detective michael stevens detective hilary bledsoe orlando police department
TRANSCRIPT
Time Share Fraud Investigations
Detective Michael StevensDetective Hilary Bledsoe
Orlando Police Department
PROBLEM: Organized Criminal Groups Conducting Wire Fraud Companies based in Central Florida that
utilize satellite offices/ drop boxes all over the US
Thousands of victims worldwideFictitious companies that rename every 60-90
daysDifficult to infiltrate into the inner groupVery little law enforcement knowledge of the
groupsIncorporated company is different from
company pitched to victimsLarge profits allow groups to finance
widespread fraud
RESPONSE: OPD dedicates two detectives full time for three months on investigationDevelop contact with Department of
Agriculture and Consumer Affairs, State Attorney Generals Office and other law enforcement agencies both State and Federal
Detectives research timeshare industry and develop a basis of knowledge
Review of crimeline complaints and tips in an attempt to identify organizations operating within the 9th Judicial circuit
Statewide prosecution focusLong term investigation targeting upper level
subjects
PHASE 1:Gather, develop and analyze intelligence and
information on groupsReview of Crime Line tips, public records,
state corporate records, internet sites and social networking sites
Contact with other Central Florida Law Enforcement agencies
Identify target for investigation
PHASE 2:Develop an operational plan for the course of the
investigationSurveillanceTrash pullsDevelopment of sources of informationUse of confidential informantsLaw enforcement informationPublic records searchInterview of witnesses and victimsContact with prosecutorDecision of prosecution before or after search
warrants
PHASE 3:Identification of
AssetsBank accounts
linked to business and subjects
HomesVehiclesBusinessesOther
PHASE 3 CONTINUED:Use of investigative subpoenaShow the money flowUse of law enforcement databases and
communicationsExamination of documents linking assets to
illegal conductContacts with financial institutionsCoordinating account seizures within the
investigation
PHASE 4:Determine charges based upon the
investigation to dateAggressive use of search and seizure
warrantsTarget “boiler/phone rooms”Residences Financial institutionsDocuments, documents, documents (nothing is
too small)Computer systems and storage devices
PHASE 5:Document review and exploitation
Immediate action at the scene (bank accounts, other search/seizure warrants, identification of assets)
Historical document reviewEvery document is important- Case agents
should review ALL evidenceUse of documents to corroborate SOI, CI,
witness and victim informationLength, scope, size and amount of fraudulent
activity
PHASE 6:Secondary interviews and Proffers
DefendantsWitnessesEx-employeesCurrent employeesNew victims
PHASE 7:Financial Investigations
Identify corporate and personal bank accounts for the organization
Identify host financial institutionsUse of investigative subpoenaExamination of subpoenaed documents
Statement review Identification of additional corporate entities and
co-conspirators Identification of money laundering counts
Clues for the AML InvestigatorCorporate accounts with limited shelf lifeActivity inconsistent with normal account activity
for the type of businessNo previous banking history for the companyWide spread deposits into the account from multiple
subjects via wire, check and direct cash depositsCorporate accounts associated with large ACH
dumpsRapid withdrawals and transfers to associated
accounts under different corporate names or individuals
Clues for the AML Investigator continuedFraud complaints made to the host financial
institutionWidespread use of bank of cashiers checksMultiple corporate accounts with the same
signatories
What We Need From YouIdentify accounts Your professional experience as subject matter
expertsMovement of fundsCorporate entities and individuals attached to the
accountsSAR and CTR activityInformation on bank and cashiers checksIdentification of major purchase and/or luxury itemsThis may come from subpoenaed documents or a
phone call
KEY POINTS TO REMEMBERTREAT THE INVESTIGATION AS A RICODOCUMENTS ARE KEYDEVELOP COOPERATING DEFENDANTSWORK WITH YOUR PROSECUTORUSE SEARCH WARRANTS AS A TOOL NOT
AN END RESULTCHOOSE EVIDENCE OVER MONEYWORK TOGETHER/ASK FOR ASSISTANCEGO UP THE FOOD CHAIN NOT DOWN IT
Case StudiesVacation Realty International
Account seizureCarFurnitureHomes$ payments to straw nomineeBank of AmericaFifth ThirdSun Trust
Case StudiesJAMS Management
15 million in fraud over two yearsWidespread ACH dumps into corporate
accounts and personal checksFunds transferred to other corporate accounts
all within the organizationPurchases
CarsHomesHorses