ShoreBank, the CFSI Board of Directors, and all the CFSI Funding Organizations: Annie E. Casey Foundation, Bank of America Charitable Foundation, Ford Foundation Heron Foundation, Citigroup Foundation, should be subjected to scrutiny.
THE MODUS OPERANDI The IRS has pinpointed tax-exempts and non-profits as the locus classicus for money laundering and tax evasion (stolen money is taxable).
The biggest frauds are tax-exempts writing checks to other tax-exempts---the way these "altruistic do-gooders" siphon off, then launder, tax-free monies for themselves.
The use of government funds to subsidize ShoreBank gives rise to concerns about massive govt fraud and money laundering.
Do these entities engage in offshore financial actvities?
Was there improper use of pension funds?
Was there improper use of credit cards? (EXAMPLE government fraud and embezzlement from pension funds could be facilitated w/ credit cards utilizing complex repayment systems).
Did ShoreBank "write off" millions in "loans" to these entities?
Criminal complaints for fraud, embezzlement, conspiracy and concealment, and criminal civil rights violations could be charged. It is also possible that other federal offenses have also been committed including but not limited to;
Title 18 U.S.C. §1341, Mail Fraud,
18 U.S.C.§1001, Presenting a False Document to the an Agent of the US Government;
18 U.S.C.§1027 False statements and concealment of facts in relation to documents required by the 1974 ERISA law and other possible offenses including civil and/or criminal RICO violations.
18 U.S.C. §§1961-68 (RICO Act)
18 U.S.C. §1001 (False Statementsto Agents of the US Government),
18 U.S.C. §1341 (Mail Fraud),
18 U.S.C. §1027 (ERISA Violations), and,
18 U.S.C. §241(Conspiracy Against Civil Rights).
Full investigations of a RICO conspiracy under 18 U.S.C. §1962(c) could be warranted because the law asserts that (1) persons (2) were employed by or associated with an enterprise (3) that engaged in or affected interstate commerce and that (4) the defendant persons operated or managed the enterprise (5) through a pattern (6) of racketeering activity, and (7) the complaints were injured in its business or property by reason ofthe pattern of racketeering activity.
RICO investigation could also warrant Complaints alleging a violation of Title 18 U.S.C. §241 – Conspiracy Against Constitutional Rights – which prohibits in relevant part, “two or more persons (from conspiring) to injure, oppress, threaten, or intimidate any person in any State, Territory,Commonwealth, Possession, or District in the free exercise or enjoyment of any right or privilege secured to him by the Constitution or laws of the United States, or because of his having so exercised the same . . .” See, 18 U.S.C. §241.
========================================
While acting as succesful philanthropists, did the named individuals create a labyrinth of complex, interrelated international funds, institutions and financial entities with assets and businesses in multiple places overseas to facilitate money laundering, tax evasion and government fraud?
The Center for Financial Services Innovation, ShoreBank, and its associates, could be operating:
(1) a Ponzi fraud;
(2) laundering tax-free money for the wealthy with phony philathropic "foundations and charities"
(3) IRS fraud facilitation;
(4) a protection racket (shielding wealthy individuals from federal scrutiny);
(5) laundering tax-free money that ended up as donations to Democrat candidates (campaign fraud).