Fraud and Money Laundering: Can You

Think Like a Fraudster?

WCAML Forum

October 17, 2013

Dennis M. Lormel

President & CEO

DML Associates, LLC

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WCAML Forum

Dennis M. Lormel | October 17, 2013

Think Like a Fraudster

• Introduction

• Can You Think Like a Bad Guy?

▫ The Allure of Fraud

• Fraud and Money Laundering

• Understanding the Crime Problem

▫ Scott Rothstein Ponzi Scheme

• Current and Emerging Trends

• Suspicious Activity Reporting

• Competing Against the Fraudster

• End Game

Introduction

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Dennis M. Lormel | October 17, 2013

Overview

• Advance together

▫ Cooperation, coordination, communication

• Get in fraudster’s head (mindset)

▫ Exploits systemic vulnerabilities

▫ Avoids detection

▫ Protects ill gotten gains

• Technology as proactive investigative

and detection tool

• Exploit vulnerabilities of bad guys

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Dennis M. Lormel | October 17, 2013

Advantages of being a Fraudster

• Fraud detection reactive

• Criminals motivated by greed

• Fraudsters adept at exploiting systemic vulnerabilities

• Fraudsters understand how to use financial institutions to

facilitate their illicit activity

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Dennis M. Lormel | October 17, 2013

Beneficial Ownership

▫ The term “beneficial ownership” when used to refer to

beneficial ownership of an account in AML context is

conventionally understood as equating to ultimate control

over funds in such account, whether through ownership or

other means. “Control” in this sense is to be distinguished

from mere signature authority or legal title.

▫ The ability to conceal beneficial ownership is extremely

attractive to bad guys

▫ The ability to conceal beneficial ownership is a detriment

to law enforcement

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Dennis M. Lormel | October 17, 2013

Shell Companies

• Non-publicly traded corporations, limited liability

companies (LLCs), and trusts that typically have no

physical presence

• Most shell companies are formed by individuals and

businesses for legitimate purposes

• Shell companies have become common tools for

money laundering and other financial crimes

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Shell Companies: The Constant &

Variables

• Constant

▫ Shell companies have been a constant vulnerability to the

financial services industry

• Consistent criminal facilitation tool

• Congressional testimony

• Variables

▫ Patterns of activity and trends driven by variables

• World events

• Opportunity

▫ Proficiency of criminal activity

• Technology

• New products

• Regulatory actions

• Law enforcement focus

• Various others

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Dennis M. Lormel | October 17, 2013

Shell Companies: The Bad Guy Factor

• What makes shell companies attractive to bad guys?

▫ Anonymity

• Easy to hide beneficial ownership

▫ Can serve as gateway to other facilitation tools

• Correspondent banking

• Wire transfers

▫ Global reach

• Can reach any corridor in the world

▫ Easy to set up

• Can use formation companies as fronts

▫ Limited oversight

• Can avoid detection

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Importance of Due Diligence

• Know your customer

program

▫ Sound process

▫ Verification

▫ Documentation

• Identify beneficial

ownership

▫ FATF recommendations

▫ FinCEN guidance

• Both stress importance of

identification and

consequence of risk

• Address customer risk

▫ Recognition

▫ Mitigation

▫ Adaptability factor

▫ Living process

• Assess reasonableness

of business activity

• Consider enhanced due

diligence

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Deconstructing Ownership & Risk

Customer Due Diligence

Process

Identify Beneficial Ownership

Adequate

Conduct Ongoing Due Diligence

Vigilance

Assess Customer Risk

Consider Enhanced Due Diligence

Assess Reasonableness of Business Activity

Consider Enhanced Due Diligence

Verification Documentation

Accurate Timely

Can You Think Like a Bad Guy?

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Fraud and Money Laundering

• Can you think like a bad guy?

