DOCSLIB.ORG

Investigation of the SEC's Response to Concerns Regarding Robert

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
Investigation of the SEC's Response to Concerns Regarding Robert This document is subject to the provisions of the Privacy Act of 1974, and may require redaction before disclosure to third parties. No redaction has been performed by the Office of Inspector General. Recipients of this report should not disseminate or copy it without the Inspector General’s approval. REPORT OF INVESTIGATION UNITED STATES SECURITIES AND EXCHANGE COMMISSION OFFICE OF INSPECTOR GENERAL Case No. OIG-526 Investigation of the SEC’s Response to Concerns Regarding Robert Allen Stanford’s Alleged Ponzi Scheme March 31, 2010 REDACTION KEY AC = Attorney-Client Privilege DPP = Deliberative Process Privilege LE = Law Enforcement Privilege PII = Personal Identifying Information PP = Personal Privacy WP = Attorney Work Product This document is subject to the provisions of the Privacy Act of 1974, and may require redaction before disclosure to third parties. No redaction has been performed by the Office of Inspector General. Recipients of this report should not disseminate or copy it without the Inspector General’s approval. Report of Investigation Investigation of the SEC’s Response to Concerns Regarding Robert Allen Stanford’s Alleged Ponzi Scheme Case No. OIG-526 Table of Contents INTRODUCTION AND BACKGROUND ....................................................................... 1 SCOPE OF THE OIG INVESTIGATION ......................................................................... 2 I. E-MAIL SEARCHES AND REVIEW OF E-MAILS......................................... 2 II. DOCUMENT REQUESTS AND REVIEW OF RECORDS.............................. 3 III. TESTIMONY AND INTERVIEWS ................................................................... 4 RELEVANT STATUTES, RULES AND REGULATIONS ........................................... 10 EXECUTIVE SUMMARY .............................................................................................. 16 RESULTS OF THE INVESTIGATION .......................................................................... 29 I. IN 1997, THE FWDO EXAMINATION STAFF REVIEWED STANFORD’S BROKER-DEALER OPERATIONS AND MADE A REFERRAL TO ENFORCEMENT DUE TO A CONCERN THAT ITS SALES OF CDs CONSTITUTED A PONZI SCHEME............................................................................................... 29 A. Two Years After Stanford Group Company Began Operations, the SEC Identified It as a Risk and a Target For an Examination Based on Suspicions That Its CD Sales Were Fraudulent........................................................................................ 29 B. After Conducting a Short Examination, the Examination Staff Concluded That Stanford Was Probably Operating a Ponzi Scheme............................................................................................ 30 C. As a Result of Their Concerns That Stanford Was Operating a Ponzi Scheme, the Examination Staff Referred Their Stanford Findings to the Enforcement Staff.................................... 33 This document is subject to the provisions of the Privacy Act of 1974, and may require redaction before disclosure to third parties. No redaction has been performed by the Office of Inspector General. Recipients of this report should not disseminate or copy it without the Inspector General’s approval. II. EIGHT MONTHS AFTER THE EXAMINATION STAFF REFERRED STANFORD, THE ENFORCEMENT STAFF OPENED, AND QUICKLY CLOSED, A MATTER UNDER INQUIRY........................................................................................................... 34 A. The 1998 Stanford MUI Was Likely Not Even Opened in Response to the Examination Staff’s Referral, But in Response to a Concern From the U.S. Customs Department That Stanford Was Laundering Money..................................................... 34 B. After Stanford Refused to Produce Documents, No Further Investigative Steps Were Taken................................................................ 36 C. The Enforcement Staff Closed the 1998 Stanford MUI Three Months After It Was Opened.......................................................... 37 1. The Enforcement Staff Told the Examination Staff That an Investigation of Stanford Was Not Warranted Because of the Lack of U.S. Investors..............................................38 2. The Enforcement Staff Told the Examination Staff That an Investigation of Stanford Would Be Too Difficult Because of the Staff’s Inability to Obtain Records From Antigua......................................................................39 3. SGC’s Outside Counsel, a Former Head Of The SEC’s Fort Worth Office, May Have Assured Barasch That “There Was Nothing There”.......................................40 III. IN 1998, THE FWDO EXAMINATION STAFF EXAMINED SGC’S INVESTMENT ADVISER OPERATIONS AND REACHED THE SAME CONCLUSION AS THE BROKER- DEALER EXAMINERS: STANFORD’S CD SALES WERE PROBABLY FRAUDULENT........................................................................... 