The Treasury Department recently issued a Report on money laundering in the art markets. To no one’s surprise, Treasury found the art market to be an “attractive” one for money launderers, given the “the high-dollar values,” “ease of transportability,” “long-standing culture of privacy,” and “increasing use of art as an investment or financial asset.” When Congress mandated the report back in...
Top Ten Financial and Healthcare Fraud Prison Sentences of 2021
Posted 01/28/22
Individuals involved in financial and healthcare fraud schemes face not just civil liability, but also criminal penalties – including prison time. In 2021, the Department of Justice obtained substantial prison sentences in a myriad of cases involving healthcare and financial frauds, many of which involved convictions of the type of fraudulent schemes that whistleblowers report. Whistleblowers play an essential role...
Top Ten Federal Financial Fraud Recoveries of 2021
Posted 01/21/22
While 2021 may have felt like more of the same as the pandemic dragged on, it marked some new trends in federal financial fraud recoveries. As we predicted last year, the Anti-Money Laundering Act of 2020 has heralded some large recoveries against banks. The Act also established an Anti-Money Laundering Whistleblower Program, so that whistleblowers who report financial institutions engaging in money laundering –...
As we recently detailed, 2021 proved to be a blockbuster year for whistleblowers under the CFTC and SEC Whistleblower Programs. Seven of the ten largest whistleblower awards of 2021 were made to SEC and CFTC whistleblowers, including a massive $200 million CFTC award that was roughly twice as large as all prior CFTC awards combined. In total, the SEC paid more awards—both in total dollars and individual...
Two Florida men, Reinier Gonzalez Caballero and Alexeis Napoles Manresa, have each been sentenced to a little over four years in prison for laundering the ill-gotten proceeds of a $3 million healthcare fraud scheme against Medicare. Over a couple months in 2019, durable medical equipment company Universal Ortho Supplies, Inc. billed Medicare for orthosis and prosthetics that were never prescribed by physicians, nor provided to patients. The reimbursements were then turned over to the defendants, who attempted to disguise the source of the funds by setting up shell corporations and opening up fake bank accounts. Two co-conspirators have already been convicted and sentenced; another two have pleaded guilty and await sentencing. USAO SDFL
Broker-dealer Wedbush Securities Inc. has agreed to pay $1.2 million to resolve allegations related to the unregistered sale of large blocks of 50 different low-priced microcap companies by Silverton SA, a former offshore customer. The SEC also found that Wedbush failed to file SARs for certain suspicious transactions that it executed for Silverton, despite the presence of numerous red flags. SEC
The New ENABLERS Act May Be a Backdoor Way to Expand the Anti-Money Laundering Whistleblower Program
Posted 10/14/21
In The Hill this week, I argue that the newly proposed ENABLERS Act is a lot more powerful than even its authors seem to realize. The proposed law would effectively expand the Bank Secrecy Act to apply the same reporting requirements currently imposed on banks to all sorts of actors who enable (get it?) money laundering: lawyers, investment advisers, accountants, art dealers, public relations firms, and the like. ...
Pandora Papers Show the Value of Financial Transparency, the Critical Role of Whistleblowers – and the Need for Additional Regulation
Posted 10/8/21
This week, the International Consortium of Investigative Journalists and its partners began publicly reporting on the “Pandora Papers,” a trove of millions of leaked documents from firms around the world that help customers set up “offshore” accounts and shell companies designed to conceal financial truths. The leaked documents, and the extensive reporting on the documents, sheds light on the murky world of...
Catch of the Week: San Francisco Garbage Companies Cop to Bribing Corrupt City Regulator in $36 Million Deal with Feds
Posted 09/10/21
Three San Francisco trash and recycling companies, all Recology, Inc. subsidiaries, have agreed to pay $36 million in a corruption scheme involving substantial bribes to former San Francisco Public Works Director Mohammad Nuru. The SF Recology Group, which includes Recology San Francisco, Sunset Scavenger Company, and Golden Gate Disposal & Recycling Company agreed to a deferred prosecution deal on charges they...
Catch of the Week: Telemedicine Company Owner Charged in $784 Million Kickback Scheme
Posted 08/20/21
Underscoring the fraud risks associated with the government’s continued expansion and loosening of restrictions on telehealth, the U.S. Department of Justice recently announced that a grand jury in New Jersey has returned a superseding indictment against the Florida owner of multiple telemedicine companies, referred to by DOJ prosecutors as the Video Doctor Network, for allegedly participating in a massive Medicare...