▫ YES, we all can

▫ The first step is to understand how five elements, or fraud traits,

combine to influence an individual

• Integrity

• Opportunity

• Incentive, motivation or pressure

• Rationalization or attitude

• Capability

▫ The second step is to understand fraud on two levels

• Definition

▫ Deception

• Reality

▫ Specific fraud schemes

• Limited only by the imagination

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The Fraud Triangle

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The Fraud Diamond

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Stolen Without A Gun

Walter Pavlo, Jr. found himself in situation where he succumbed to

temptation of committing fraud

• Insider’s tale of greed,

excess and fraud at Bernard

Ebbers’ MCI Worldcom

• In position to execute fraud

scheme

• Embezzled $6 million

• Masterful case study of how

easily weak accounting

controls can be exploited

to facilitate fraud

• Started his MCI career as an

honest and ambitious junior

financial executive

• Earned $62,000

• Forced to “cook books”

to make numbers

• Became jaded and resentful

about having to falsify

financial records

• “I’m underpaid; everyone’s

cheating

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• What does a criminal think about every

day?

‒ Not getting caught

‒ Not having his assets confiscated

• Imagine:

‒ All your money is illegal

‒ And the government will seize it if they

find it

‒ How can you hide it?

‒ How can you put it in the bank?

‒ How can you transport / transfer it?

‒ How can you support your family ?

‒ How can you enjoy your wealth?

How Criminals Think About Money

The Allure of Fraud

19 Dennis M. Lormel | October 17, 2013

The Smell of Greed

• Three businessmen cross the line of INTEGRITY

• They seize the OPPORTUNITY to trade inside

information

• Their INCENTIVE is big payouts (greed)

• Their RATIONALIZATION is entitlement

• They possess the skill sets and access, providing them

the CAPABILITY to succeed

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Insider Trading

• Scheme involved three individuals who stole, traded and illegally

profited from non-public insider information

▫ Conspirators criminally charged for activities between 2006 and 2011

• Invested over $109,000,000 and netted over $32,000,000 in illicit profits

• Conspirators

▫ Matthew Kluger attorney

• Between 1994 and 2011, worked at various times at three very

prominent merger and acquisition law firms

• Regularly stole and disclosed non-public insider information

▫ Kenneth Robinson one time trader/in mortgage loan business

• Middleman who received and passed along insider information to trader

and then received cash from illicit transactions and passed money back

to attorney

• Executed two trades

▫ Garrett Bauer stock trader

• Worked at three separate proprietary trading firms

• Used trading accounts to execute illegal trades

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How Scheme Worked

• Kluger would steal non-public insider information by exploiting

the law firm document management system to obtain inside

information about ongoing deals at the firm

▫ Covered tracks by not being involved in the deals and by not

opening documents

• Viewed titles of documents

• No digital record of his activity

• Kluger passed the information on to Johnson. In turn,

Johnson provided the information to Bauer along with the

number of shares to be purchased for he and Kluger

• Bauer would add the shares he wanted and made purchases

in various trading accounts

▫ Usually made substantial profit

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How Scheme Worked

• To limit detection, Bauer paid Johnson in cash

▫ Would make cash withdrawals from ATM machines

• Had at least six separate accounts with the same major financial

institution

• Made withdrawals on consecutive days

• Once Bauer drew appropriate amount, he gave cash to

Johnson

• Johnson then split the proceeds with Kluger

▫ Johnson maintained accounts at three different banks

• He made deposits in branches near each other within minutes of

each other

• For the two deals Johnson handled without Bauer, he

structured cash withdrawals out of his bank accounts in

$9,000 increments

▫ Paid Kluger approximately $160,000

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How Scheme Worked

• Johnson used a safe deposit box to hide illicit money

• The conspirators used throw away phones to communicate

• At least 11 transactions took place while Kluger worked at the

last law firm he was associated with

• Illicit gains / money flow:

▫ 05/02/2006 $1,724,208

▫ 05/16/2006 $1,680,987

▫ 06/04/2007 $368,193

▫ 09/28/2007 $2,433,947

▫ 10/25/2007 $758,467

▫ 03/31/2008 $2,954,599

▫ 04/20/2009 $11,356,145

▫ 09/15/2009 $8,299,690

▫ 11/11/2009 $199,248

▫ 08/19/2009 $494,182

▫ 02/21/2011 $1,957,257

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What Went Down

• FBI and IRS executed search warrant at Johnson’s

residence on 3/8/2011

▫ Questioned Johnson about his and Bauer’s suspicious trades

and Johnson’s numerous instances of structuring cash into

and out of his bank accounts

▫ Johnson flipped and cooperated. He consensually recorded

a series of telephone calls individually with Kluger and Bauer

• Kluger and Baure made numerous incriminating statements

▫ Admissions of participation in the insider trading scheme

▫ Admissions of destroying evidence

▫ Bauer wanted Johnson to burn $175,000 from the last deal that

Johnson was still holding (fingerprint concern)

• Forfeiture action against Bauer

▫ NYC condo purchased for over $6,650,000

▫ Boca Raton home purchased for over $875,000

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Questions

• What red flags were prevalent?

