1. 1 U. S. Department of Transportation: Office of Inspector General Office of Investigations and Illinois Department of Transportation: Financial Review and Investigation Section Office of Quality Compliance & Review Shah Engineering Inc. Todd Kath Special Agent Telephone 312-353-0106 Todd.O.Kath@oig.dot.gov Gene Gansz Supervisory Auditor Telephone 217-785-4592 Gene.Gansz@illinois.gov

2. 2 Per FBI statistics dated between 2006 and 2008, the average dollar loss per offense for: Per FBI statistics dated between 2006 and 2008, the average dollar loss per offense for: Identity theft was $6,383 Identity theft was $6,383 Car theft was $6,751 Car theft was $6,751 Bank robbery was $4,854 Bank robbery was $4,854 Burglary was $2,079 Burglary was $2,079

3. How would you like to end your career after you caught: How would you like to end your career after you caught: 1,481 Car Thieves, or 1,481 Car Thieves, or 1,566 Identity Thieves, or 1,566 Identity Thieves, or 2,060 Bank Robbers, or 2,060 Bank Robbers, or 4,810 Burglars??? 4,810 Burglars??? 3

4. You might think that this might be that retiree... 4

5. In reality it could be any one of you!!! In reality it could be any one of you!!! Program managers, Program managers, Project executives, Project executives, Contracting officials, Contracting officials, Analysts, Analysts, Engineers, Engineers, Attorneys, Attorneys, Auditors, and Auditors, and Law enforcement personnel Law enforcement personnel The Shah Engineering Inc. investigation resulted in a settlement of $10 MILLION.... equaling 4,810 burglars or 160 burglars per year for a 30 year career, nearly one burglar caught every other day. The Shah Engineering Inc. investigation resulted in a settlement of $10 MILLION.... equaling 4,810 burglars or 160 burglars per year for a 30 year career, nearly one burglar caught every other day. 5

6. 6 Shah Engineering, Inc. (SEI) Engineering firm located in Chicago, Illinois Engineering firm located in Chicago, Illinois Manu Shah was the sole shareholder and was solely responsible for the billing and management of contracts Manu Shah was the sole shareholder and was solely responsible for the billing and management of contracts SEI provided a full range of engineering and architectural services to public and private sector clients with over 20 years in Consulting/Engineering. SEI provided a full range of engineering and architectural services to public and private sector clients with over 20 years in Consulting/Engineering.

7. 7 Illinois Department of Transportation (IDOT) Audit January 12, 2004 – IDOT audit January 12, 2004 – IDOT audit Initial Conference/Conferences Initial Conference/Conferences Claimed no Job cost information Claimed no Job cost information Partial records released to auditors Partial records released to auditors Field Testing Field Testing Timesheets unsigned or unapproved Timesheets unsigned or unapproved Timesheet corrections not initialed Timesheet corrections not initialed Shifting hours between jobs or office work Shifting hours between jobs or office work Invoices with little or no detail Invoices with little or no detail Assets depreciated and leased by various Shah-owned companies Assets depreciated and leased by various Shah-owned companies Employee lists did not match up with payroll summary Employee lists did not match up with payroll summary

8. 8 Example of shifting hours (with instructions)

9. 9 No invoice support and childs company

10. 10 Payments to GCM at end of year (from warrant)

11. 11 Illinois Department of Transportation (IDOT) Audit January 12, 2004 – IDOT audit – Continued January 12, 2004 – IDOT audit – Continued Observations Observations Employee worker caught creating a timesheet Employee worker caught creating a timesheet Blank timesheets found on copy machine Blank timesheets found on copy machine Related Companies – owned by children Related Companies – owned by children Noticing number of alterations on timesheets Noticing number of alterations on timesheets Accounting contact could not provide information without the owners review Accounting contact could not provide information without the owners review Fresh copies of old invoices Fresh copies of old invoices Conclusion Conclusion Based on initial review, IDOT believed SEI had received in excess of $1,500,000 more than its entitlement and referred the audit to DOT/OIG, FBI, and the USAO Based on initial review, IDOT believed SEI had received in excess of $1,500,000 more than its entitlement and referred the audit to DOT/OIG, FBI, and the USAO

12. 12 IDOT analysis of timesheet alterations

13. Search Warrant 13

14. 14 Search Warrant IDOT committed to work with investigators IDOT committed to work with investigators IDOT gave detailed information on search sites IDOT gave detailed information on search sites Simultaneous warrant of SEI corporate office and Manu Shahs residence Simultaneous warrant of SEI corporate office and Manu Shahs residence Interviews of employees including Manu Shah at residence Interviews of employees including Manu Shah at residence IDOT auditors brought in to sites as experts IDOT auditors brought in to sites as experts Identification of relevant paperwork Identification of relevant paperwork

15. 15 Investigation / Analysis Investigation / analysis took approximately 2 years Investigation / analysis took approximately 2 years Team Approach Team Approach IDOT audit spent time calculating amount of fraud versus normal audit adjustments IDOT audit spent time calculating amount of fraud versus normal audit adjustments Agents used this information to extend the reach of the investigation Agents used this information to extend the reach of the investigation US Attorneys supported efforts with use of grand jury tools, subpoenas, immunity for non-targets US Attorneys supported efforts with use of grand jury tools, subpoenas, immunity for non-targets Interviews of relevant parties Interviews of relevant parties

