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Welcome to the ACAMS Web Seminar

SAR/STR Case Studies (Part I): Exposing the Red Flags of

Tax Fraud Schemes

September 18, 2013 12:00 Noon– 2:00 pm ET

The web seminar has not yet started.

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Welcome to the ACAMS Web Seminar

SAR/STR Case Studies (Part I): Exposing the Red Flags of

Tax Fraud Schemes

September 18, 2013 12:00 Noon– 2:00 pm ET

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Speakers Arash Kiadeh, EA, CFE, CAMS

Senior Investigator First Republic Bank

Jerome McDuffie Supervisory Special Agent

IRS-CI Liaison to FinCEN

Moderator

Michael Schidlow, Esq., CAMS Senior Manager, Audit Group

HSBC Bank


The following presentation contains case studies that represent scenarios based on

publicly available information. In some case studies, the characters have been

combined and/or events have been condensed in order to protect the privacy of

others or for educational purposes. As a result, any similarity with these conflated

events or characters to real persons is purely coincidental. This presentation

represents my views and not the view of First Republic Bank or its

affiliates. Further, this presentation is for informational purposes only, and should

not be construed as legal advice on any subject matter. No recipients of this

information should act or refrain from acting on the basis of anything included

herein. Finally, this presentation shall not create an attorney – client relationship.

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Criminal Tax Evasion and Tax Fraud Vs. Civil Tax Evasion and Tax Fraud

IRS needs more convincing evidence in a criminal case

Standards of Proof

1. For criminal case need to prove beyond a reasonable doubt

2. For civil case need to prove by showing clear and convincing evidence

3. Preponderance of evidence

90%

75%

51%

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Civil

Tax Evasion

Criminal

Tax Fraud

Criminal

Tax Evasion

Civil

Tax Fraud

Civil

Tax Evasion

Has to file taxes Doesn’t have to file taxes

Beyond Reasonable Doubt

Clear and convincing

Taxpayer attitude/ behavior

Government Discretion

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Methods of Proof

• Specific items method – Evidence that specific income was not reported

• Net worth method – Unaccounted for increase in wealth

• Expenditures method – Prove they spent a lot more than they made

• Bank deposits method – Reconstruction of income by analysis of bank deposits

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• Steal someone's identity, file their tax return before they do, and claim a refund

• Can be committed on a large scale by anyone with access to personal info:

– Hospital staff

– Military staff

– Prison staff

– Government agency staff

• Red Flag

– Numerous deposits from the IRS or state tax authority, to one entities’

bank account(s) or prepaid cards

SIRF – Stolen Identity Refund Fraud

12


ClaustrumView LLC

Account @ My Bank ClaustrumView LLC

Account @ ABC Bank $8,000,000

Escrow Company

$7,750,000

I get a call from the branch and hear the following story…..

• 4 months ago, a new client, 67 yrs old opened a business checking account for ClaustrumView LLC.

• He was referred by a fairly new but existing client, a contractor.

• At account opening, elder client is accompanied by younger “friend,” Tom.

• Tom does most of the talking, says he wants to help his friend who can’t speak much English.

• Tom says that elder is a real estate developer and plans to purchase a $8,000,000 residential apartment

complex.

• Elder presents Secretary of State filing showing that he is the CEO of recently formed ClaustrumView LLC.

• He would like a business checking account in the name ClaustrumView LLC.

• He tells the bank to expect the $8,000,000 wire from his other bank account, within a few days.

• 4 months later, there is an email request to wire out the rest of the money.

• The banker performs a call back and asks to speak to the elder.

• A gentleman speaking perfect English says that he is the elder, and authorizes the wire.

• The banker says that the elder did not speak good English like the caller, and he would

have to come into the bank to complete the wire.

• LN of elder shows no property ownership address and no work history, and a Thomas as a possible associate. 13


ClaustrumView LLC

Account @ ABC Bank

ClaustrumView LLC

Account @ My Bank $8,000,000

Escrow Company

$7,750,000

Elder Personal Account

@ ABC Bank

$8,000,000

Cash - Over the last 4 1/2 yrs

5 to 7k a week or $250K a year

Cash is salary from managing

Gas stations owned by

his nephew, Thomas.

Wires from Eastern Europe

-Proceeds from the sale of investments

- Using retirement funds

$1,000,000 $4,000,000

Wire ClaustrumView LLC

Account @ XYZ Bank

$3,000,000

Tom Skimmed from gas stations

Elder, Acct bank2

Elder, Acct bank1 Elder, Acct bank3

5 to 7k a week cash, each account

Said he was helping family and

preparing for retirement

Per the indictment…..

