex frauds entice individuals into investing in the spot foreign currency market through false claims and high-pressure sales tactics Foreign currency firms that engage in this type of fraud invest client funds into the Forex market not with the intent to conduct a profitable trade for the client, but merely to churn the client s ac count Churning creates large commission charges benefiting the trading firm In other Forex frauds, the perpetrator creates artificial account statements that reflect purported investments when, in reality, no such investments have been made Instead, the money has been diverted for the perpetrator s personal use. Precious Metals Fraud These fraud schemes offer investment opportunities in metals commodities such as rare earth, gold, and silver The perpetrators of precious metals frauds entice individuals into investing in the commodity through false claims and high-pressure sales tactics Oftentimes in these frauds, the perpetrators create artificial account statements that reflect purported investments when, in reality, no such investments have been made Instead, the money has been diverted for the perpetrators personal use. Market Manipulation These schemes, commonly referred to as pump-and-dumps, are effected by creating artificial buying pressure for a targeted security, generally a low - trading volume issuer in the over-the-counter securities market that is largely controlled by the fraud perpetrators This artificially increased trading volume has the effect of artificially increasing the price of the targeted security i e the pump , which is rapidly sold off into the inflated market for the security by the fraud perpetrators i e the dump These actions result in illicit gains to the perpetrators and losses to innocent third-party investors Typically, the increased trading volume is generated by inducing unwitting investors to purchase shares of the targeted security through false or deceptive sales practices and or public information releases. A modern variation on these schemes involves largely foreign-based computer criminals gaining unauthorized access and intruding into the online brokerage accounts of unsuspecting victims in the United States These intruded victim accounts are then used to engage in coordinated online purchases of the targeted security to affect manipulation while the fraud perpetrators sell their preexisting holdings in the targeted security into the inflated market. Broker Embezzlement These schemes involve illicit and unauthorized actions by brokers to steal directly from their clients Such schemes may be facilitated by the forging of client documents, doctoring of account statements, unauthorized trading funds transfer activities, or other conduct in breach of the broker s fiduciary responsibilities to the victim client. Late-Day Trading These schemes involve the illicit purchase and sale of securities after regular market hours Such trading is restricted in order to prevent individuals from profiting on market-moving information which is released after the close of regular trading Unscrupulous traders attempt to illegally exploit such opportunities by buying or selling securities at the market close price, secure in the knowledge that the market-moving information will generate illicit profits at the opening of trading on t he following day. As of the end of FY 2011, the FBI was investigating 1,846 cases of securities and commodities fraud and had recorded 520 indictments informations and 394 convictions against this criminal threat Additional notable accomplishments in FY 2011 include 8 8 billion in restitution orders 36 million in recoveries 113 million in fines and 751 million in forfeitures The chart below reflects securities and commodities fraud pending cases from FY 2007 through FY 2011.Joseph Blimline, Provident Royalties Dallas This investigation centered on Joseph Blimline, who orchestrated one of North Texas largest oil and gas investment Ponzi schemes, defrauding 7,700 investors of over 485 million Beginning in 2006, Blimline and others involved at Provident Royalties made false representations and failed to disclose other material facts to their investors The investors were not told that Blimeline had received millions of dollars in unsecured loans and had been previously charged with securiti es fraud Blimline issued approximately 20 oil and gas offerings, raising over several hundred million dollars from investors Blimline used a significant amount of the money raised in these offerings to purchase oil and gas assets from earlier offerings and to pay dividends to earlier investors to facilitate the scheme On August 31, 2010, Blimline pled guilty to an information Blimline is awaiting sentencing in January 2012.A O Entities Richmond A O originally sold fractionalized, no-risk interests in life insurance policies, primarily to elderly investors, with promised rates of return from 9-15 percent A O bank accounts were under the control of the owners of A O, who diverted more than 50 million for their personal benefit On September 27, 2011, co-conspirator Chris Allmendinger was sentenced to 45 years imprisonment for his role in the scheme On September 28, 2011, Adley Adulwahab was sentenced to 60 years imprisonment, which is the second-longest white-collar criminal sentence in t he history of the Eastern District of Virginia As of September 30, 2011, seven subjects have been sentenced to federal prison terms ranging from three years to 60 years for their roles in this Ponzi scheme, which bilked more than 800 investors out of more than 100 million This case was investigated jointly with the Virginia Financial and Securities Fraud Task Force. Nicholas Cosmo New York Nicholas Cosmo was the owner and president of Agape World, Inc and Agape Merchant Advance LLC AMA Cosmo, through Agape and AMA, solicited money from investors purportedly to provide bridge loans to companies Cosmo and his sales force promised investors returns of 12 to 15 percent per month The investor funds were ultimately used to pay Cosmo s personal expenses, pay back previous investors, and speculate in future contracts In April 2009, Nicholas Cosmo was indicted on charges of mail fraud in connection with operating a several-hundred-million-dollar Ponzi scheme On October 14, 2011, Cosmo was senten ced to 25 years in prison He was also ordered to pay 179 million in restitution to more than 4,000 victims and agreed to an asset forfeiture judgment in the amount of 409,305,000 as part of his sentence. The FBI s mission in health care fraud HCF is to oversee the FBI s HCF initiatives by providing national guidance and assistance to support HCF investigations targeting individuals and organizations who are defrauding the public and private health care systems The FBI works closely with its federal, state, and local law enforcement partners the Centers for Medicare and Medicaid Services CMS and other government and privately sponsored program participants to address vulnerabilities, fraud, and abuse. All health care programs are subject to fraud however, Medicare and Medicaid programs are the most visible Estimates of fraudulent billings to health care programs, both public and private, are estimated between 3 and 10 percent of total health care expenditures The fraud schemes are not sp ecific to any area, but they are found throughout the entire country The schemes target large health care programs, public and private, as well as beneficiaries Certain schemes tend to be worked more often in certain geographical areas, and certain ethnic or national groups tend to also employ the same fraud schemes The fraud schemes have, over time, become more sophisticated and complex and are now being perpetrated by more organized crime groups. Emerging Trends and Projections HCF is expected to continue to rise as people live longer This increase will produce a greater demand for Medicare benefits As a result, it is expected that the utilization of long - and short-term care facilities such as skilled nursing, assisted living, and hospice services will expand substantially in the future Additionally, fraudulent billings and medically unnecessary services billed to health care insurers are prevalent throughout the country These activities are becoming increasingly complex and can be p erpetrated by corporate-driven schemes and systematic abuse by providers. The most recent CMS statistical estimates project that total health care expenditures are estimated to total 2 4 trillion, representing 14 percent of the gross domestic product GDP By the year 2016, CMS estimates total health care spending to exceed 4 14 trillion, representing 19 6 percent of the GDP. With health care expenditures consistently increasing, it is especially important to coordinate all investigative efforts to combat fraud within the health care system The FBI is the primary investigative agency in the fight against HCF and has jurisdiction over both the federal and private insurance programs With more than 1 trillion being spent in the private sector on health care and its related services, the FBI s efforts are crucial to the success of the overall program The FBI leverages its resources in both the private and public arenas through investigative partnerships with agencies such as the Health and Hum an Services-Office of Inspector General HHS-OIG , the Food and Drug Administration FDA , Drug Enforcement Administration, Defense Criminal Investigative Service, Office of Personnel Management, IRS-CID, and various state and local agencies On the private side, the FBI is actively involved with national groups such as the National Health Care Anti-Fraud Association and the National Insurance Crime Bureau NICB , as well as many other professional and grassroots efforts to expose and investigate fraud within the system. Collaboration In furtherance of the FBI s efforts to combat HCF in the United States, the FBI participates in various initiatives with federal, state, and local agencies At the Headquarters level, the FBI participates in a senior level working group which includes the CMS, DOJ, HHS-OIG, and other agencies to identify and assess health care industry vulnerabilities and make recommendations to protect the industry and the public through a coordinated effort At the Headquarter s level, the FBI is also involved in coordination meetings at the DOJ which include various DOJ components involved in the fight against HCF National-level liaison is also maintained with federal law enforcement agencies, the National Association of Medicaid Fraud Control Units, and other partners. Throughout the country, FBI field offices participate in HCF working groups which involve law enforcement agencies, prosecutors, regulatory agencies, and health insurance industry professionals to identify the various crime problems involving HCF The FBI develops national and local initiatives when large-scale fraud is detected, which may involve participation by several FBI