42 A. The 1998 Examination Concluded That SGC’s Sales of SIB CDs Were Not Consistent With SGC’s Fiduciary Obligation to Its Clients Under the Investment Advisers Act............................................................................................................. 44 B. The Enforcement Staff Failed to Consider the Investment Adviser Examiners’ Concerns in Deciding Not to Investigate Stanford Further ..................................................................... 46 ii This document is subject to the provisions of the Privacy Act of 1974, and may require redaction before disclosure to third parties. No redaction has been performed by the Office of Inspector General. Recipients of this report should not disseminate or copy it without the Inspector General’s approval. IV. IN 2002, THE SEC EXAMINERS EXAMINED SGC’S INVESTMENT ADVISER OPERATIONS AGAIN AND REFERRED STANFORD TO ENFORCEMENT ............................................ 47 A. In the 2002 Examination, the Examiners Found That Stanford’s CD Sales Had Increased Significantly, Which Led to Concerns That the Potential Ponzi Scheme Was Growing .................................................................................................... 47 B. The 2002 Examination Found That SGC Was Violating the Investment Advisers Act By Failing to Conduct Any Due Diligence Related to the SIB CDs ............................................................ 50 C. During the 2002 Examination, the FWDO Enforcement Staff Received a Letter From the Daughter of an Elderly Stanford Investor Concerned That the Stanford CDs Were Fraudulent ................................................................................................. 53 Complainant 1 D. The FWDO Did Not Respond to the Letter and Did Not Take Any Action to Investigate Her Claims............................... 55 Complainant 1 E. Although a Decision Was Made to Forward the Letter to the Texas State Securities Board, the Letter Was Never Forwarded ...................................................................................... 56 F. In December 2002, the Examination Staff Referred Their Stanford Findings to the Enforcement Staff ............................................. 56 Complainant 1 G. Based on the Earlier Decision to Forward the Letter to the TSSB, the “Matter” Was Considered Referred to the TSSB Even Before the 2002 Examination Report Was Sent to Enforcement.......................................................................... 57 H. The Enforcement Staff Did Not Open an Inquiry Into Stanford and Did Not Even Review the 2002 Examination Report........................................................................................................ 58 I. The Enforcement Staff Did Not Refer the 2002 Examination Report Findings to the TSSB............................................... 59 J. In December 2002, the SEC Examination Staff Attempted to Interest the Federal Reserve in Investigating Stanford, But Concluded That the Federal Reserve Had DPP DPP of Stanford ................................................................................... 60 iii This document is subject to the provisions of the Privacy Act of 1974, and may require redaction before disclosure to third parties. No redaction has been performed by the Office of Inspector General. Recipients of this report should not disseminate or copy it without the Inspector General’s approval. V. IN 2003, THE SEC ENFORCEMENT STAFF RECEIVED TWO COMPLAINTS THAT STANFORD WAS A PONZI SCHEME, BUT NOTHING WAS DONE TO PURSUE THOSE COMPLAINTS.................................................................................................. 63 Confidential Source A. in a Ponzi Scheme Case Filed By the SEC Noted Several Similarities Between That Case and Stanford’s Operations ............................................................................... 63 B. An Anonymous Insider Warned That Stanford Was Operating “a Massive Ponzi Scheme” ...................................................... 65 VI. IN OCTOBER 2004, THE EXAMINATION STAFF CONDUCTED A FOURTH EXAMINATION OF SGC IN ORDER TO REFER STANFORD TO THE ENFORCEMENT STAFF AGAIN.................................................................................................. 70 A. The Examination Staff Was Alarmed at the Increasing Size of the Apparent Ponzi Scheme, and Accordingly, Made Another Enforcement Referral of Stanford a “Very High Priority”..................................................................................................... 70 B. The 2004 Examination Report Concluded That the SIB CDs Were Securities and Were Part of a “Very Large
Load more

Recommended publications
  • Howard R. Elisofon Partner; Co-Chair, Securities Litigation and Enforcement [email protected] (212) 592-1437 PHONE (212) 545-3366 FAX
