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 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 Purchases
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