314b

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Fun Fact Break

Reasons financial statement fraud is committed:

1. Comply with financial covenants imposed by a bank

2. To help get financing

3. Cover up poor performance

4. Selling the business

Make business look

better

Make business look

worse

1. Tax Fraud

2. Bankruptcy

3. Divorce - Split in half a smaller number

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• Client for 4 years

• U.S. Importer- specializing in importing children’s toys

• Per narrative in loan file, 70% of business income is from action figures

• In business 12 years

• Owner has MBA

• 8 years as an investment banker prior to starting import business

Date Amount Transaction Direction Beneficiary

2/14/2013 $ 250,000.00 Wire Transfer Debit Singapore Toy Co., Ltd

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Importer

Flee market vendors

Fashion district vendors

AB Toys Cash

• 6 month review, previous monthly average was 90k

• Tells us to anticipate increased transaction volumes

• Bendable Gumby action figures have regained popularity

partially because a celebrity tweeted about it

• Blogs and articles support Gumby popularity claims

• Singapore Toy Co., Ltd. has a website where you can order toys

• Client provides us with receipts

• Receipt says he paid $2 each for 125,000 Gumby (or Gumbi)

• Recent site visit of clients warehouse shows inventory of action figures

Overbilling?

Trade based ML?

Beneficial owner of Singapore Toy Co., Ltd?

Singapore Toy Co., Ltd

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Singapore Toy Co., Ltd Importer

Flee market vendors

Fashion district vendors

AB Toys

Cash

- Showed us receipt for 125,000 Gumby @ $2

- Gumby really cost $1 each

Importer’s Singapore account

$0.90

Draws $ into U.S. via credit card

$2 Split 3 ways

$0.90 back to Importer

$1 for Gumby

$0.10 Commission

Higher U.S. business expenses

Secret non-taxable accounts offshore

U.S. Singapore

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• There are 19 tax court judges who travel to all 50 states

to hold tax court

Fun Fact Break

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• Moshe Handelsman, MBA and PhD age 63

• Is an expert in data analysis, econometrics, forecast modeling

• Professor at a University

• Started a company called Advanced Forecasting Inc., in 1987

• The company developed a formula that it claimed could accurately predict demand in the semiconductor

industry 18 months out

• Semiconductor- also known as “chips” which are used in computers, cell phones other technology

• After several years of accurate forecasts, they attracted big name clients like Cisco, and Applied Materials

• Somewhere along the way he decided he was going to begin to evade taxes

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Exportus Ltd- Bank Account 1 Advanced Forecasting Corp From 2003 to 2008 - $1,808,075

Israel

On Advanced Forecasting corp’s

return he called these “information

acquisition expenses”

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Exportus Ltd- Bank 1 account 1 Advanced Forecasting Corp Step 1-$1,808,075

Exportus Ltd – Bank 2 account 1 Charles Schwab

relative’s account

U.S. Personal account

Non-taxable gift

$

Step 2

$

$ $

Step 3

Step 4 $

$

Estimated tax savings assuming 30%

tax rate. 1.8MM x 30% = $540,000

Sentencing this November 2013

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Cities with the most tax evasion:

1. Los Angeles

2. San Francisco

3. Houston

4. Atlanta

5. DC

Fun Fact Break

23


24


Rob Sr.

Acct

Credit Cards

Checks to “Luxury Air Travel”

Insurance

Mortgage

• 6 month review shows numerous CTR filings

• Credits: 60% credit cards, 30% of deposits are cash, 10% checks from companies

• Debits: 30% food/alcohol, 30% labor, 40% rent

Rest Acct 1 Rest Acct 2

Family Mgt Corp Acct

Rest Acct 3

$ $

$

• Rob Jr.. is sole signer on restaurant accounts and owner of the operating company

• Property restaurants are on owned by Family Mgt Corp which is owned by Rob Sr.