field offices and other law enforcement agencies. During the past year, the FBI continued to identify and analyze industry fraud trends through input from private and public health care program experts Present areas of concern include DME hospital fraud physician fraud home health agencies beneficiary-sharing chiropractic, pain management, and associated drug diversion physical therapists prescription drugs multidisciplinary fraud and identity theft which involves physician identifiers used to fraudulently bill government and private insurance programs. As part of our national strategy to address HCF, the FBI cooperates with the DOJ and the various USAOs throughout the country to pursue offenders through parallel criminal and civil remedies These cases typically target large-scale medical providers, such as hospitals and corporations, who engage in criminal activity and commit fraud against the government which undermines the credibility of the health care system As a result, a great deal of emphasis is placed on recovering the illegal proceeds through seizure and forfeiture proceedings as well as substantial civil settlements Upon the successful conviction of HCF offenders, the FBI provides assistance to various regulatory and state agencies, which may seek exclusion of convicted medical providers from further participation in the Medicare and Medicaid health care systems. Data Mining Techniques The FBI and the health care industry continue to expand their technology and intelligence assessments through the use of sophisticated data-mining techniques to identify patterns of fraud, systemic weaknesses, and aberrant billing activity. In 2005, the FCS developed the Electronic Bank Records Initiative EBRI The EBRI was implemented to identify and develop a process for obtaining electronic digital format records from financial institutions Historically, financial institutions have provided paper copies of records to law enforcement when they receive a subpoena from the government These records are generally maintained by the banks in an electronic format The time it takes the financial institution to make the copies of the records and for the investigative agencies to return the paper copies back to an electronic format for financial analysis creates a severe negative effect on the timelines s, effectiveness, and efficiency of investigations In an effort to increase the efficiency of the process, a subpoena attachment was developed by the DOJ, FBI, and IRS-CID for the production of electronic records instead of paper copies The development included significant coordination with the financial institutions and their associations The subpoena attachment was not based upon new or expanded laws, regulations, or rules The attachment is merely meant to standardize and clarify the requests for electronic records according to the current federal rules of criminal and civil procedure In general terms, if a financial institution maintains records electronically, the requesting agency would be seeking to obtain the records electronically In addition, the scope of the records requested has not changed due to the subpoena attachment, with the exception of seeking the records electronically. The subpoena attachment was disseminated to FBI offices, IRS offices, and throughout the DOJ in No vember 2007 The goal of the DOJ, FBI, and IRS-CID is to inform and prepare financial institutions and their respective agencies for the use and response to the subpoena attachment This includes working with financial institutions during the transition period in coordinating the requests and associated responses to subpoenas In addition, it is anticipated the EBRI will greatly increase the efficiency of the financial records production process and provide significant costs savings to both the government and private industry. Through FY 2011, 2,690 cases investigated by the FBI resulted in 1,676 informations indictments and 736 convictions of HCF criminals It should be noted that numerous cases are pending plea agreements and trials The following notable statistical accomplishments are reflective in FY 2011 for HCF 1 2 billion in restitutions 1 billion in fines 96 million in seizures 320 million in civil restitution and over 1 billion in civil settlements The chart below reflects HCF pend ing cases from FY 2007 through FY 2011.Glaxosmithkline GSK San Juan Drugs manufactured at the GSK plant located in Cidra, Puerto Rico were not safe and or effective and, therefore, claims for payment of prescription drugs made by GSK to Medicare, state Medicaid programs, and other state and federal purchasers of prescription drugs were false or fraudulent GSK is accused of distributing reject drug product to the U S market and submitting false claims for drug products that were not safe and or effective Drugs affected include, but are not limited to, Avandamet, Coreg, Bactroban, Abreva, Cimetidine, and Kytril GSK allegedly lied to the FDA in order to conceal those violations GSK s violations of current good manufacturing practices include, but are not limited to, product mix-ups inadequate investigation of out-of-specification results detected during laboratory testing inadequate process validation and equipment calibration and substandard quality and control of the plant s water syste ms, resulting in microbial contamination of drug products On December 26, 2010, GSK pled guilty to charges relating to the manufacture and distribution of certain adulterated drugs A 600 million civil settlement under the False Claims Act was agreed upon in addition to 150 million in criminal fines and forfeiture. American Therapeutic Corporation Miami This matter was initiated by a civil qui tam filed unsealed by a relator The investigation into American Therapeutic Corporation ATC addressed an identified threat of community mental health center fraud within South Florida ATC has been identified as the largest community medical health center CMHC in Florida, and its owners and operators of facilities have submitted approximately 205 million in fraudulent claims to Medicare, with approximately 85 million being reimbursed ATC owners allegedly have been engaged in widespread fraud and have paid kickbacks to assisted living facilities in order to recruit patients for unnecessary group ther apy programs and partial hospitalization programs This investigation has brought greater awareness to the fraud and abuse of CMHCs within South Florida Payments to ATC have been suspended, thereby protecting the federal trust fund for Medicare On September 16, 2011, owner Lawrence Duran was sentenced to 50 years in prison and restitution of 87,533,863 On September 19, 2011, owner Marianella Valera was sentenced to 35 years in prison and restitution of 87,533,863 Over 20 defendants were indicted and arrested as part of the investigation, which was worked jointly by FBI Miami and HHS-OIG, along with trial attorneys from DOJ. HCF is carried out by many segments of the health care system using various methods Some of the most prevalent schemes include. Billing for Services not Rendered These schemes can have several meanings and could include any of the following. No medical service of any kind was rendered. The service was not rendered as described in the claim for payment. The service was pre viously billed and the claim had been paid. Upcoding of Services This type of scheme involves a billing practice where the health care provider submits a bill using a procedure code that yields a higher payment than the code for the service that was truly rendered The upcoding of services varies according to the provider type Examples of service upcoding include. A routine, follow-up doctor s office visit being billed as an initial or comprehensive office visit. Group therapy being billed as individual therapy. Unilateral procedures being billed as bilateral procedures.30-minute sessions being billed as 50 minute sessions. Upcoding of Items A medical supplier is upcoding when, for example, the supplier delivers to the patient a basic, manually propelled wheelchair, but bills the patient s health insurance plan for a more expensive motorized version of the wheelchair. Duplicate Claims A duplicate claim usually involves a certain item or service for which two claims are filed In this scheme, a n exact copy of the claim is not filed a second time rather, the provider usually changes a portion, most often the date of service on the claim, so that the health insurer will not realize the claim is a duplicate In other words, the exact claim is not filed twice, but one service is billed two times, in an attempt to be paid twice for one service. Unbundling This is the practice of submitting bills in a fragmented fashion in order to maximize the reimbursement for various tests or procedures that are required to be billed together at a reduced cost For example, clinical laboratory tests may be ordered individually, or in a panel i e a lipid panel, an arthritis panel, a hepatitis panel Billing tests within each panel as though they were done individually on subsequent days is an example of unbundling. Excessive Services These schemes typically involve the provision of medical services or items which are in excess of the patient s actual needs Examples of excessive services include. A med ical supply company delivering and billing for 30 wound care kits per week for a nursing home patient who only requires a change of dressings once per day. Daily medical office visits conducted and billed for when monthly office visits would be more than adequate. Medically Unnecessary Services A service is medically unnecessary and may give rise to a fraudulent scheme when the service is not justified by the patient s medical condition or diagnosis For example, a claim for payment for an electrocardiogram test may be fraudulent if the patient has no conditions, complaints, or factors which would necessitate the test. Kickbacks A health care provider or other person engages in an illegal kickback scheme when he or she offers, solicits, pays, or accepts money, or something of value, in exchange for the referral of a patient for health care services that may be paid for by Medicare or Medicaid A laboratory owner and doctor each violate the Anti-Kickback Statute when the laboratory owner pay s the doctor 50 for each Medicare patient a doctor sends to the laboratory for testing Although kickbacks are often paid in cash based on a percentage of the amount paid by Medicare or Medicaid for a service, kickbacks may take other forms such as jewelry, free paid vacations, or other valuable items. Health Care Fraud Prevention Measures. HCF is not a victimless crime It increases health care costs for everyone It is as dangerous as identity theft Fraud has left many thousands of people injured Participation in HCF is a crime. Keeping America s health system free from fraud requires active participation from each of us The large number of patients, treatments, and complex