    Howard R. Elisofon Partner; Co-Chair, Securities Litigation and Enforcement [email protected] (212) 592-1437 PHONE (212) 545-3366 FAX Howard Elisofon is a nationally renowned litigator with more than 35 years of experience in securities law and enforcement. Howard began his career as trial counsel for the SEC’s Division of Enforcement. He subsequently worked in a variety of senior legal positions at Prudential Securities and First New York Securities, where he obtained his Series 7 and Series 24 licenses, and then in private practice at Greenberg Traurig LLP, where he was a founding member of the firm’s New York office. As co-chair of Herrick’s Securities Litigation and Enforcement practice, Howard focuses on securities and commodities litigation, arbitration, mediation and investigations for broker- dealers, brokerage firms, investment advisers, investment companies, venture capital firms and insurance companies, as well as securities traders and industry executives. He represents clients in a wide variety of complex commercial litigation matters, as well as enforcement proceedings before the SEC, the Offices of the U.S. Attorneys, the New York State Attorney General and New York State District Attorneys, as well as FINRA and various exchanges, and state securities and insurance regulators. A frequent speaker on securities and enforcement related topics, and a sought-after authority on broker-dealer issues, Howard’s commentary is often featured in major media outlets. High-Profile Government Investigations and Litigation Howard has defended clients in numerous high-profile government investigations, including the Drexel Burnham/Ivan Boesky insider trading matter, the Prudential Securities limited partnership fraud scandal, the Prudential market timing investigation and the Stanford Ponzi scheme.
    [Show full text]
  • Special Committee Report
    REPORT OF THE 2009 SPECIAL REVIEW COMMITTEE ON FINRA’S EXAMINATION PROGRAM IN LIGHT OF THE STANFORD AND MADOFF SCHEMES SEPTEMBER 2009 SPECIAL REVIEW COMMITTEE Charles A. Bowsher (Chairman) ———————————— Ellyn L. Brown ———————————— Harvey J. Goldschmid ———————————— Joel Seligman ———————————— INDUSTRY GOVERNOR ADVISERS OF COUNSEL Mari Buechner Paul V. Gerlach W. Dennis Ferguson Griffith L. Green G. Donald Steel Dennis C. Hensley Michael A. Nemeroff SIDLEY AUSTIN LLP 1501 K Street, NW Washington, DC 20005 TABLE OF CONTENTS I. EXECUTIVE SUMMARY .............................................................................................. 1 A. The Stanford Case................................................................................................. 2 B. The Madoff Case................................................................................................... 4 C. Recommendations................................................................................................. 6 II. BACKGROUND ON FINRA EXAMINATION PROGRAM...................................... 9 III. EXAMINATIONS OF MEMBER FIRMS INVOLVED IN THE STANFORD AND MADOFF SCANDALS.................................................................. 11 A. The Stanford Case............................................................................................... 12 1. Background............................................................................................... 12 2. Daniel Arbitration and 2003 Cycle Examination...................................... 13 3. 2003
    [Show full text]
  • Rotary Club of Tampa North a 100% Paul Harris Fellow Club
    Rotary Club of Tampa North District 6890 ~ Club # 4293 Chartered 1954 A 100% Paul Harris Fellow Club May 4, 2020 Volume 2019-2020, Issue 31 Today’s Speaker: Andrew Warren Andrew Warren was elected as State Attorney of Florida's 13th Judicial Circuit, Hillsborough County, in November 2106. Warren leads an office of approximately 130 prosecutors and 300 total employees whose mission is to build a safer community while promot- ing justice and fairness for everyone in the criminal justice system. Since taking office on January 3, 2017, Warren has been reforming our local criminal justice system. He has been tough on violent crimi- nals, fraudsters, and repeat offenders who threaten the safety of our neighborhoods. He has utilized innovative reforms and created successful diversion programs to hold low-level offenders accountable while steering them away from the downward spiral of the system, including civil citation programs for juveniles and adults. Warren has focused on treatment, prevention, and rehabilitation for offenders with substance abuse and mental illness in order to reduce recidivism rather than further the revolving door of the criminal justice system. He has minimized poverty traps that criminalize people because they are poor. He has embraced data-driven approaches that improve safety, cut crime, and save taxpayer dollars. Additionally, Warren has emphasized transparency and civic engagement to build trust with the community that he serves. Warren previously served as a federal prosecutor with the United States Department of Justice. After initially prosecuting street crime in Washington, DC, he spent the majority of his career with the Justice Department prosecuting complex financial fraud all across the country—crimes that victimized retirees, investors, and taxpayers.