7/16/2013 $6,509

7/17/2013 $8,975

7/10/2013 $4,985

7/11/2013 $7,582

Alert

Acct 1 Acct 2

$

Rental Acct 2

Rental Acct 1 Rental Acct 3

$ $

$

Each rental property is owned by Rob Sr. 25


• Earned/Active income - Any income generated by working

• W-2 income from working at a job

• Owning a small business/1099 income

• Gambling

• Portfolio income – Income from investments

• Money from the sale of stocks, bonds

• Buying and selling real estate

• Interest income from CDs

• Passive income - money you get from assets you have purchased or created

• Rental income from real estate

• Limited Partnerships

• Royalties from the sale of patents, books, music/television

NOTE: Exceptions – inheritance and winning the lottery

Types of Income:

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650

2,300

39,670

11,691

18,181

72,492

(24,492) X 3 properties = 75k in

“suspended” Passive

Activity Losses

DEPRECIATION

$1,000,000 house

50% of the value is the

“depreciable” base

$500,000/27.5

48,000

Assumptions

$1,000,000 house

30 years @ 4%

Nothing down

4k a month rent

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• Earned income - Any income generated by working

• W-2 income from working at a job

• Owning a small business/1099 income

• Gambling

• Portfolio income – Income from investments

• Money from the sale of stocks, bonds

• Buying and selling real estate

• Interest income from CDs

• Passive income - money you get from assets you have purchased or created

• Rental income from real estate

• Limited Partnerships

• Royalties from the sale of patents, books, music/television

Suspended passive activity losses can only be offset by other passive income

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Rob Sr.

Acct

Credit Cards


Insurance

Mortgage






Rest Acct 3

$ $

$

• Rob Jr. is sole signer on restaurant accounts and owner of the operating company

• Property restaurants are on is owned by Family Mgt Corp which is owned by Rob Sr.

7/16/2013 $6,509

7/17/2013 $8,975

7/10/2013 $4,985

7/11/2013 $7,582

Alert

Acct 1 Acct 2

$

Rental Acct 2


$ $

$

Each rental property is owned by Rob Sr

$75k in suspended losses a year

Offset by high rents

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Income $1,000,000

Expenses

Food $300,000

Labor $300,000

Rent $400,000

Taxable income $0

Higher rent = lower taxable income for restaurant operating company

Vs.

Income $1,000,000

Expenses

Food $300,000

Labor $300,000

Rent $100,000

Taxable income $300,000

Market rate

Arm’s length principle: Prices must be comparable to the prices charged for the same goods and services between unrelated parties.

ACTUAL rent

30


No SAR

• Not structuring because they are filing

CTRs

• Their pattern of related company

transactions is supportable

• No negative news father or son

• No negative LexisNexis info

• Great Yelp reviews for the restaurant

• BBB rated

Questions: • Should the estimated amount of tax evaded be the basis for the decision to SAR?

• What if he had 12 rental properties and 12 restaurants?

• When do high rents go from avoidance, to evasion…to criminal evasion?

• How do you know all the tax laws involved with certainty?

• If you file a SAR…what precedence have you set for your financial institution?

…what precedence have you set for the SAR 90?

SAR

• Rent payments are 4 times market. Between

the suspended losses and restaurant tax

benefit, hundreds of thousands could be

evaded.

31


Rob Sr.

Acct

Credit Cards


Insurance

Mortgage






Rest Acct 3

$ $

$

• Rob Jr. is sole signer on restaurant accounts and owner of the operating company

• Property restaurants are on is owned by Family Mgt Corp which is owned by Rob Sr.

7/16/2013 $6,509

7/17/2013 $8,975

7/10/2013 $4,985

7/11/2013 $7,582

Alert

Acct 1 Acct 2

$

Rental Acct 2


$ $

$

Each rental property is owned by Rob Sr

$75k in suspended losses a year

Offset by high rents

32


PAL

Passive Income Generators (PIGs) eat Passive Income Losses (PALs)

PIGs Eat PALs

PIG

33


34

IRS Criminal Investigation (CI)

BSA Program

• Jerome McDuffie

• Supervisory Special Agent

• IRS-CI Liaison to FinCEN


35

• Provide an overview of BSA reporting requirements

• Identify Statutes used by IRS CI • Identify Title 31 Authority for IRS-CI (Treasury Directive 15-

41 and 15-42, 31 CFR 1010.810(c), Treasury Order 150-35)

• Define Suspicious Activity

• Disclosure rules regarding SARs

• Define SAR Review Teams and Financial Crimes Task Forces

Purpose of this Presentation


36

IRS-CI has the authority to investigate:

• Tax crimes under Title 26 of the USC Tax Evasion, False Income Tax Returns, and Failure to File

• Money laundering under Title 18 – 1956 and 1957, and

• BSA violations under Title 31 of the USC

Overview of the criminal statutes utilized by IRS-CI Special Agents


37

Bank Secrecy Act (BSA)

• Enacted in 1970 to fight money laundering & other financial crimes

• Created a series of reporting and record keeping requirements to document suspicious or large cash transactions


38

THE IMPORTANCE OF BSA DATA!!!

