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

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

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

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

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

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

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

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

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and exploitation Immediate action at the scene (bank accounts, other search/seizure warrants, identification of assets) Historical document review Every document is important- Case agents should review ALL evidence Use of documents to corroborate SOI, CI, witness and victim information Length,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

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

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

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

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

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

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

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

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

How they see themselves…..

DOCUMENTS LOCATED INSIDE THE BOILER ROOM