• At what point should the banks where the conspirators

maintained their accounts have questioned / investigated

transactional activity?

▫ Reasonableness

• What was the likelihood SARs were filed, and against whom?

• Subpoenas were served for Johnson’s bank records, and at

some point, probably for Bauer and Kluger

▫ How would your financial institution react to the subpoenas?

• Would your bank consider exiting account relationships?

▫ Law enforcement consideration

26 Dennis M. Lormel | October 17, 2013

What if ???

• Instead of disbursing cash through ATM withdrawals, the

three conspirators established a shell company

▫ The shell company was set up as an investment club

▫ Kluger, Robinson and Bauer were the club members

• Hid their beneficial ownership

• If they needed additional cover to hide their identity, they would

use nominees to receive payment

▫ As successful businessmen, would being part of an

investment club have been reasonable and would it have

raised suspicion?

• If yes, they could have taken additional DECEPTIVE steps by

creating more SPIN

Fraud and Money Laundering

28 Dennis M. Lormel | October 17, 2013

Fraud and Money Laundering

• Fraud and money laundering are interconnected

▫ The proceeds of fraud and other criminal activities need to

be laundered

• Gives appearance of legitimacy

• Fraudsters must be able to move, store and spend the

proceeds of their criminal activity in order to succeed

• Greed factor is infectious

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Frankel Case

• Martin Frankel

▫ International con man

• Convicted and sentenced to 17 years in prison

• Embezzled $200 million from insurance companies in five

states

▫ Gained control of small insurance companies

▫ Stole their assets

• Lived in two-mansion compound in wealthy Greenwich,

Connecticut

▫ Maintained lavish lifestyle

• Fled from U.S. leaving behind piles of smoldering documents

▫ Authorities recovered to-do list

• Item #1 – “launder money”

• Arrested as fugitive in Germany

30 Dennis M. Lormel | October 17, 2013

Understanding the Crime Problem

32 Dennis M. Lormel | October 17, 2013

The Many Faces of Fraud

• Fraud is deception

• Fraud knows no boundaries

• Fraud schemes range from simple to

complex

• Evolution of fraud with the internet

▫ Provides anonymity

• Fraudsters adept at exploiting

systemic vulnerabilities

• Fraudsters understand how to use

financial institutions to facilitate their

illicit activity

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Understand the Crime Problem

• Fraud should be assessed and understood from two

perspectives

▫ Generic

▫ Specific

• Fraud schemes range from simple to complex

▫ Common frauds

▫ Major financial frauds

• The ability to be deceptive and avoid detection is a fraudster’s

primary key to success

• When investigators understand how fraudsters take advantage

of generic and specific fraud schemes, they position themselves

to more effectively and efficiently prepare and plan to compete

against fraudsters

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Major Financial Frauds

• Corporate fraud

• Investment fraud

• Financial institution fraud

▫ Check fraud

▫ Loan fraud

• Mortgage fraud

• Insider trading

• Hedge fund fraud

• Internet fraud

• Bankruptcy fraud

• Other

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Common Frauds

• Identity theft

• Jury duty scams

• Fraud against the elderly

▫ Grandparent scam

▫ Mortgage scams

▫ Investment scams

• Telemarketing fraud

• Credit card fraud

• Advanced fee schemes

• Nigerian letter or 419 fraud

• Health care fraud/health insurance

fraud

• Other

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• Opportunity

• Incentive / pressure

• Rationalization / attitude

• Capability

Investment Fraud Indicators

• If it seems too good to be true, IT USUALLY IS

• Unusually high investment returns

• Consistently high investment returns

• Lack of transparency

• Madoff

• Stanford

• Lack of oversight

• Circumvention of controls

• Select individuals with unfettered access to funds

• Fraud diamond

lack of controls

life style

greed / entitlement

position / skill sets

Case Study

Rothstein Ponzi Scheme

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Scott Rothstein

• Attorney located in Fort Lauderdale, Florida

• CEO and Chairman of law firm Rothstein Rosenfeldt Adler

▫ Used law firm and investment side business to commit $ 1.2 billion Ponzi

scheme

• Funded his philanthropy, political contributions, law firm salaries and

extravagant lifestyle

• Allegedly paid gratuities to senior bankers, law enforcement and

politicians

• Lived “rock star lifestyle”