Identifies potential illegal activity and

unreported income

Prevents the flow of illicit funds

Establishes emerging threats through analysis of

patterns and trends

Identifies and provides leads to assets

purchased with illicit proceeds that may be

seized


Treasury Directive 15-41

–Initiate investigations of any person, including banks and brokers or dealers in securities, for possible criminal violations of Title 31

• TD 15-42

– Authority to investigate violations of 18 U.S.C. §§1956 and 1957

– Seizure and forfeiture authority over violations of 18 U.S.C. §981 relating to violations of:

– 31 U.S.C. §§5313 and 5324

– 18 U.S.C. §§1956 and 1957 which are within the investigatory jurisdiction of IRS

– Seizure authority relating to any other violation of 18 U.S.C. §1956 or 1957 if the bureau with investigatory authority is not present to make the seizure.

39


• 31 CFR 1010.810(c) - Authority for investigating criminal violations of this chapter is delegated as follows:

–(2) To the Commissioner of Internal Revenue except with respect to

§ 1010.340 (CMIR)

• Treasury Order 150-35

–Authority to refer all criminal matters within the jurisdiction of the IRS to the Department of Justice for grand jury investigation, criminal prosecution, or other criminal enforcement action requiring court order or DOJ approval

40

Title 31 Authority for IRS CI


• T-31

– 5313: Reporting Requirement

– 5317: Seizure, Forfeiture Authority

981, 982, and 984

– 5322: Criminal Penalties [5 yrs.]

– 5324: STRUCTURING--- “the biggie”

– 5330: Registering of MSBs

– 5332: Bulk Currency Smuggling

41

T-31 Authority in the U.S. Code


• TDF 90-22.47 Suspicious Activity Report

• FinCEN 104 Currency Transaction Report

• FinCEN 105 CMIR

• FinCEN 107 Registration of MSBs

• FinCEN 109 SAR for MSBs

• FinCEN 8300 Report of Cash >$10,000 in a

Trade or Business

• TDF 90-22.1 [FBAR] Foreign Bank Account 42

BSA FORMS: [main ones]


Currency Transaction Report Requirement

F A Currency Transaction Report (CTR) is required to be filed by a financial institution for any transaction involving in excess of $10,000 in currency.

43


Form 8300 Statutes • This form is covered by two sections of law;

Title 26 USC, Section 6050I in 1984 & 26 CFR 1.6050I;

Title 31 USC, Section 5331 in 2001 & 31 CFR 1010.330.

• Requires those engaged in a trade or business to report cash (or cash equivalent) transactions in excess of $10,000.

44


Report of Foreign Bank and Financial Accounts

An FBAR must be completed by individuals

who have a financial interest or signature authority on a foreign account that at any time during the past year had a balance in excess of $10,000.

45


Money Services Business (MSB)

Case development is focused on the entire scope of financial services offered by registered and licensed and unregistered and unlicensed MSBs (i.e. to include Western Unions and Hawaladars) MSB could be any business or organization that moves money! MSB’s includes:

• Check casher • Money transmitters – like Western Union and Money Gram

Issuer, seller or redeemer of travelers’ checks, money order • Prepaid Access • Currency dealing or exchange

MSB includes any person doing business in the above mentioned category who conducts more than $1,000 in business with one person in one or more transaction There is no activity threshold for money transmitter

46


Suspicious Activity Reports

• Annunzio-Wylie Anti-Money Laundering Act (1992) - Required Suspicious Activity Reports and eliminated previously used Criminal Referral Forms

• Used by law enforcement to identify potential violations of the BSA and other laws

47


48

Suspicious Activity Defined

Any conducted or attempted transaction or pattern of transactions that may:

– Involve funds derived from an illegal activity

– Be designed to evade the BSA requirements


49

Suspicious Activity Defined

– Appear to serve no business or apparent lawful purpose

– Involve use of bank, etc. to facilitate criminal activity


50

SAR Regulation

• Suspicious Activity Reports are required by regulations under 31 U.S.C. 5318(g).

• There are different reporting requirements depending on the type of financial institution involved.


51

FinCEN

• The Financial Crimes Enforcement

Network (FinCEN) administers the Bank

Secrecy Act (BSA).

• FinCEN establishes policies and procedures for access to and use of SAR information.


52

Safeguarding SARs and SAR Information

• SARs and SAR information must be treated the same as information from a confidential informant.

• All employees must handle SAR information in

strict confidence.

• The identity of the individuals or entities, for example, financial institutions, casinos, who furnished the information must be protected.


Questions from the Taxpayer

• The information contained in, and even the existence of a SAR cannot be disclosed to the taxpayer or the subject of a SAR.