16. Additional Documentation Dozens of Subpoenas issued Dozens of Subpoenas issued Personal and corporate bank records Personal and corporate bank records Review of banking/investment documents Review of banking/investment documents Individuals for testimony under oath Individuals for testimony under oath Multiple transfers to friends, family, personal contacts Multiple transfers to friends, family, personal contacts Checks endorsed by Manu Shah and deposited back into SEI or Manus accounts Checks endorsed by Manu Shah and deposited back into SEI or Manus accounts Extensive transfers into trust accounts for tax and disadvantaged business enterprise (DBE) purposes Extensive transfers into trust accounts for tax and disadvantaged business enterprise (DBE) purposes 16

17. Investigation / Analysis Obtained evidence of the following: Obtained evidence of the following: Mail Fraud, 18 U.S.C. § 1341 Mail Fraud, 18 U.S.C. § 1341 Direct billing fraud Direct billing fraud Overhead fraud Overhead fraud DBE certification DBE certification Money laundering, 18 U.S.C. § 1956 & 1957 Money laundering, 18 U.S.C. § 1956 & 1957 False documents / statements, 18 U.S.C. § 1001 False documents / statements, 18 U.S.C. § 1001 Witness tampering, 18 U.S.C., § 1512 Witness tampering, 18 U.S.C., § 1512 RICO, 18 U.S.C. § 1962 RICO, 18 U.S.C. § 1962 Examples…. Examples…. 17

18. 18 Original Invoice

19. 19 Fake Invoice

20. 20 SEI Outbound Check to Bipin

21. 21 Manus Summary

22. 22 SEI Inbound Checks from Bipin Total of $17,160.00

23. 23 Summary of Dirigo Transactions

24. 24 Original Invoice From Dirigo

25. 25 Manus Fake Invoice

26. 26 Investigative Results Manu Shah Manu Shah Pled to 2 counts of mail fraud Pled to 2 counts of mail fraud Inflated hours Inflated hours False SEFC False SEFC Pled to 1 count of false statements* Pled to 1 count of false statements* Initial escrow of $5.5 million stock toward loss Initial escrow of $5.5 million stock toward loss Sentenced to 41 months in prison, starting August 20, 2009 Sentenced to 41 months in prison, starting August 20, 2009 SEI SEI Pled to 1 count of mail fraud Pled to 1 count of mail fraud $500,000 fine $500,000 fine Manu Shah and SEI debarred Manu Shah and SEI debarred $10 million restitution ordered to 12 State and municipal entities $10 million restitution ordered to 12 State and municipal entities Actual Overbilling as much as $12,366,947.45 Actual Overbilling as much as $12,366,947.45

27. Indictment --Count 2 …During the course of the audit, Manu Shah was requested to supply documentation for certain direct labor and overhead expenses claimed for IDOT and other contracts in prior years. On or about February 24, 2004, in the Central District of Illinois, MANU SHAH … submitted a false writing or document, knowing the same to contain a materially false, fictitious and fraudulent statement and entry including an invoice purportedly from Associated Engineering and Technology, which had been altered to read office rent (which was listed as an overhead expense) from the original invoice which was actually for the delivery of other services...in violation of Title 18, United States Code, § 1001. 27

28. Lessons Learned/Fraud Prevention Stay Alert!!! Stay Alert!!! Verify with sources (documents & people) Verify with sources (documents & people) Document Red Flags Document Red Flags Communicate with Audit or Investigative counterparts Communicate with Audit or Investigative counterparts Get angry – this is YOUR money! Get angry – this is YOUR money! 28

29. Manu Shahs residence – July 1, 2007 29

30. Manu Shahs Residence, October 6, 2010 -- ASHLAND FCI ASHLAND FCI ASHLAND FCI MANU SHAH, 15384-026, 74-Asian-M, MANU SHAH, 15384-026, 74-Asian-M, Release date 08-10-2012 Release date 08-10-2012 30

31. Robert Sullingers residence October 6, 2010 1. ROBERT G SULLINGER 15508-026 1. ROBERT G SULLINGER 15508-026 61-White-M 05-02-2012 MARION USP 61-White-M 05-02-2012 MARION USPMARION USPMARION USP 31

32. CATCH the Biggest Robbers & Thieves! CATCH the Biggest Robbers & Thieves! Contract fraud Contract fraud Grant fraud Grant fraud Embezzlement Embezzlement Etc. Etc. Remember..... You can save the taxpayer the equivalent of: Millions of $$$$$$ (Or More!) Thousands of cars Thousands of Identities 32

33. A little visual of the savings 33

34. 34 Questions Todd Kath Special Agent Telephone 312-353-0106 todd.o.kath@oig.dot.gov U. S. Department of Transportation: Office of Inspector General Office of Investigations and Illinois Department of Transportation: Financial Review and Investigation Section Office of Quality Compliance & Review Gene Gansz Supervisory Auditor Telephone 217-785-4592 Gene.Gansz@illinois.gov