billing practices attracts criminals skilled in victimizing innocent people by committing fraud. What is Health Care Fraud. Altered or fabricated medical bills and other documents. Excessive or unnecessary treatments. Billing schemes, such as. charging for a service more expensive than the one provided. charging for services that were not provided. duplicate charges. False or exaggerated medical disability. Collecting on multiple policies for the same illness or injury. Tips to Protect Yourself Against Health Care Fraud. Protect your health insurance information card like a credit card. Beware of free services is it too good to be true. Review your medical bills, such as your explanation of benefits, after receiving health care services Check to ensure the dates and services are correct to ensure you get what you paid for. If you suspect HCF, contact your insurance company You can also contact your local FBI field office and or the local Department of HHS-OIG Office. The mission of the Financial Institution Fraud Unit FIFU is to oversee the investigation of financial industry fraud schemes perpetrated by individuals, as well as criminal organizations, which target our nation s financial institutions. The FIFU protects the public s interest by educating individuals and businesses about pervasive financial industry fr aud schemes working closely with federal, state, and local law enforcement agencies and maintaining liaison contacts with our regulatory and industry partners In addition, the FIFU obtains relevant intelligence data to prepare proactive strategies to neutralize current and emerging financial threats The FIFU has oversight responsibilities of the mortgage fraud, financial institution fraud, credit card fraud, and bankruptcy fraud subprograms. In 2011, mortgage loan originations were at their lowest levels since 2001 This can be partially attributed to tighter underwriting standards following the financial crisis This decrease in loan originations has resulted in a corresponding decrease in new loan origination fraud investigations Foreclosures and delinquencies, on the other hand, have skyrocketed over the past few years, with a corresponding increase in mortgage fraud schemes aimed at distressed homeowners For the first time in recent history, distressed homeowner fraud has displaced lo an origination fraud as the number one mortgage fraud threat in many offices Though the FBI considers loan origination fraud to be the most egregious type of mortgage fraud because of the high dollar losses attendant therewith, the FBI has now adapted its focus to include other new and emerging schemes. Mortgage fraud schemes employ some type of material misstatement, misrepresentation, or omission relating to a real estate transaction which is relied on by one or more parties to the transaction These schemes include. Foreclosure rescue schemes. Loan modification schemes. Illegal property flipping. Builder bailout condo conversion. Equity skimming. Silent second. Home equity conversion mortgagemercial real estate loans. Mortgage fraud is a part of the FIF subprogram within the FBI s WCCP The FBI investigates mortgage fraud in two distinct areas fraud for profit and fraud for housing Those who commit mortgage fraud for profit are often industry insiders using their specialized knowledge or autho rity to commit or facilitate the fraud Current investigations and widespread reporting indicate a high percentage of mortgage fraud involves collusion by industry insiders, such as bank officers, appraisers, mortgage brokers, attorneys, loan originators, and other professionals engaged in the industry Fraud for housing typically represents illegal actions conducted solely by the borrower, who is motivated to acquire and maintain ownership of a house under false pretenses such as misrepresented income and asset information on a loan application. One of the ways the FBI becomes aware of mortgage fraud is through the analysis of suspicious activity reports SARs , which are filed by federally insured financial institutions Mortgage fraud SARs have increased from 6,936 in FY 2003 to 93,508 in FY 2011 These SARs provide valuable intelligence in mortgage fraud trends and can lead to the initiation of mortgage fraud cases as well as the enhancement of current FBI investigations. Note Of those SA Rs that report a dollar loss, approximately 82 percent do not contain a dollar loss amount. FBI Response With elevated levels of mortgage fraud, the FBI has continued to dedicate significant resources to the threat The FBI has increased the number of agents who investigate mortgage fraud cases from 120 special agents in FY 2007 to 325 special agents in FY 2011 FBI pending mortgage fraud cases have increased from 1,199 in FY 2007 to 2,691 in FY 2011, with a peak of 3,129 in FY 2010.The FBI employs advanced and or sophisticated investigative techniques, such as undercover operations and wiretaps, which result in the collection of valuable evidence and provide an opportunity to apprehend criminals in the commission of their crimes This ultimately reduces the losses to individuals and financial institutions The FBI has also instituted several intelligence initiatives to support mortgage fraud investigations and has improved law enforcement and industry relationships The FBI has established methodology to proactively identify potential mortgage fraud targets using tactical analysis coupled with advanced statistical correlations and computer technologies. In September 2009, the FBI established the FIC to provide tactical analysis of intelligence datasets and financial databases The FIC uses evolving technology and data exploitation techniques to create targeting packages to identify the most egregious criminal enterprises and to enhance current criminal investigations The FIC has worked jointly with the FIFU to assist the field offices by creating mortgage fraud targeting packages. The FBI continues to enhance liaison partnerships within the mortgage industry and law enforcement to promote mortgage fraud awareness and share intelligence As part of the effort to address mortgage fraud, the FBI continues to support 25 mortgage fraud task forces and 67 working groups The FBI also participates in the DOJ National Mortgage Fraud and National Bank Fraud Working Groups, as well as the FFETF The FFETF s mission is to enhance the government s effectiveness in sharing information to help prevent and combat financial fraud FBI personnel routinely participate in various mortgage industry conferences and seminars, including those sponsored by the Mortgage Bankers Association MBA Collaborative educational efforts are ongoing to raise public awareness of mortgage fraud schemes through the publication of the annual Mortgage Fraud Report and this report, and through the dissemination of information jointly or between various industry and consumer organizations Analytic products are routinely distributed to a wide audience, including public and private sector industry partners, the intelligence community, and other federal, state, and local law enforcement partners. In June 2010, Operation Stolen Dreams was the largest collective enforcement effort ever brought to bear in confronting mortgage fraud This FIFU-led initiative involved 1,517 criminal defendants nationwide, who were allegedly responsible for more than 3 billion in losses Additionally, the operation resulted in 191 civil enforcement actions and the recovery of more than 196 million. The FBI remains committed to its responsibility to aggressively investigate mortgage fraud, as well as engage with the mortgage industry in identifying fraud trends and educating the public To maximize current resources, the FBI is relying on intelligence collection and analysis to identify emerging trends and egregious offenders and strong relationships with law enforcement and regulatory agency partners to disrupt and dismantle the criminal organizations and individuals engaging in these fraud schemes. Through FY 2011, FBI investigations resulted in 1,223 informations and indictments and 1,082 convictions of mortgage fraud criminals The following notable statistical accomplishments are reflective in FY 2011 for mortgage fraud 1 38 billion in restitutions 116 3 million in fines seizures valued at 15 7 million and 7 33 million in forfeitures. Luis Belevan, The Guardian Group, LLC Phoenix Luis Belevan pled guilty in federal court to conspiring to commit wire fraud and mail fraud during the period of 2009 to 2010 Belevan and his co-conspirator were charged with defrauding at least 1,800 local distressed homeowners out of a 1,595 upfront fee for bogus promises of assistance in avoiding home foreclosure Belevan used false promises on the company s website to convince consumers that it could help them save their home if the homeowner paid an upfront fee The homeowners were never helped, and they were scammed out of their hard-earned money Belevan generated almost 3 million in funds in just nine months, which he and others used for personal expenses and for other failed ventures. Howard Shmuckler, The Shmuckler Group Washington, D C From 2009 to 2010, Howard Shmuckler owned and operated a mortgage-rescue business known as The Shmuckler Group TSG , which claimed to be the largest, most successful group of professionals coming together to help home owners keep their homes in a manageable and affordable manner Operating his business at various times in McLean and Vienna, Virginia, Shmuckler is accused of misrepresenting that TSG had a success rate of 97 percent and falsely portraying himself as an attorney licensed in Virginia Based on these false representations, clients paid fees ranging from 2,500 to 25,000 to modify the terms of their mortgages Shmuckler was indicted and is awaiting trial, currently scheduled for early 2012 This case was jointly investigated by the FBI, FDIC-OIG, and SIGTARP. Carl Cole David Crisp Sacramento In January 2011, a 56-count indictment was returned against 10 subjects for their roles in a large-scale loan origination scheme The scheme included approximately 140 fraudulent mortgage transactions on 108 properties with loans totaling 142 million This investigation was initiated in December 2006 Carl Cole and David Crisp, partners in Crisp and Cole Real Estate C CRE , utilized CCRE to orchestrate an extensive loan origination mortgage fraud scheme The scheme involved several mortgage brokers, appraisers, realtors, loan officers, certified public accountants, bank financial institution employees, straw buyers, title companies, and builders. Mortgage Fraud Schemes and Trends. Foreclosure Rescue Schemes The perpetrators identify homeowners who are in foreclosure or at risk of defaulting on their mortgage loan The perpetrators then mislead the homeowners into believing they can save their homes by transferring the deed or putting the property in the name of an investor The perpetrators profit by selling the property to an