    [Show full text]
  • Stanford Ponzi Scheme: Lessons for Protecting Investors from the Next Securities Fraud
    THE STANFORD PONZI SCHEME: LESSONS FOR PROTECTING INVESTORS FROM THE NEXT SECURITIES FRAUD HEARING BEFORE THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON FINANCIAL SERVICES U.S. HOUSE OF REPRESENTATIVES ONE HUNDRED TWELFTH CONGRESS FIRST SESSION MAY 13, 2011 Printed for the use of the Committee on Financial Services Serial No. 112–30 ( U.S. GOVERNMENT PRINTING OFFICE 66–868 PDF WASHINGTON : 2011 For sale by the Superintendent of Documents, U.S. Government Printing Office Internet: bookstore.gpo.gov Phone: toll free (866) 512–1800; DC area (202) 512–1800 Fax: (202) 512–2104 Mail: Stop IDCC, Washington, DC 20402–0001 VerDate Nov 24 2008 17:24 Aug 25, 2011 Jkt 066868 PO 00000 Frm 00001 Fmt 5011 Sfmt 5011 K:\DOCS\66868.TXT TERRIE HOUSE COMMITTEE ON FINANCIAL SERVICES SPENCER BACHUS, Alabama, Chairman JEB HENSARLING, Texas, Vice Chairman BARNEY FRANK, Massachusetts, Ranking PETER T. KING, New York Member EDWARD R. ROYCE, California MAXINE WATERS, California FRANK D. LUCAS, Oklahoma CAROLYN B. MALONEY, New York RON PAUL, Texas LUIS V. GUTIERREZ, Illinois DONALD A. MANZULLO, Illinois NYDIA M. VELA´ ZQUEZ, New York WALTER B. JONES, North Carolina MELVIN L. WATT, North Carolina JUDY BIGGERT, Illinois GARY L. ACKERMAN, New York GARY G. MILLER, California BRAD SHERMAN, California SHELLEY MOORE CAPITO, West Virginia GREGORY W. MEEKS, New York SCOTT GARRETT, New Jersey MICHAEL E. CAPUANO, Massachusetts RANDY NEUGEBAUER, Texas RUBE´ N HINOJOSA, Texas PATRICK T. MCHENRY, North Carolina WM. LACY CLAY, Missouri JOHN CAMPBELL, California CAROLYN MCCARTHY, New York MICHELE BACHMANN, Minnesota JOE BACA, California THADDEUS G. McCOTTER, Michigan STEPHEN F.
    [Show full text]
  • Yom Kippur Morning 5770 Lehman Brothers, Failed
    YOM KIPPUR MORNING 5770 LEHMAN BROTHERS, FAILED BANKS, UNEMPLOYMENT, CITIBANK, ALLEN STANFORD, AIG, MARC DREIER, THE SEC, BEAR STEARNS, BAIL OUTS, BANKRUPTCIES, UNEMPLOYMENT, JAMES NICHOLSON, DELAYED RETIREMENTS, BANK OF AMERICA, UBS. BERNIE MADOFF, GREED IS GOOD, FINANCIAL MELTDOWN, MERRILL LYNCH, SUB-PRIME MORTGAGE LOANS, CALIFORNIA GOING BROKE. NON-PROFITS GOING BROKE, 401K’s DISAPPEARING, WALL STREET, TARP AND GREED, INVESTMENT BANKING IS ALL WE NEED. ECONOMY IN A FREEFALL, ECONOMY IN NEAR COLLAPSE, SUICIDE AND HEDGE FUNDS, PLUNGING HOME VALUES. THE IRS BANK FAILURES, DELAYED RETIREMENT, GM STOCK SELLING FOR A DOLLAR, STIMULUS PACKAGE, JOBS DISAPPEARING, COLLEGE ENDOWMENT FUNDS ARE SLASHED FRANK DIPASCALI, PONZI SCHEMES, CHURCH PONZI SCHEMES, AFRICAN PONZI SCHEMES, JEWISH PONZI SCHEMES, PONZI, PONZI, PONZI, BERNIE MADOFF My son David will tell you that the wildest roller coaster rides in the country are at Cedar Point Amusement Park in Sandusky, Ohio. However, looking at the American economy these past two years, we know that there have been some pretty wild rides here as well and, unlike the amusement park, these rides don’t end after two minutes. The last year and a half of the Bush Administration was a terrifying freefall. Not necessarily because of the wrong decisions being made; it just seemed that no one was in charge. No one spoke up. No one acted. No one took responsibility and the economy seemed to careen closer to the edge of the cliff with every passing day. The only real option for whoever won the Presidential election was to actually do something. Our congregants and our community, like most other congregations and communities, have been deeply affected by the events of the past two years.
