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Historical document reviewEvery document is important- Case agents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

How they see themselves…..

DOCUMENTS LOCATED INSIDE THE BOILER ROOM