investor or straw borrower, creating equity using a fraudulent appraisal, and stealing the seller proceeds or fees paid by the homeowners The homeowners are sometimes told they can pay rent for at least a year and repurchase the property once their credit has been reestablished However, the perpetrators fail to make the mortgage pa yments and usually the property goes into foreclosure. Loan Modification Schemes Scammers purport to assist homeowners who are delinquent in their mortgage payments and are on the verge of losing their home by offering to renegotiate the terms of the homeowners loan with the lender The scammers, however, demand large fees up front and often negotiate unfavorable terms for the clients, or do not negotiate at all Usually, the homeowners ultimately lose their homes This scheme is similar to a foreclosure rescue scam. Illegal Property Flipping Property is purchased, falsely appraised at a higher value, and then quickly sold What makes property flipping illegal is that the appraisal information is fraudulent The schemes typically involve one or more of the following fraudulent appraisals falsified loan documentation inflated buyer income or kickbacks to buyers, investors, property loan brokers, appraisers, and title company employees. Builder Bailout Condo Conversion Builders facing rising inv entory and declining demand for newly constructed homes employ bailout schemes to offset losses Builders find buyers who obtain loans for the properties The buyers then allow the properties to go into foreclosure In a condo-conversion scheme, apartment complexes purchased by developers during a housing boom are converted into condos When the market declines, developers have excess inventory of units Developers recruit straw buyers with cash-back incentives and inflate the value of the condos to obtain a larger sales price at closing In addition to failing to disclose the cash-back incentives to the lender, the straw buyers income and asset information are often inflated in order for them to qualify for properties that they otherwise would be ineligible or unqualified to purchase. Equity Skimming An investor may use a straw buyer, false income documents, and false credit reports to obtain a mortgage loan in the straw buyer s name Subsequent to closing, the straw buyer signs the property over to the investor in a quit claim deed, which relinquishes all rights to the property and provides no guaranty to title The investor does not make any mortgage payments and rents the property until foreclosure takes place several months later. Silent Second The buyer of a property borrows the down payment from the seller through the issuance of a nondisclosed second mortgage The primary lender believes the borrower has invested his own money in the down payment, when in fact, it is borrowed The second mortgage may not be recorded to further conceal its status from the primary lender. Home Equity Conversion Mortgage HECM A HECM is a reverse mortgage loan product insured by the Federal Housing Administration to borrowers who are 62 years or older, own their own property or have a small mortgage balance , occupy the property as their primary residence, and participate in HECM counseling It provides homeowners access to equity in their homes, usually in a lump sum payment Perpetrators rec ruit seniors through local churches, investment seminars, and television, radio, billboard, and mailer advertisements The scammers then obtain a HECM in the name of the recruited homeowner to convert equity in the homes into cash The scammers keep the cash and pay a fee to the senior citizen or take the full amount unbeknownst to the senior citizen No loan payment or repayment is required until the borrower no longer uses the house as a primary residence In the scheme, the appraisals on the home are vastly inflated and the lender does not detect the fraud until the homeowner dies and the true value of the property is discoveredmercial Real Estate Loans Owners of distressed commercial real estate obtain financing by creating bogus leases and using these fake leases to exaggerate the building s profitability, thus inflating their appraisal values using the income method approach These false leases and appraisals trick lenders into extending loans to the owner As cash flows are restricted to the borrower, property repairs are neglected By the time the commercial loans are in default, the lender is oftentimes left with dilapidated and unusable or difficult-to-rent commercial property Many of the methods of committing mortgage fraud that are found in residential real estate are also present in commercial loan fraud. Air Loans This is a nonexistent property loan where there is usually no collateral Air loans involve brokers who invent borrowers and properties, establish accounts for payments, and maintain custodial accounts for escrows They may establish an office with a bank of telephones, each one used as the fake employer, appraiser, credit agency, etc to fraudulently deceive creditors who attempt to verify information on loan applications. For additional information regarding mortgage fraud schemes and trends, please see the FBI Annual Mortgage Fraud Report which can be found at. Mortgage Fraud Prevention Measures. Tips to Protect Yourself Against Mortgage Fraud. Get refer rals for real estate and mortgage professionals Check the licenses of the industry professionals with state, county, or city regulatory agencies. An outrageous promise of extraordinary profit in a short period of time signals a problem. Be wary of strangers and unsolicited contacts, as well as high-pressure sales techniques. Look at written information, to include recent comparable sales in the area and other documents such as tax assessments to verify the value of the property. Understand what you are signing If you do not understand, re-read the documents or seek assistance from an attorney or third party who represents your interest. Review the title history of the home you are anticipating to purchase to determine if the property has been sold multiple times within a short period It could mean that this property has been flipped, and the value falsely inflated. Know and understand the terms of your mortgage Check your personal information against the information as listed on the loan doc uments to ensure it is accurate and complete. Never sign any loan documents that contain blanks This leaves you vulnerable to fraud. Check out the tips on the MBA website at for additional advice on avoiding mortgage fraud. Tips to Protect Yourself Against Mortgage Debt Elimination Schemes. Be aware of e-mails or web-based advertisements that promote the elimination of mortgage loans, credit card, and other debts while requesting an up-front fee to prepare documents to satisfy the debt The documents are typically entitled Declaration of Voidance, Bond for Discharge of Debt, Bill of Exchange, Due Bill, Redemption Certificate, or other similar variations These documents do not achieve what they purport. There is no easy method to relieve your debts. Borrowers may end up paying thousands of dollars in fees without the elimination or reduction of any debt. Tips to Protect Yourself Against Foreclosure Fraud Schemes. Be aware of offers to save homeowners who are at risk of defaulting on loans, or wh ose houses are already in foreclosure. Seek a qualified credit counselor or attorney to assist. Do not pay advanced fees for promised services. Financial Institution Fraud. FIF investigations are among the most demanding, difficult, and time-consuming cases undertaken by law enforcement in the area of white-collar crime Other than mortgage fraud, areas of primary investigative interest relative to FIF include insider fraud embezzlement and misapplication , check fraud, counterfeit negotiable instruments, check kiting, and fraud contributing to the failure of financial institutions. With the onset of the U S housing crisis that began in 2007, as well as the global financial crisis, mortgage fraud became a primary focus of the FIFU Although resources were shifted to combat mortgage fraud, the FBI continues to address other fraud schemes that impact our financial institutions FIF investigations related to emerging technologies and computer-related banking are taking on added significance among the nation s financial institutions. The FBI continues to concentrate its efforts on organized criminal groups involved in FIF These groups are often involved in the sale and distribution of stolen and counterfeit corporate checks, money orders, payroll checks, credit and debit cards, U S Treasury checks, and currency Furthermore, the groups involved in check and loan fraud schemes are often involved in illegal money laundering activities in an effort to conceal their illegal proceeds The FBI often utilizes asset forfeiture statutes to seize and forfeit the proceeds of criminal activity. The FBI, USPIS, and the IRS conduct criminal FIF investigations with the goal of disrupting and dismantling organized fraud rings, as well as addressing individuals who continue to manipulate internal controls either alone or in collusion with others The FBI strongly supports joint investigations to effectively utilize limited resources while strengthening investigations by tapping into each agency s ex pertise Federal agencies work with state and local law enforcement, regulators, and the financial institution industry to combat this crime problem. The FBI fosters relationships and partnerships within the banking industry to promote FIF awareness To raise awareness and increase accessibility to investigative personnel, the FBI has designated points of contact with relevant groups including the National Bank Fraud Working Group, local bank fraud working groups, and SAR working groups across the nation Included among these working groups are federal, state, and local law enforcement partners regulatory industry representatives and banking industry representatives. During FY 2011, cases pursued by the FBI resulted in 521 informations and indictments, and 429 convictions of FIF criminals The following are notable statistical accomplishments in FY 2011 for FIF 1 38 billion in restitutions 116 3 million in fines and seizures valued at 15 7 million The chart below reflects pending FIF cases f rom FY 2007 through FY 2011.Anthony Raguz Cleveland On September 27, 2011, Anthony Raguz, the former chief operating officer of the St Paul Croatian Federal Credit Union FCU , pleaded guilty to six counts, including bank fraud, money laundering, and bank bribery, for his role in one of the largest credit union failures in American history Raguz issued more than 1,000 fraudulent loans totaling more than 70 million to over 300 account holders in the Albanian and Croatian communities near Cleveland from 2000 to 2010 He accepted more than 1 million worth of bribes, kickbacks, and gifts in exchange for the fraudulent loans Raguz is one of 16 people charged