Time Share Fraud Investigations

1. Time Share Fraud Investigations Detective Michael Stevens Detective Hilary Bledsoe Orlando Police Department

2. PROBLEM: Organized Criminal Groups Conducting Wire Fraud • Companies based in Central Florida that utilize satellite offices/ drop boxes all over the US • Thousands of victims worldwide • Fictitious companies that rename every 60-90 days • Difficult to infiltrate into the inner group • Very little law enforcement knowledge of the groups • Incorporated company is different from company pitched to victims • Large profits allow groups to finance widespread fraud

3. RESPONSE: OPD dedicates two detectives full time for three months on investigation • Develop contact with Department of Agriculture and Consumer Affairs, State Attorney Generals Office and other law enforcement agencies both State and Federal • Detectives research timeshare industry and develop a basis of knowledge • Review of crimeline complaints and tips in an attempt to identify organizations operating within the 9th Judicial circuit • Statewide prosecution focus • Long term investigation targeting upper level subjects

4. PHASE 1: • Gather, develop and analyze intelligence and information on groups • Review of Crime Line tips, public records, state corporate records, internet sites and social networking sites • Contact with other Central Florida Law Enforcement agencies • Identify target for investigation

5. PHASE 2: • Develop an operational plan for the course of the investigation • Surveillance • Trash pulls • Development of sources of information • Use of confidential informants • Law enforcement information • Public records search • Interview of witnesses and victims • Contact with prosecutor • Decision of prosecution before or after search warrants

6. PHASE 3: • Identification of Assets • Bank accounts linked to business and subjects • Homes • Vehicles • Businesses • Other

7. PHASE 3 CONTINUED: • Use of investigative subpoena • Show the money flow • Use of law enforcement databases and communications • Examination of documents linking assets to illegal conduct • Contacts with financial institutions • Coordinating account seizures within the investigation

8. PHASE 4: • Determine charges based upon the investigation to date • Aggressive use of search and seizure warrants • Target “boiler/phone rooms” • Residences • Financial institutions • Documents, documents, documents (nothing is too small) • Computer systems and storage devices

9. PHASE 5: • Document review and exploitation • Immediate action at the scene (bank accounts, other search/seizure warrants, identification of assets) • Historical document review • Every document is important- Case agents should review ALL evidence • Use of documents to corroborate SOI, CI, witness and victim information • Length, scope, size and amount of fraudulent activity

10. PHASE 6: • Secondary interviews and Proffers • Defendants • Witnesses • Ex-employees • Current employees • New victims

11. PHASE 7: • Financial Investigations • Identify corporate and personal bank accounts for the organization • Identify host financial institutions • Use of investigative subpoena • Examination of subpoenaed documents • Statement review • Identification of additional corporate entities and co-conspirators • Identification of money laundering counts

12. Clues for the AML Investigator • Corporate accounts with limited shelf life • Activity inconsistent with normal account activity for the type of business • No previous banking history for the company • Wide spread deposits into the account from multiple subjects via wire, check and direct cash deposits • Corporate accounts associated with large ACH dumps • Rapid withdrawals and transfers to associated accounts under different corporate names or individuals

13. Clues for the AML Investigator continued • Fraud complaints made to the host financial institution • Widespread use of bank of cashiers checks • Multiple corporate accounts with the same signatories

14. What We Need From You • Identify accounts • Your professional experience as subject matter experts • Movement of funds • Corporate entities and individuals attached to the accounts • SAR and CTR activity • Information on bank and cashiers checks • Identification of major purchase and/or luxury items • This may come from subpoenaed documents or a phone call

15. KEY POINTS TO REMEMBER • TREAT THE INVESTIGATION AS A RICO • DOCUMENTS ARE KEY • DEVELOP COOPERATING DEFENDANTS • WORK WITH YOUR PROSECUTOR • USE SEARCH WARRANTS AS A TOOL NOT AN END RESULT • CHOOSE EVIDENCE OVER MONEY • WORK TOGETHER/ASK FOR ASSISTANCE • GO UP THE FOOD CHAIN NOT DOWN IT

16. Case Studies • Vacation Realty International • Account seizure • Car • Furniture • Homes • $ payments to straw nominee • Bank of America • Fifth Third • Sun Trust

17. Case Studies • JAMS Management • 15 million in fraud over two years • Widespread ACH dumps into corporate accounts and personal checks • Funds transferred to other corporate accounts all within the organization • Purchases • Cars • Homes • Horses

18. How they see themselves…..

19. DOCUMENTS LOCATED INSIDE THE BOILER ROOM