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4
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.
5
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
6
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.
8
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
90%
2. For civil case need to prove by showing clear and convincing evidence
75%
3. Preponderance of evidence
51%
9
Has to file taxes
Criminal
Tax Fraud
Doesn’t have to file taxes
Criminal
Tax Evasion
Government Discretion
Beyond Reasonable Doubt
Clear and convincing
Civil
Tax Fraud
Civil
Civil
Tax
Tax Evasion
Evasion
Taxpayer attitude/ behavior
10
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
11
SIRF – Stolen Identity Refund Fraud
• 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
12
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.
ClaustrumView LLC
Account @ My Bank
$8,000,000
ClaustrumView LLC
Account @ ABC Bank
$7,750,000
Escrow Company
•
•
•
•
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
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.
Wire ClaustrumView LLC
Account @ XYZ Bank
$1,000,000
$3,000,000
Elder Personal Account
@ ABC Bank
314b
ClaustrumView LLC
Account @ My Bank $8,000,000
$8,000,000
Wires from Eastern Europe
-Proceeds from the sale of investments
- Using retirement funds
$4,000,000
Said he was helping family and
preparing for retirement
Elder, Acct bank2
Elder, Acct bank1
Elder, Acct bank3
ClaustrumView LLC
Account @ ABC Bank
5 to 7k a week cash, each account
$7,750,000
Per the indictment…..
Escrow Company
Tom Skimmed from gas stations
14
Fun Fact Break
Reasons financial statement fraud is committed:
1.
2.
3.
4.
Comply with financial covenants imposed by a bank
To help get financing
Cover up poor performance
Selling the business
1. Tax Fraud
2. Bankruptcy
3. Divorce - Split in half a smaller number
Make business look
better
Make business look
worse
15
Date
Amount
Transaction Direction Beneficiary
2/14/2013 $ 250,000.00 Wire Transfer Debit
Singapore Toy Co., Ltd
•
•
•
•
•
•
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
16
Fashion district vendors
Flee market vendors
Overbilling?
Trade based ML?
Beneficial owner of Singapore Toy Co., Ltd?
Cash
AB Toys
Importer
• 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
17
Secret non-taxable accounts offshore
U.S.
Singapore
Draws $ into U.S. via credit card
Importer’s Singapore account
Fashion district vendors
AB Toys
Flee market vendors
Cash
Importer
Higher U.S. business expenses
$2 Split 3 ways
$0.90 back to Importer
$1 for Gumby
$0.10 Commission
$0.90
- Showed us receipt for 125,000 Gumby @ $2
- Gumby really cost $1 each
18
Fun Fact Break
• There are 19 tax court judges who travel to all 50 states
to hold tax court
19
• 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
20
Israel
Advanced Forecasting Corp
From 2003 to 2008 - $1,808,075
Exportus Ltd- Bank Account 1
On Advanced Forecasting corp’s
return he called these “information
acquisition expenses”
21
Estimated tax savings assuming 30%
tax rate. 1.8MM x 30% = $540,000
Sentencing this November 2013
U.S. Personal account
Non-taxable gift
$
Step 1-$1,808,075
Advanced Forecasting Corp
Exportus Ltd- Bank 1 account 1
$
Step 2
$ Step 4
$
Charles Schwab
relative’s account
Step 3
$
$
Exportus Ltd – Bank 2 account 1
22
Fun Fact Break
Cities with the most tax evasion:
1.
2.
3.
4.
5.
Los Angeles
San Francisco
Houston
Atlanta
DC
23
24
• 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
Alert
Acct 1
$6,509 7/10/2013
$8,975 7/11/2013
7/16/2013
7/17/2013
• 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.
Acct 2
$4,985
$7,582
Rest Acct 3
Rest Acct 2
Rest Acct 1
$
$
Rob Sr.
Acct
Insurance
$
$
Rental Acct 1
Checks to “Luxury Air Travel”
$
Family Mgt Corp Acct
$
Credit Cards
$
Rental Acct 3
Rental Acct 2
Mortgage
Each rental property is owned by Rob Sr.
25
Types of Income:
• 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
26
Assumptions
$1,000,000 house
30 years @ 4%
Nothing down
4k a month rent
48,000
650
39,670
DEPRECIATION
$1,000,000 house
50% of the value is the
“depreciable” base
11,691
$500,000/27.5
2,300
18,181
72,492
(24,492)
X 3 properties = 75k in
“suspended” Passive
Activity Losses
27
Suspended passive activity losses can only be offset by other passive income
• 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
28
Alert
Acct 1
Acct 2
$6,509 7/10/2013
$8,975 7/11/2013
7/16/2013
7/17/2013
Rest Acct 1
$
• 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.