for their roles in the credit union s collapse The failure of St Paul Croatian FCU resulted in a 170 million loss to the National Credit Union Share Insurance Fund. Gary Foster New York Gary Foster, a former vice president in Citigroup s treasury finance department, pleaded guilty on September 6, 2011, to bank fraud stemming from his embez zlement of more than 22 million from Citigroup Between September 2003 and June 2011, Foster first transferred money from various Citigroup accounts to Citigroup s cash account and then wired the money to his personal bank account at another bank Foster concealed his thefts by making various false accounting entries to create the appearance that the cash account was in balance and by placing a fraudulent contract or deal number in the reference line of the wire transfer instructions to give the appearance the wire transfers were actually in support of an existing Citigroup contract Foster used the money to buy real estate and luxury automobiles, including a Ferrari and a Maserati. William T Hernandez Louisville On September 20, 2011, William T Hernandez was sentenced to 41 months in prison and ordered to pay 453,819 in restitution for embezzling money from elderly customers Between October 2006 and June 2010, Hernandez, who was an investment banker employed by PNC Investments at the time , transferred money from investment accounts maintained with PNC Investments Hernandez deposited the money into a PNC account, then issued cashier s checks for his personal benefit and gain Hernandez pleaded guilty on June 21, 2011, to two counts of bank fraud. Financial Institution Failures. The FBI began to track the number of financial institution failure investigations in February 1986 A total of 157 banks failed in 2010, and 85 have failed since January 1, 2011, with the total number reaching 410 closures since 2007 Last year saw the highest number of bank failures since 1992, when 181 institutions closed By comparison, over 1,000 banks failed between 1987 and 1992, and more than 9,000 failed during the Great Depression, between 1930 and 1933.In addition, there are currently 865 U S banks on the Federal Deposit Insurance Corporation FDIC problem list as of June 30, 2011 Problem banks account for about 11 percent of all banking institutions As of October 2011, there were 7,433 FDIC-i nsured banking institutions with FDIC-insured deposits of almost 9 8 trillion and assets totaling over 13 6 trillion Of these institutions, about 4,600 are regulated by the FDIC and the remainder are supervised by the Office of the Comptroller of the Currency and the Federal Reserve In addition, the National Credit Union Administration is charged with supervising the 7,239 active federally insured credit unions. The vast majority of the failed banks have closed as a result of market conditions e g devalued properties associated with the current financial crisis Their solvency is usually compromised because of unsafe and unsound banking practices and inappropriate risk management tied to heavy concentration of commercial real estate and acquisition, development, and construction loans The catalyst for the failure has been the economic climate and not criminal activity Upon closer inspection of the loan portfolios, however, some level of fraud is usually uncovered in many of the loans. One of the outcomes of the financial crisis that began in 2007 was the failure of the largest number of U S banks since the savings and loan crisis of the 1980s As a result of the nature of this financial crisis, bank failure investigations have been opened at the FBI under a myriad of classifications, such as mortgage fraud, corporate fraud, and bank fraud Of the 1,719 pending FIF investigations, only 49 cases, or about 2 85 percent, involve criminal activity related to a failed federally insured financial institution. Donna Shebetich Pittsburgh On October 6, 2010, Donna Shebetich was indicted on five counts of filing false call reports to the FDIC Shebetich, a former vice president, director, and loan officer at Metropolitan Savings Bank, underreported millions of dollars in delinquent mortgages shortly before the Pittsburgh bank failed and its deposits were taken over by another bank Shebetich filed five false quarterly reports with the FDIC In the last report filed in November 2006, th ree months before the bank failed, she listed 0 in delinquent mortgages, when the bank really had more than 7 million in loans at least 30 days overdue The bank had roughly 15 8 million in assets in that quarter. Elexa Manos Pittsburgh On June 6, 2011, Elexa Manos pleaded guilty to one count of bank fraud in connection with a scheme to steal 4 million from the Dwelling House Savings Loan, a historic African-American financial institution founded in the 1890s, causing it to fail Beginning in about 2006, Manos stumbled upon and then exploited weaknesses in the internal controls of the savings and loan s Automated Clearing House ACH system Manos and other individuals she recruited, including her son, withdrew funds from 13 savings accounts via ACH debits or withdrawals The transactions were fraudulent because the accounts did not have sufficient funds available to cover the amounts being withdrawn, causing the bank to use all of its capital reserves to absorb the losses The funds were used to pay various vendors and creditors, as well as to fund electronic PayPal accounts Manos was sentenced to 150 months incarceration and ordered to pay 2 5 million in restitution. Robert E Maloney, Jr Atlanta On June 22, 2011, Robert E Maloney, Jr was indicted in a multi-million-dollar fraud and money laundering conspiracy This superseding indictment charged Maloney and two former top officers of First City Bank FCB of Stockbridge, Georgia with conspiracy to commit bank fraud, bank fraud, and related crimes in connection with misconduct at FCB in the years before the bank s seizure by state and federal authorities on March 20, 2009 Maloney assisted Mark Connor, the former bank president, and Clayton Coe, a senior lending officer, with massive insider dealing and fraud that preceded the bank s failure The dollar loss from the fraudulent activity caused FCB to fail and was a contributing factor in the failure of several other Georgia banks. The U S insurance industry consists of thousands of companies and collects nearly 1 trillion in premiums each year The size of the industry, unfortunately, makes it a prime target for criminal activity The Coalition Against Insurance Fraud CAIF estimates that the cost of fraud in the industry is as high as 80 billion each year This cost is passed on to consumers in the form of higher premiums. The FBI continues to identify the most prevalent schemes and the top echelon criminals defrauding the insurance industry in an effort to reduce insurance fraud The FBI works closely with the National Association of Insurance Commissioners, the NICB, the CAIF, as well as state fraud bureaus, state insurance regulators, and other federal agencies to combat insurance fraud In addition, the FBI is a member of the International Association of Insurance Fraud Agencies, an international nonprofit organization whose mission is to maintain an international presence to address insurance and insurance-related financial crimes on a global basis. With the coo peration of the insurance industry, through referrals from industry liaison and other law enforcement agencies, the FBI continues to target the individuals and organizations committing insurance fraud The FBI continues to initiate and conduct traditional investigations as well as utilize sophisticated techniques, to include undercover investigations, to apprehend the fraudsters Currently, the FBI is focusing a majority of its resources relating to insurance fraud on the following schemes. Premium Diversion Unauthorized Entities The most common type of fraud involves insurance agents and brokers diverting policyholder premiums for their own benefit There are a growing number of unauthorized and unregistered entities engaged in the sale of insurance-related products As the insurance industry becomes open to foreign players, regulation becomes more difficult Additionally, exponentially rising insurance costs in certain areas i e terrorism insurance, directors officers insurance, and corpor ations increase the possibility for this type of fraud. Insurance-Related Corporate Fraud Although corporate fraud is not unique to any particular industry, there have been instances involving insurance companies caught in the web of these schemes The temptations for fraud within the insurance industry can be greater during periods of financial downturns Insurance companies hold customer premiums, which are forbidden from operational use by the company However, when funding is needed, unscrupulous executives invade the premium accounts in order to pay corporate expenses This leads to financial statement fraud because the company is required to cover its tracks to conceal the improper utilization of customer premium funds. Viatical Settlement Fraud A viatical settlement is a discounted, pre-death sale of an existing life insurance policy on the life of a person known to have a terminal condition The parties to a viatical settlement include the insured party, insurance agent broker, insura nce company, viatical company broker, and the investor Viatical settlement fraud occurs when misrepresentations are made on the insurance policy applications, in effect hiding the fact that the party applying for a policy has already been diagnosed with a terminal condition Additionally, fraud occurs when misrepresentations are made to the investors by the viatical companies about life expectancies of insured parties and guaranteed high rates of return. Workers Compensation Fraud The Professional Employer Organization PEO industry operates chiefly to provide workers compensation insurance coverage to small businesses by pooling businesses together to obtain reasonable rates Workers compensation insurance accounts for as much as 46 percent of small business owners general operating expenses Due to this, small business owners have an incentive to shop workers compensation insurance on a regular basis This has made it ripe for entities that purport to provide workers compensation insurance to enter the marketplace, offer reduced premium rates, and misappropriate funds without providing insurance The focus of these investigations is on allegations that numerous entities within the PEO industry are selling unauthorized and non-admitted workers compensation coverage to businesses across the United States This insurance fraud scheme has left injured and deceased victims without workers compensation coverage to pay their medical bills. Disaster Fraud When a disaster occurs, there are often individuals who seek to profit via false claims of damages Additionally, there are also non-insurance-related disaster frauds as many organizations and individuals solicit