• Quotes attributed to Rothstein after agreeing to cooperate

▫ “It was the power that got a hold of us and kept pulling this forward. The

more power, the more money; the more money the more power”

▫ “We were handing out money like Santa Claus hands out candy canes

to anybody that needed it for our purposes”

▫ “All Ponzi schemes do the same thing: They explode at the end”

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Investment Scheme

• Rothstein persuaded investors (mostly hedge funds and

wealthy families in New York, Florida and Texas) to buy stakes

in what he said were payouts from settlements of sexual

harassment and workplace discrimination lawsuits

▫ Scheme involved purchase of “structured lawsuits”

• People would sell large settlements in legal cases for lump sum cash

• Investors would make up-front cash payments to individuals owed

money from court cases to buy right to collect the full amount of the

settlements later

• Investors guaranteed a minimum of 20% investment returns in as little

as three months

▫ Made representation to investors that he had access to millions of

dollars in lawsuits

▫ Claims to have received support from senior executives at two

banks

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Bank Facilitation of Ponzi Scheme

• Initially banked with Gibraltar Private Bank

▫ Rothstein claimed to have CEO and senior bank officer in his pocket

• Invested $5,000,000 to become shareholder to avoid BSA scrutiny

• Felt AML and BSA compliance officers asked to many questions and

requested to many documents

• Moved bank accounts to TD Bank

▫ Large investors more comfortable with bigger bank

▫ Rothstein tired of Gibraltar AML and BSA compliance officers

▫ Claimed to have given at least $50,000 to vice president to assist

• Questionable activity at one or both banks

▫ Velocity of money in and out, often same day, sometimes within minutes

▫ Constantly shifting money between operating accounts and trust accounts

▫ Irregularity of activity and overdrafts

▫ Banks facilitated distribution of false statements to Rothstein clients

41 Dennis M. Lormel | October 17, 2013

Rothstein Timeline

• Operated racketeering (Ponzi) scheme from 2005 to 2009

▫ Created false documents and bank statements

▫ Purchased restaurants as mechanisms to support scheme

▫ Used two banks

• Initially maintained accounts at Gibraltar Private Bank

▫ Allegedly paid two executives to keep compliance in check

• Later opened accounts at TD Bank

▫ Allegedly had support from TD Bank

• Scheme unraveled in 2009

▫ Complaint to FBI in September

▫ Lack of new investment funds in October

• Exit strategy

▫ Rothstein fled to Casablanca, Morocco on October 26, 2009

42 Dennis M. Lormel | October 17, 2013

Timeline (continued)

• Returned to U.S. on November 3, 2009

• Indicted on December 1, 2009

• Plead guilty in federal court and sentenced to 50 years

▫ Agreed to cooperate with prosecutors and attorneys representing

victims

• Looking for sentence reduction

• 2011 and 2012,Gibraltar Private Bank and TD Bank subject of

lawsuits and adverse decisions

• 2011 and 2012, various co-conspirators charged an/or convicted for

their roles in the conspiracy

• Rothstein gave two week deposition in December 2011

• Rothstein providing three weeks of depositions in June 2012

43 Dennis M. Lormel | October 17, 2013

Gibraltar Bank – Rothstein Case

• “Question: Now, was [Gibraltar] bank important for your Ponzi

scheme?

• Rothstein: Critical.

• Question: And why?

• Rothstein: Because I had [Gibraltar’s Fort Lauderdale market

manager] John Harris in my pocket and later had [Gibraltar

Chairman and CEO] Steve Hayworth in my pocket, and they

were essential for me being able to do what I needed to do

without having interference with the federal or state

authorities...”

Source: Rothstein Deposition Transcript, 12/12/12 p.m. session

44 Dennis M. Lormel | October 17, 2013

Why Fraudsters Become Shareholders

of Banks

• “Question: Was there ever a conversation (…) with any of

those folks concerning your regulatory problems, compliance

problems, vis-a-vis become a major shareholder in the bank?