$4,985
$7,582
Rest Acct 2
$
Rental Acct 1
Rest Acct 3
Credit Cards
$
$
 $75k in suspended losses a year
 Offset by high rents
$
$
Rental Acct 3
Rental Acct 2
$
Rob Sr.
Acct
Insurance
Mortgage
Each rental property is owned by Rob Sr
29
Higher rent = lower taxable income for restaurant operating company
ACTUAL rent
Income
$1,000,000
Expenses
Food
$300,000
Labor
$300,000
Rent
$400,000
Taxable income
$0
Market rate
Vs.
Income
$1,000,000
Expenses
Food
$300,000
Labor
$300,000
Rent
$100,000
Taxable income $300,000
Arm’s length principle: Prices must be comparable to the prices charged for the same
goods and services between unrelated parties.
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
•
SAR
Rent payments are 4 times market. Between
the suspended losses and restaurant tax
benefit, hundreds of thousands could be
evaded.
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?
31
Alert
Acct 1
Acct 2
$6,509 7/10/2013
$8,975 7/11/2013
7/16/2013
7/17/2013
Rest Acct 1
$
• 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.
$4,985
$7,582
Rest Acct 2
$
Rental Acct 1
Rest Acct 3
Credit Cards
$
$
 $75k in suspended losses a year
 Offset by high rents
$
$
Rental Acct 3
Rental Acct 2
$
Rob Sr.
Acct
Insurance
Mortgage
Each rental property is owned by Rob Sr
32
Passive Income Generators (PIGs) eat Passive Income Losses (PALs)
PIGs Eat PALs
PIG
PAL
33
IRS
Criminal Investigation (CI)
BSA Program
• Jerome McDuffie
• Supervisory Special Agent
• IRS-CI Liaison to FinCEN
34
Purpose of this Presentation
• Provide an overview of BSA reporting requirements
• Identify Statutes used by IRS CI
• Identify Title 31 Authority for IRS-CI (Treasury Directive 1541 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 Forces35
Overview of the criminal statutes utilized
by IRS-CI Special Agents
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
36
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
37
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
38
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
39
seizure.
Title 31 Authority for IRS CI
• 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
T-31 Authority in the U.S. Code
• T-31
–
–
5313:
5317:
–
–
–
–
5322:
5324:
5330:
5332:
Reporting Requirement
Seizure, Forfeiture Authority
981, 982, and 984
Criminal Penalties [5 yrs.]
STRUCTURING--- “the biggie”
Registering of MSBs
Bulk Currency Smuggling
41
BSA FORMS: [main ones]
•
•
•
•
•
•
TDF 90-22.47
FinCEN 104
FinCEN 105
FinCEN 107
FinCEN 109
FinCEN 8300
Suspicious Activity Report
Currency Transaction Report
CMIR
Registration of MSBs
SAR for MSBs
Report of Cash >$10,000 in a
Trade or Business
• TDF 90-22.1 [FBAR] Foreign Bank Account
42
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
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
48
Suspicious Activity Defined
– Appear to serve no business or apparent lawful
purpose
– Involve use of bank, etc. to facilitate criminal
activity
49
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.
50
FinCEN
51
•
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.
Safeguarding SARs and SAR
Information
52
•
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
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
54
•
Information
•It is imperative that the information
contained in, and even the existence of, a
SAR cannot be disclosed to taxpayer.
55
Information
Criminal penalties may apply for willful
unauthorized disclosures.
56
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
57
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.
72
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
If you have additional questions for today’s experts,
or
suggestions for future web seminars,
please send those to:
[email protected]
Thank you for joining us today!
77
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To request a certificate of attendance, please fill out the
request form, found in your reference materials, and
email the form to [email protected] along with your
payment information. First certificate is included in cost
of seminars. There is a $40 administrative fee for each
additional certificate.
You may also call +1 305.373.0020 to process payment
over the phone.
78
SAVE THE DATE! TARGETED FULL-DAY SEMINARS FOR ALL
LEVELS
1)
AML BSA 101: Essential Training for Compliance Professionals
September 11 | Chicago
September 13 | New York City
DOWNLOAD AGENDA AT www2.acams.org/101
2)
Building a Sound Framework For Enterprise Risk Management (ERM)
September 30 | Chicago
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October 4 | Toronto
DOWNLOAD AGENDA AT www2.acams.org/RISK
3)
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October 28 | Chicago
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DOWNLOAD AGENDA AT www2.acams.org/TRADE
Future Web Seminars
OCT 02 –
FREE Financial Warfare: A Conversation with
National Security Expert Juan Zarate
Level: All
Noon to 2:00pm EDT
OCT 08 –
FREE ACAMS 12th Annual Conference Insight: Managing
Global Financial Crime Risk
Level: All
Noon to 1:00pm EDT
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of the Industry
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