contributions for the victims of the disaster Most of the organizations and individuals involved are legitimate however, there are some who are not Victims may be approached through unsolicited e-mails asking for donations to a legitimate-sounding organization The schemer will instruct the victim to send a donation via a money transfer. Following the 2005 Hurricanes Katrina, Rita and Wilma, billions of dollars in federal disaster relief poured into the Gulf Coast region In order to screen, de-conflict, and refer reports of fraud to law enforcement, DOJ established the National Center for Disaster Fraud NCDF for individuals to report suspected fraud related to any type of disaster relief The FBI and the NCDF have established a 24-hour hotline that the public can contact in order to report suspected scams and or fraud associated with disaster relief such as the BP oil spill relief effort The public can report suspicious activity by telephone at 866 720-5721 or by e-mail at. Staged Auto Accidents Perpetrators of staged auto accidents will either stage an accident with co-conspirators or maneuver innocent motorists into accidents Although the resulting property damage may be small, the perpetrators make large and illegal claims for fake injuries and property damage This type of fraud results in higher insura nce premiums for all drivers In some cases, innocent victims have been killed or injured in a staged auto accident gone wrong. Property Insurance Fraud Perpetrators of property insurance fraud seek to obtain payment that is higher than the value of the property damaged or destroyed, or intentionally destroy property that could not be sold Common examples include arson, scuttling of boats, and the ditching of vehicles in lakes or canals. During FY 2011, 140 cases investigated by the FBI resulted in 19 indictments informations, 13 arrests, and 21 convictions of insurance fraud criminals In addition, the FBI obtained 87 6 million in restitutions in FY 2011 for insurance fraud Although the FBI has focused its efforts on higher priority WCC matters, insurance fraud investigations continue to be important and are often addressed utilizing liaison efforts in conjunction with other federal, state, and local law enforcement The chart below reflects insurance fraud pending cases from FY 2007 throu gh FY 2011.Ronald Allen Newark On July 26, 2011, Ronald Allen was sentenced to 70 months in prison for diverting policyholder premiums for his own benefit Allen, along with a number of co-conspirators, sold insurance liability policies to high-risk business such as restaurants and bars Premiums were diverted and legitimate insurance policies were never issued A number of businesses that thought they had insurance had claims filed against them It could cost the businesses millions of dollars to cover claims that they thought were covered by the fictitious insurance policies The aforementioned premium diversion insurance fraud is the most common type of insurance fraud that is reported to the FBI. Mass marketing fraud is a general term for frauds which exploit mass-communication media, such as telemarketing, mass mailings, and the Internet Since the 1930s, mass marketing has been a widely accepted and exercised practice Advances in telecommunications and financial services technologies ha ve further served to spur growth in mass marketing, both for legitimate business purposes as well as for the perpetration of consumer frauds They share a common theme the use of false and or deceptive representations to induce potential victims to make advance fee-type payments to fraud perpetrators Although there are no comprehensive statistics on the subject, it is estimated mass marketing frauds victimize millions of Americans each year and generate losses in the hundreds of millions of dollars The following is a brief description of some of the key concepts and schemes associated with the mass marketing advance fee fraud crime problem. Advance Fee Fraud This category of fraud encompasses a broad variety of schemes which are designed to induce their victims into remitting upfront payments in exchange for the promise of goods, services, and or prizes Some of the most prevalent schemes being encountered are the following. Nigerian Letter Fraud Victims are contacted regarding substantial sums of money held in foreign accounts and are requested to pay various fees to secure their transfer to the United States in exchange for a portion of the total proceeds Alternatively, victims are asked to act as a U S agent in securing the release of such funds and are provided with counterfeit instruments which are to be cashed in order to pay any required fees, only to discover they must reimburse their financial institution for cashing a counterfeit instrument A variation of this fraud involves the use of fraudulent websites which have been created to resemble website pages of legitimate financial institutions to enhance the scheme s credibility and swindle greater amounts of money from victims The victims are directed to open accounts at the fictitious banks websites into which the perpetrators transfer the victims funds Victims cannot withdraw or transfer the funds when they log on to the fictitious bank websites and are prompted to pay additional taxes or fees before the funds can be released The funds are never released. Foreign Lottery Sweepstakes Fraud Victims are informed they have won a substantial prize in a foreign drawing, but must remit payment for various taxes fees to receive their winnings Alternatively, victims are provided with counterfeit instruments, representing a portion of the winnings, which are to be cashed in order to pay the required fees, only to discover they must reimburse their financial institution for cashing a counterfeit instrument. Overpayment Fraud Victims who have advertised some item for sale are contacted by buyers who remit counterfeit instruments, in excess of the purchase price, for payment The victims are told to cash the payments, deduct any expenses, and return or forward the excess funds to an individual identified by the buyer, only to discover they must reimburse their financial institution for cashing a counterfeit instrument. Recovery Impersonation Schemes Victims are contacted by perpetrators posing as law enforc ement officers, government employees, or lawyers to inform victims that the persons responsible for the original fraud schemes have been arrested or successfully sued and their bank accounts have been seized The victims are told the seized money is going to be returned to the victims, but the victims must first pay fees for processing and administrative services Recovery pitches often target victims many months or years after the original fraud schemes. The predominantly transnational nature of the mass marketing fraud crime problem presents significant impediments to effective investigation by any single agency or national jurisdiction Typically, victims will reside in one or more countries, perpetrators will operate from another, and the financial money services infrastructure of numerous additional countries are utilized for the rapid movement and laundering of funds For these reasons, the FBI is uniquely positioned to assist in the investigation of these frauds through its network o f legal attach legat offices located in over 60 U S Embassies around the world By leveraging its global presence and network of liaison contacts, the FBI has successfully cooperated with other domestic and foreign law enforcement agencies to combat, disrupt, and dismantle international mass marketing fraud groups The FBI participates in the International Mass Marketing Fraud Working Group IMMFWG , a multi-agency working group established to facilitate the multi-national exchange of information and intelligence, the coordination of cross-border operational matters, and the enhancement of public awareness of international mass marketing fraud schemes The current membership of the IMMFWG consists of law enforcement, regulatory, and consumer protection agencies from seven countries, including Australia, Belgium, Canada, the Netherlands, Nigeria, the United Kingdom, and the United States. Despite the best interagency enforcement efforts to combat mass marketing fraud, the FBI remains cogniza nt of the fact that the only enduring remedy for this crime problem lies in consumer education and fraud prevention programs Toward this end, the FBI has not only produced its own mass marketing fraud prevention materials, but coordinates on other public information efforts with the DOJ, FTC, and the USPIS, among others The FBI also supports a consumer fraud prevention website in conjunction with the USPIS which can be located on the web at Additionally, further information on mass marketing fraud schemes can be found at , and. As of the end of FY 2011, the FBI was investigating 96 cases of mass marketing fraud and, during FY 2011, recorded multiple indictments and convictions Although the FBI has focused its efforts on higher-priority financial crime matters, mass marketing fraud investigations continue to be addressed utilizing liaison efforts in conjunction with other federal, state, and local law enforcement agencies and the IMMFWG The chart below reflects mass marketing fraud pendi ng cases from FY 2007 through FY 2011.Foreign Lottery Sweepstakes Fraud New York This investigation centered on the activities of Israel-based telemarketing con men that pitched winnings in an international lottery sweepstakes primarily to elderly American victims The victims were informed they won the lottery, but first had to send over payment to cover taxes and fees to have the money released and sent to their account However, there was no lottery and the perpetrators would just keep the funds for personal use and continue to try to solicit victims for additional fees and taxes to release their alleged winnings A total of nine subjects were charged, and seven of the subjects, all Israeli nationals, were extradited to the United States and sentenced to prison terms that ranged from 33 months to nine years This is the largest number of Israeli citizens ever extradited to a foreign country in a single case This investigation was extremely successful in large part due to the FBI s conti nued use of sophisticated investigative techniques to address financial crimes and the outstanding cooperation and assistance provided by the Tel Aviv Fraud Division of the Israel National Police Total victim losses were approximately 2 million. Foreign Lottery Sweepstakes Fraud Los Angeles This investigation centered on the activities of Vancouver, Canada-based telemarketing businesses that pitched European prize bonds to primarily elderly Americans These companies promised victims that their money would be pooled and used to purchase lottery tickets, that the victims had a very good chance of winning money, or that the victims had actually won a large sum of money Fraudsters