• Employees must not lie to the taxpayer.

53


54

Strict Disclosure Rules for SARs

May NOT be:

•Referenced in indictments, warrants, or subpoenas

•Referenced when interviewing a subject

•Generally cannot be used in open court


55


•

•It is imperative that the information contained in, and even the existence of, a SAR cannot be disclosed to taxpayer.


56


Criminal penalties may apply for willful unauthorized disclosures.


57

SARs

Unauthorized Disclosure of a SAR

• **DON’T DO IT**

• Subject to a fine of $250,000 and/or • imprisonment for up to 5 years • 31 U.S.C. 5318 and 5322


SAR Review Teams and Financial Crime Task Forces

58


Using SARs as Leads

The Proactive Approach

• In 2001, DOJ & Treasury issued the National Money Laundering Strategy Report

• Report called for the establishment of SAR review teams in all federal judicial districts

• The idea: don’t just use SARs to further cases, but to initiate cases, using multi-agency review team

59


Currently, there are:

• One or more SAR-RT in each judicial district

and

• 53 IRS- CI led Financial Crimes Task Forces (FCTF)

60


SAR Review Teams

• Led by USAO

• Multi-Agency (some of the participating agencies

are: IRS-CI, FBI, HSI, DEA, USSS, FDIC, USDA- OIG)

• Meet monthly

• Review SAR filings for their area of responsibility

61


Key Functions of SAR-RTs

• Two very important functions of the SAR review teams are:

– Deconfliction among various law enforcement agencies

– Foster information sharing and cooperation among all participating law enforcement agencies

62


Financial Crimes Task Forces

• Investigate leads developed by SAR-RTs and through other sources

• Focus on BSA violations & Money Laundering

• Led by dedicated IRS-CI agents

• Full-time State & Local Law Enforcement Officers (Task Force Officers)

63


Win-Win Situation • IRS-CI

– Additional investigative manpower

– Fosters good relations with state & local law enforcement

– Development of numerous tax cases

• State & Local Police – Forfeiture proceeds

– Expanded resources

– Increased local enforcement

– Financial investigations Training/Expertise

64


Preliminary Investigation

• Contact & request supporting documentation from the respective SAR source.

• Create spreadsheet of structuring activity.

• De-conflict w/other agencies

• Discuss w/AUSA

65


Additional Preliminary Investigative Steps

• Surveillance/Drive-bys

• Criminal history search

• Interviews

• Trash runs

66


Investigations

Funds involved in structuring or money laundering are subject to seizure.

67


Types Of Investigations Initiated

CI initiates many different types of criminal investigations based on BSA data filings.

• Title 26

• Title 31

• Title 18

68


Case #1

Man Convicted of Selling Stolen Art and Evading the Payment of Federal Income Taxes Sentenced to More Than Seven Years in Prison He was also convicted of structuring cash transactions to avoid federal reporting requirements by making cash withdrawals in smaller amounts so as to avoid possible seizure of the funds by authorities.

69


Case #2

Contractor Pleads Guilty to Money Laundering

A builder who was awarded a contract to repave an Interstate filed bankruptcy and was using his daughters’ accounts to transfer funds and avoid detection to creditors.

70


Case #3

Former Doctor Admits Hiding Cash Deposits

A former doctor has pleaded guilty to structuring bank transactions to evade a law that requires reporting cash deposits of more than $10,000.

71


Case #4 Auto Dealer Pleads Guilty to Evading Bank Report to IRS

A car dealer plead guilty in federal court to structuring deposits of more than a million dollars to avoid having the bank report the transactions to the IRS. He made deposits of $10,000 or less, sometimes multiple times in a single day, to avoid bank reporting requirements.

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Case #5 Gamblers Pleads Guilty to Structuring to Avoid Reporting Requirements

Individuals were accused of conspiring to conduct an illegal gambling business involving cockfighting, dice tables and card games. They were also charged with 13 counts of structuring deposits from the gambling business to evade regulations relating to currency reporting.

73


Case #6

Indoor Farm Equipment Supplier Pleads Guilty to Failure to File Form 8300 A business owner selling indoor marijuana growing equipment and supplies to individuals that were illegally growing marijuana failed to file Form 8300 after accepting $17,000 in cash from an undercover law

enforcement agent.

74


Thanks

If you have any questions feel free to call us anytime.

Jerome Mc Duffie

Supervisory Special Agent, IRS-Criminal Investigation

FinCEN Liaison

Work: (703) 905-3521

Cell: (909) 322-8317

75



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