    [Show full text]
  • Stanford Arbreq 290313 USPFTA
    REQUEST FOR ARBITRATION AND STATEMENT OF CLAIM UNDER THE UNCITRAL ARBITRATION RULES AND SECTION B OF CHAPTER 10 OF THE UNITED STATES - PERU FREE TRADE AGREEMENT NATIONALS OF PERU VICTIMIZED BY THE STANFORD PONZI SCHEME INVESTORS / CLAIMANTS and THE GOVERNMENT OF THE UNITED STATES OF AMERICA PARTY / RESPONDENT Pursuant to Article 10.16(1)(a) of the United States - Peru Free Trade Agreement (“USPFTA”), the Claimants hereby serve this Request for Arbitration and Statement of Claim for the non-compliance of the Government of the United States of America (the “U.S.A.,” the "United States" or the "Respondent") with certain of its obligations under the USPFTA. I. NAME AND ADDRESS OF THE DISPUTING INVESTORS 1. Pursuant to powers of attorney granted by each claimant to his, her or its respective attorney, the addresses for the Claimant/Investors are as follows: For the Claimants listed in Appendix I, Tab A: c/o: Mr. Edward F. Valdespino Strasburger & Price, LLP 300 Convent Street, Suite 900 San Antonio, Texas 78205 For the Claimants listed in Appendix I, Tab B: c/o: Mr. Peter Morgenstern Butzel Long, A Professional Corporation 380 Madison Avenue, 22nd Floor New York, NY 10017 II. BREACH OF OBLIGATIONS 2. The Claimants allege that the United States has acted inconsistently with its obligations under Section A of Chapter 10 of the USPFTA, with respect to the following provisions: i) Article 10.3 – National Treatment; ii) Article 10.4 – Most-Favored-Nation Treatment; and iii) Article 10.5 – Minimum Standard of Treatment. 3. In relevant part, the text of each applicable USPFTA provision is as follows: Article 10.3.
    [Show full text]
  • Zerohack Zer0pwn Youranonnews Yevgeniy Anikin Yes Men
    Zerohack Zer0Pwn YourAnonNews Yevgeniy Anikin Yes Men YamaTough Xtreme x-Leader xenu xen0nymous www.oem.com.mx www.nytimes.com/pages/world/asia/index.html www.informador.com.mx www.futuregov.asia www.cronica.com.mx www.asiapacificsecuritymagazine.com Worm Wolfy Withdrawal* WillyFoReal Wikileaks IRC 88.80.16.13/9999 IRC Channel WikiLeaks WiiSpellWhy whitekidney Wells Fargo weed WallRoad w0rmware Vulnerability Vladislav Khorokhorin Visa Inc. Virus Virgin Islands "Viewpointe Archive Services, LLC" Versability Verizon Venezuela Vegas Vatican City USB US Trust US Bankcorp Uruguay Uran0n unusedcrayon United Kingdom UnicormCr3w unfittoprint unelected.org UndisclosedAnon Ukraine UGNazi ua_musti_1905 U.S. Bankcorp TYLER Turkey trosec113 Trojan Horse Trojan Trivette TriCk Tribalzer0 Transnistria transaction Traitor traffic court Tradecraft Trade Secrets "Total System Services, Inc." Topiary Top Secret Tom Stracener TibitXimer Thumb Drive Thomson Reuters TheWikiBoat thepeoplescause the_infecti0n The Unknowns The UnderTaker The Syrian electronic army The Jokerhack Thailand ThaCosmo th3j35t3r testeux1 TEST Telecomix TehWongZ Teddy Bigglesworth TeaMp0isoN TeamHav0k Team Ghost Shell Team Digi7al tdl4 taxes TARP tango down Tampa Tammy Shapiro Taiwan Tabu T0x1c t0wN T.A.R.P. Syrian Electronic Army syndiv Symantec Corporation Switzerland Swingers Club SWIFT Sweden Swan SwaggSec Swagg Security "SunGard Data Systems, Inc." Stuxnet Stringer Streamroller Stole* Sterlok SteelAnne st0rm SQLi Spyware Spying Spydevilz Spy Camera Sposed Spook Spoofing Splendide
    [Show full text]