also told victims their money would buy a bond and their investments were guaranteed, meaning they could obtain refunds of their initial investments after a short period of time However, the victims money was never used to provide any benefit to victims, and none of the victims ever received any substantial paymen t from the fraudulent companies Approximately 4,500 individuals, mostly elderly, were victimized by this scheme The main subject was sentenced to nine years in prison and ordered to repay victims 4 76 million This case was investigated by FBI Los Angeles, in conjunction with the USPIS, FTC, and the Royal Canadian Mounted Police. Foreign Lottery Sweepstakes Fraud Los Angeles This investigation centered on the activities of several lottery companies based in London, England Using phone calls, letters, and e-mails, subjects contacted potential victims, telling them they had won a lottery prize However, to collect the winnings, victims had to call telemarketers in Spain or England, who told the victims they had to pay taxes or other fees to receive prizes that never materialized Approximately 52 victims, primarily elderly, were defrauded out of more than 2 7 million Victims were from around the world, including the United States and the United Arab Emirates The main subject was sentenced to 14 years in prison This case was investigated by FBI Los Angeles and the Metropolitan Police Service in London. Tips to Protect Yourself Against Mass Marketing Fraud. Things You Should Do. Insist on learning the full name, address, and contact information for any company soliciting your business, personal information, or assistance. Insist that all solicitors send materials to you in writing so that you are able to study the full details of the offer, as well as any guarantees and or refund policies. Research all solicitors through the Better Business Bureau, state attorney general s office, and or consumer protection service in the state or city where the company is located. Prior to making any significant financial decisions, consult a family member, friend, your attorney, accountant, and or other trusted advisor for an objective opinion. To stop receiving telephone solicitations, instruct solicitors to delete your contact information from all call lists and register with the FTC s Do Not Call Registry. Report suspicious telemarketing calls, mail solicitations, or advertisements to the FTC at 1 877 FTC HELP or online at. Things You Should NOT Do. Do not make any payments to either secure a prize or improve your chances of winning a prize. Do not be intimidated into making hasty financial decisions by high-pressure sales tactics. Do not provide anyone with your sensitive personal or financial information unless. it is to an entity whose legitimacy is personally known to you, and. you personally initiated the contact with the entity. Do not send funds via wire or electronic money transfer services unless. it is to an entity whose legitimacy is personally known to you, and. you personally initiated the contact with the entity. Do not deposit checks and wire back any fees using the check proceeds until the checks have fully cleared It is common for a fraudster to send a check to victims with a requirement that a portion of the check be returned to the fraudster e g wire back taxes on winnings using part of the check or wiring back excess amount received for something you were selling. Do not be lured by offers that are simply too good to be true they almost certainly are. Asset Forfeiture Money Laundering. The mission of the Asset Forfeiture Money Laundering Unit AF MLU is to promote the strategic use of asset forfeiture and to ensure field offices employ the money laundering violation in all investigations, where appropriate, to disrupt and or dismantle criminal enterprises The asset forfeiture and money laundering process identifies, targets, disrupts, and dismantles criminal and terrorist organizations and individuals engaged in fraud schemes which target our nation s financial infrastructure. The implementation of the asset forfeiture process to criminal investigations provides law enforcement with the opportunity to deprive wrongdoers of the proceeds of their crimes, recover property that may be used to compensate victims, and deter future criminal activity The as set forfeiture process can destroy the financial infrastructure of criminal enterprises, return funds to victims of large-scale fraud, and share forfeited property with state and local law enforcement agencies. The AF program and the ML program provide support to all FBI investigative programs, to include the international and domestic terrorism programs. The DOJ defines money laundering in the following manner. Money laundering is the process by which criminals conceal or disguise the proceeds of their crimes or convert those proceeds into goods and services It allows criminals to infuse their illegal money into the stream of commerce, thus corrupting financial institutions and the money supply, thereby giving criminals unwarranted economic power. The FBI maintains a proactive approach when investigating money laundering After identifying a specified unlawful activity that generates illicit proceeds, a parallel financial investigation is conducted in order to locate the proceeds and prove their connection to the underlying crime. The FBI s AF program is one of the most successful in all of law enforcement In the WCCP, the bulk of the monies seized are returned to victims of the frauds that generated them This is unique to the FBI and some other agencies Most people associate the seizure and forfeiture of assets with narcotics trafficking Although the FBI does seize assets from drug dealers and other criminals, the WCCP is the largest contributor to the FBI s forfeiture program. Through FY 2011, 303 cases investigated by the FBI resulted in 37 indictments and 45 convictions of money laundering fraud criminals For FY 2011, the following money laundering accomplishments were achieved for the WCCP 18 4 million in restitutions 809,414 in recoveries and 983,536 in fines The chart below reflects pending money laundering cases from FY 2007 through FY 2011.Barclays New York On August 16, 2010, Barclays Bank entered into a deferred prosecution agreement waiving indictment and the filing of a two-count criminal information charging violations of Title 50, United States Code USC , Section 1705, the International Emergency Economic Powers Act IEEPA and Title 50, USC, Section 5 16, Trading With the Enemy Act TWEA Under IEEPA and TWEA, it is a crime to willfully violate or attempt to violate any regulation issued under the act, including those related to Cuba, Iran, Libya, Sudan, and Burma The IEEPA and TWEA regulations are administered by the Office of Foreign Assets Control OFAC This investigation resulted in the forfeiture of 298 million. Credit Suisse New York On December 16, 2009, Credit Suisse entered into a deferred prosecution agreement waiving indictment and the filing of a one-count criminal information in violation of Title 50, USC, Section 1705, the IEEPA The violations relate to transactions Credit Suisse illegally conducted on behalf of customers from Iran, Sudan, and other countries sanctioned in programs administered by the Department of the Treasury s OFAC This investigation resulted in the forfeiture of 536 million, which was the largest forfeiture ever received for this type of violation. The Forensic Accountant Unit FAU was established in March 2009 to support all FBI investigative matters requiring a forensic financial investigation The FAU provides oversight of the forensic accountant FoA and financial analyst FA programs, ensuring that the FBI s financial investigative needs and priorities are continuously addressed Key to the FAU s mission is developing, managing, and enhancing the FoA and FA programs, to ensure that FBI financial investigative matters are expedited with the high-level of expertise required in an increasingly complex global financial system. The forensic accountant program FAP is the culmination of years of effort to advance and professionalize the FBI s financial investigative capabilities The FoA position was developed to attract and retain top-tier accounting professionals who possess the ability to conduc t complex and thorough forensic financial investigations The FBI s FoAs are expected to testify as expert witnesses in judicial proceedings after completing the financial investigative portion of complex investigations. The mission of the FAU is to support all FBI investigative matters requiring a forensic financial investigation and to ensure the FBI s financial investigative priorities are continually addressed The FAU seeks to provide the highest caliber of financial investigative work product and support as well as contributing to the FBI s intelligence cycle The FAU continues to develop and implement a rigorous training curriculum and is collaborating with an array of public and private organizations in an effort to cultivate a workforce that provides superior results both in the field offices and at FBI Headquarters. Forensic Accountant Support Team The Forensic Accountant Support Team FAST is stationed within the FAU, enabling the FBI to quickly respond to significant, high-profil e investigations and augment field office resources to notably advance an investigation This professional support workforce is an asset to all FBI investigative programs and enables the FBI to more efficiently and effectively conduct complex investigations requiring a thorough forensic financial review The seven members of the FAST have worked a number of priority investigations during FY 2011 across a variety of investigative matters. Forensic Accountant Core Training Session Training Course The Forensic Accountant Core Training Session FACTS is a rigorous, comprehensive introductory program of instruction designed to increase an FoA s proficiency in the critical areas necessary to conduct a financial investigation This extensive course develops the FoA s aptitude and knowledge in handling a financial investigation according to pertinent rules and regulations across a wide variety of subject matters The material covered focuses primarily on providing an overview of FBI programs and sys tems, financial investigative topics and techniques, resources available to develop an investigation, legal training, and expert witness-testifying techniques During FY 2011, the FAU held three courses with a total of 128 graduates. BankScan Initiative BankScan is an in-house-created software application which translates physical bank and credit card statements into an electronic medium, thus dramatically decreasing the time-consuming data-entry process In FY 2011, the FAU provided BankScan training to three FACTS classes, three field offices, and the Terrorism Financing Operations Section at FBI Headquarters Each field office was supplied with the necessary software and