• Rothstein: Yes. I was told by Harris and by Steve Hayworth

that we don't investigation [sic] shareholders of the bank.

• Questions: That gave you some insensitive [sic] to become a

shareholder?

• Rothstein: That's the one and only reason I invested...”

Source: Rothstein Deposition Transcript, 12/12/12 p.m. session

Current and Emerging Trends

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Intersection of Crime & Conflict

• Criminal organizations and terrorist groups have

increasingly found common ground of mutual benefit

▫ Each have learned how to benefit from conflict

▫ Each have benefited from convergence and diversification

• Convergence: the intersection where criminals and

terrorists work together to support each other with the goal

to maximize the benefit to their individual causes

▫ Mutual and individual benefit

• Diversification: as organizations mature in operations

and sophistication, they diversify into different activities and

thereby grow and strengthen their operations

▫ Rely on legitimate and illegitimate fronts

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Areas of Exploitation

• Criminal Activity

▫ Fraud

▫ Drug trafficking

▫ Human smuggling/trafficking

▫ Counterfeit goods/currency

▫ Stolen goods

▫ Violent crimes

▫ Kidnapping

▫ Extortion

▫ Cyberfraud

▫ Money laundering

• Facilitation tools

▫ Internet

▫ Credit / debit cards

▫ Stored value cards

▫ NGOs / charities

▫ Illegal money remitters

▫ Informal value transfer systems

▫ Shell companies

▫ Off shore havens

▫ Correspondent banking

▫ Wire transfers

▫ Electronic mechanisms

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Exploitation of Systemic Vulnerabilities

• Terrorist and criminal organizations constantly exploit

systemic vulnerabilities

• Vulnerabilities or high risk areas in the financial services

sector

October 17, 2013

• Fraud

• Money Laundering

▫ Wire transfer

▫ Correspondent banking

▫ Illegal money remitters /

hawalas

▫ Shell companies

▫ Electronic mechanisms

October 3, 2001*

• Wire Transfer

• Correspondent

banking

• Fraud

• MSBs

* Lormel testimony before House Committee on Financial Services

Suspicious Activity Reports

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Suspicious Activity Reports (SARs)

• Most serious compliance breakdown

▫ Failure to file SARs

• SARs must be filed within 30 days of detecting suspicious

activity

• Should be comprehensive and thorough

▫ Answer who, what, when, where, why, how

▫ Include all identifying data

• SARs make an important difference

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Dennis M. Lormel | October 17, 2013

SAR Investigative Flow

• Alerts / referrals

▫ Transaction monitoring

▫ Negative media

▫ Law enforcement

▫ Call centers

▫ Front line employees

▫ Other

• Pre-investigative analysis

▫ SAR, escalate or close

• Investigations

▫ SAR / no-SAR decision

• Reporting

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Dennis M. Lormel | October 17, 2013

Reporting Suspicious Activity

• Vigilance of frontline staff

• Review and address alerts in a timely manner

• Document investigations

• Documentation of SAR filing and supporting investigative

information

• Documentation of no SAR decisions

• Internal control focus

▫ File SARs electronically

▫ Perform monthly quality assurance on all monitoring

systems

▫ Retain documentation of review process

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Components of Effective SAR Process

• Capturing suspicious incidents

• Investigative process

• Written standards

• The right people

• Case management and management reporting

• Using investigative information to improve a program

54

FinCEN BSA IT Modernization

• The BSA IT modernization program was focused on

providing more timely, reliable and useful BSA data and

improve search and analytical capabilities for law

enforcement, intelligence, and regulatory agencies

▫ E-filing system

▫ Enhanced analytical capabilities

• User friendly

• FinCEN query / reports

• Compliments advanced analytic mechanisms developed

by investigative agencies

• Importance of financial intelligence

▫ Makes BSA data more relevant and useful

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Law Enforcement Perspective of

SARs

• Importance of reporting suspicious activity

▫ Law enforcement direct beneficiary of SARs

• Front line employees and management share responsibility for

submitting meaningful SARs

• Importance of comprehensive narrative

▫ Who, what, where, when, why, and how

• The why is most important

▫ Explain up front why the activity is suspicious

▫ Key words

• Identify crime problems

• Importance of collateral information

▫ The more common the names, the more identifiers you need

• Availability of SAR file for law enforcement

• Investigative and financial intelligence value of SARs

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Dennis M. Lormel | October 17, 2013

Evolution of Law Enforcement SAR

Review

• Review process historically manual

• Emergence of SAR review teams

• Review process becoming more automated

▫ Data mining

• FBI Investigative data warehouse

• IRS Reveal

• FinCEN modernization project

▫ Data extraction capability

Competing Against the Fraudster

58 Dennis M. Lormel | October 17, 2013

WCAML Forum

Fraud as Sporting Event

• Liken fraud to a sporting

event

▫ Fraudster v. investigator

• Player who usually comes

out on top is player better

prepared to perform

• Fraudsters tend to be more

talented

▫ Proactive

▫ Motivated by greed and

arrogance

• When investigators take time to

prepare and plan

▫ More likely to exploit

vulnerabilities of fraudsters

• Greed and arrogance

• Finance and communications

• Investigators must understand

▫ Crime problem

▫ How fraudsters operate

(business model)

▫ Game plan to exploit

vulnerabilities of bad guys

59 Dennis M. Lormel | October 17, 2013

WCAML Forum

Understand the Investigative Process

• What to investigate

▫ Understand the crime problem

• When to investigate

• Who should investigate

• How to investigate

• Evaluating evidence

• Reporting

▫ Findings and conclusions

• End game

▫ Post investigation actions

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Investigative Steps

• Collecting and analyzing documents

• Sophisticated investigative techniques

• Sources of information

▫ Public records

▫ Non-public records

• Accessing information online

▫ Validate accuracy of information

• Data analysis and reporting tools

• Interviewing

• Reporting standards

• End game

▫ Consequences

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Ingredients for Successful

Investigations

• Timely, consistent and thorough investigation

• The right investigative team

▫ Individual experience and skill sets

▫ Adequacy of resources

• Preparation and planning

▫ Maintain focus

▫ Investigative tools / interviewing

• Following rules and regulations

▫ Understand laws and / or policies and procedures

• Confidentiality and objectivity

• Having an end game

62 Dennis M. Lormel | October 17, 2013

WCAML Forum

Preparation and Planning

• Investigators must understand crime problem

• Criminal investigators must know applicable laws and level of

evidence necessary to prove violations

• Private sector investigators must have knowledge of

institutional policies and procedures and investigative steps

necessary to mitigate fraud

• Is there more to simple schemes?

▫ Vigilance

• Maintain investigative focus and discipline

▫ Adhere to investigative plan

• Be prepared to deal with contingencies

63 Dennis M. Lormel | October 17, 2013

WCAML Forum

Fraud

Investigation

Understand

Crime

Problem

Training

Experience

& Intuition

Conducting Fraud Investigations

The Triangle for Success

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Dennis M. Lormel | October 17, 2013

Investigating a Good Fraudster

• Upper hand

• Spin / deception

• Intimidation

• Persistence

• Analysis

▫ Reasonableness

• Exit strategy

End Game

66

End Game

• Once you understand how to think like a bad guy, you better

position yourself to identify fraud schemes

▫ Breaking down spin and deception

• Good fraudsters have exit strategy

▫ When scheme falters, exit strategy implemented

• Good guys need end game to prevent or disrupt exit strategy

• Two prominent end games

▫ Private sector focus

• Prevent or minimize monetary losses

• Limit reputational risk

▫ Public sector focus

• Seek criminal prosecution and/or enforcement action

• Recover illicit proceeds and assets through forfeiture actions

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Dennis M. Lormel | October 17, 2013

Conclusion

• Be safe

• Be vigilant

▫ Is there more to a case?

• Rely on investigative / analytical intuition / experience

• Continue to learn / broaden / experience

• Share information

• Be proactive

• Exploit vulnerabilities of bad guys

68 Dennis M. Lormel | October 17, 2013

Dennis M. Lormel

President & CEO

DML Associates, LLC

19309 Winmeade Drive

Lansdowne, VA 20176

571-333-0300

dlormel@dmlassociatesllc.com

www.dmlassociatesllc.com