equipment to implement the BankScan project Since its implementation, the FBI has benefited through an exponential increase in financial investigative efficiency and productivity Through the third quarter of FY 2011, an estimated 4,270 days 11 7 years of time has been saved by using BankScan. Electronic Subpoena Producti on The Electronic Subpoena Production initiative represents a joint undertaking of the FBI s CID, DOJ s Criminal Division Fraud Section, and the IRS Electronic Subpoena Production requires financial institutions to digitally produce account data stored electronically by relying on existing Rule 17 of the federal rules of criminal procedure and the updated Federal Reserve Regulation S effective January 1, 2010 When used in conjunction with BankScan, the introduction of this new process will substantially increase the efficiency and effectiveness of FBI forensic financial investigations. Financial Analyst Conversion In FY 2011, the FAU began the second phase of the selective conversion process to transition qualified FAs to the FAP to provide the FBI s investigative programs with the highest caliber of financial investigative work product and support This effort ensures only those individuals satisfying the FoA requirements convert to the FAP The second phase of the conversion will be com pleted during the early part of FY 2012.Financial Investigative Report The FAU deployed the Financial Investigative Report FIR template in FY 2011 The purpose of the FIR is to provide FAs and FoAs a standardized organizational tool that consistently presents financial investigative analysis, notes, and details to case agents CAs and assistant U S attorneys AUSAs The intended result is to create high-quality, uniform reporting that meets or exceeds the standards set by the Ca, AUSA, and the FAP. The FAP provided substantial support to the following major cases. Fair Finance Timothy Durham, James Cochran, and Rick Snow were indicted and charged with wire fraud, securities fraud, and conspiracy to commit securities fraud for allegedly committing a scheme to defraud the investors of Fair Finance Fair Finance was a privately-held niche lender that specialized in account receivables management and financing consumer installment sales contracts It is alleged in the indictment that over the last several years, Durham, Cochran, and Snow used Fair Finance investor money to finance other business operations and lifestyle expenditures, unbeknownst to investors There are over 5,000 victim-investors totaling approximately 200 million in loss Trial is scheduled for June 2012.Galleon Group Raj Rajaratnam was recently found guilty in Manhattan by a jury in federal court of conspiracy and securities fraud crimes stemming from his involvement in the largest hedge fund insider trading scheme in history Rajaratnam was the Managing Member of Galleon Management, LLC Galleon , the General Partner of Galleon Management, L P and a portfolio manager for Galleon Technology Offshore, Ltd and certain accounts of Galleon Diversified Fund, Ltd He was convicted on all 14 counts after an eight-week trial and sentenced to 11 years incarceration. American Therapeutic Corporation ATC Lawrence Duran, Marianella Valera, and others pled guilty to their roles in a scheme to submit more than 200 million of fra udulent claims to Medicare The scheme was orchestrated by the above owners and operators of American Therapeutic Corporation ATC its management company, Medlink Professional Management Group Inc and the American Sleep Institute ASI ATC s owners and operators paid kickbacks to owners and operators of assisted living facilities and halfway houses and to patient brokers in exchange for delivering ineligible patients to ATC and ASI Throughout the course of the ATC and ASI conspiracy, millions of dollars in kickbacks were paid in exchange for Medicare beneficiaries who did not qualify for partial hospitalization program services Lawrence Duran was sentenced to 50 years in prison for his role in the Medicare fraud scheme and was ordered to pay more than 87 million in restitution, jointly and severally with the co-defendants Duran s sentence is the longest prison sentence ever imposed in a Medicare Fraud Strike Force case Marianella Valera was sentenced to 35 years in prison and ordered to pay restitution Margarita Acevedo, a cooperating witness, was sentenced to seven-and-a-half years in prison and was ordered to pay 72 7 million in restitution Alan Gumer, MD Adrianna Mejia James Edwards Joseph Valdes and Nelson Fernandez also pled guilty to their roles in the fraud scheme, but have yet to be sentenced Sentencing for these individuals is scheduled for January 2012.Financial Intelligence Center. The Financial Intelligence Center FIC is a proactive data exploitation unit within the FCS, created in September 2009 It is staffed with a cadre of intelligence analysts IA and staff operations specialists SOS The FIC s mission is to provide tactical analysis of financial intelligence datasets and databases by using evolving technology and data exploitation techniques identify potential criminal enterprises and enhance investigations Additionally, the FIC has established liaison relationships with other government and regulatory agencies to identify additional data sources to disr upt and dismantle criminal enterprises and others and increase information sharing The FIC supports the following WCC subprograms. Financial institution fraud including mortgage fraud. Securities commodities fraud. Public corruption. Fraud against government. Health care fraud. Money laundering and other crimes. The FIC reviews large datasets to identify potential new targets for investigation see examples below Once a potential target is identified, the FIC conducts research using various internal databases and a myriad of external databases such as Lexis Nexis, Dun Bradstreet, CLEAR, and Public Access to Court Electronic Records and data provided by other agencies including the SEC, HHS, FINRA, and the DOJ The information is then organized using Excel spreadsheets and link chart analyses to connect the dots of all the key players The results of the research and analysis are then summarized and referred to the appropriate field office in the form of a targeting package for their discretion i n opening an investigation. Securities and Futures SAR Review Project Analysts who support the securities commodities fraud program review securities and futures SARs using defined parameters to identify potential subjects They then perform preliminary research to determine if the subjects are valid targets to disseminate to the appropriate FBI field office. Public Corruption Economic Stimulus Project Analysts who support the public corruption and fraud against the government programs research the American Recovery and Reinvestment Act funding distribution to identify vulnerabilities for fraud and prepare targeting packages to disseminate to the appropriate FBI field offices for review and potential case initiation. Health Care Fraud Prevention and Enforcement Action Team Project Analysts who support the HCF program work with HHS-OIG in collaborative data sharing to identify providers of medical equipment and services engaged in HCF The FIC performs a detailed analysis of the identified p roviders and formulates a targeting package that is presented to the applicable field office for review and potential case initiation. Health Care Fraud SAR Review Project Analysts who support the HCF program review SARs to identify physicians engaged in HCF The FIC performs a detailed analysis of the potential physicians and formulates a targeting package that is presented to the applicable field office for review and potential case initiationmercial Real Estate Loan SAR Project Analysts who support the FIF subprogram review SARs that reference commercial real estate loans to identify potential targets After further research, targeting packages are disseminated to the appropriate FBI field offices for review and potential case initiation. FDIC Referrals Initiative Analysts who support the FIF subprogram, in conjunction with the FIFU, conduct reviews of the FDIC s failed loans issued by various lending institutions to identify current indicators of potential fraudulent activity The data collected from the loan files is compared to various databases to identify subjects worthy of targeting packages Once the targeting packages are prepared, they are presented to the applicable field offices for review and potential case initiation. Money Laundering National SAR Review Project Analysts who support the ML program use this initiative, sponsored by the DOJ, to target money laundering activity with an international nexus Analysts utilize multi-agency resources to review SARs that have the potential for case initiation The FIC performs a detailed analysis of the potential cases and formulates a targeting package that is presented to the applicable field office for review and potential case initiation. Asset Forfeiture Money Laundering Unit Agape Merchant Advance, LLC Assistant United States Attorney Case Agent Coalition Against Insurance Fraud Commodities Futures Trading Commission Criminal Investigative Division Community Medical Health Center Centers for Medicare and Medicaid Services Durable Medical Equipment Department of Justice Deferred Prosecution Agreement Electronic Bank Records Initiative Economic Crimes Unit Financial Analyst Forensic Accountant Core Training Session Forensic Accountant Program Forensic Accountant Support Team Forensic Accountant Unit Federal Bureau of Investigation First City Bank Financial Crimes Section Federal Deposit Insurance Corporation Food and Drug Administration Financial Fraud Enforcement Task Force Financial Intelligence Center Financial Institution Fraud Financial Institution Fraud Unit Financial Industry Regulation Authority Financial Investigative Report Forensic Accountant Foreign Currency Exchange Forfeiture Support Project Federal Trade Commission Fiscal Year Gross Domestic Product Glaxosmithkline Health Care Fraud Health Care Fraud Unit Home Equity Conversion Mortgage Health and Human Services-Office of Inspector General Intelligence Analyst International Emergency Economic Powers Act International Mass Marketin g Fraud Working Group Internal Revenue Service Legal Attach Mortgage Bankers Association Money Laundering National Center for Disaster Fraud National Health Care Anti Fraud Association National Insurance Crime Bureau Operation Broken Trust Office of Foreign Assets Control Office of Inspector General Professional Employer Organization Suspicious Activity Reports Securities and Exchange Commission Special Inspector General for the Troubled Asset Relief Program Staff Operations Specialist Taylor, Bean Whitaker Trading With the Enemy Act U S Attorney s Office U S Postal Inspection Service White-Collar Crime White-Collar Crime Program. 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