  • Branding in Ponzi Investment Schemes by Yaron Sher Thesis Bachelors of Honours in Strategic Brand Communication Vega School Of
    BRANDING IN PONZI INVESTMENT SCHEMES BY YARON SHER THESIS SUBMITTED IN THE FUFILLMENT OF THE REQUIREMENTS OF THE DEGREE BACHELORS OF HONOURS IN STRATEGIC BRAND COMMUNICATION AT THE VEGA SCHOOL OF BRAND LEADERSHIP JOHANNESBURG SUPERVISOR: NICOLE MASON DATE: 23/10/2015 Acknowledgements First and foremost, I wish to express my thanks to Nicole Mason, my research supervisor, for providing me with all the necessary assistance in completing this research paper. I would also like to give thanks to Jenna Echakowitz and Alison Cordeiro for their assistance in the construction of my research activation and presentation. I take this opportunity to express gratitude to all faculty members at Vega School of Brand Leadership Johannesburg for their help and support. I would like thank my family especially my parents Dafna and Manfred Sher for their love and encouragement. I am also grateful to my girlfriend Cayli Smith who provided me with the necessary support throughout this particular period. I also like to place on record, my sense of gratitude to one and all, who directly or indirectly, have helped me in this producing this research study. Page 2 of 60 Abstract The subject field that involves illegal investment schemes such as the Ponzi scheme is an issue that creates a significant negative issues in today’s society. The issue results in forcing financial investors to question their relationship and trust with certain individuals who manage their investments. This issue also forces investors, as well as society, to question the ethics of people, especially those involved in investments who operate their brand within the financial sector.
    [Show full text]
  • Drug Enforcement Administration FOIA Request Logs, FY2011-2016
    Drug Enforcement Administration FOIA request logs, FY2011-2016 Brought to you by AltGov2 www.altgov2.org/FOIALand Received between 10/01/2010 and 09/30/2011 Request ID Received Date Closed Date Request Description Final Disposition 10/1/2010 4/30/2012 ANY AND ALL DOCUMENTS AND INFORMATION Granted/Denied in Part REGARDING AIRCRAFT BEECRAFT KING AIR 200 TAIL/ID #N642TF. ETC. 11-00001-F 8/2/2011 8/2/2011 INFORMATION CONCERNING THE "COCAINE Other Reasons - Records not reasonably 11-00002-F DRUG STATUE" described 6/22/2011 6/22/2011 INFORMATION REGARDING ILLEGAL DRUG Other Reasons - "Refusal to comply with other ACTIVITIES BETWEEN FLORIDA AND BILLERICA, requirements - Identification..." MA THAT WAS REPORTED TO DEA BY THE BOSTON, MA FIELD INTELLIGENCE SUPPORT 11-00003-F TEAMS (FIST) (SEPTEMBER 2005) 10/5/2010 6/29/2011 ANY AND ALL REPORTS, NOTICES OF LOSS Granted in full AND/OR FILINGS OF ANY SORT PERTAINING TO THE HAMPSTEAD PHARMACY, INC. AND/OR HAMPSTEAD MEDICAL CENTER LOCATED AT 14980 US WEST HIGHWAY 17, NORTH 11-00004-F HAMPSTEAD, NORTH CAROLINA 28443 10/5/2010 6/24/2011 COPIES OF THE "OATH OF OFFICE" FOR THE Granted/Denied in Part (b)(6), DEA SPECIAL AGENTS, FOR THE U.S. DEPARTMENT OF JUSTICE , DRUG ENFORCEMENT ADMINISTRATION'S LAKE MARY/HEATHROW 11-00005-F OFFICE IN FLORIDA 10/5/2010 6/27/2011 STRIDE DATA ON MARIJUANA FOR ALL YEARS Other Reasons - Request Withdrawn 11-00006-F AVAILABLE 10/5/2010 11/29/2010 ANY AND ALL RECORSD IN POSSESSION, Other Reasons - "Refusal to comply with other CUSTODY, OR CONTROL OF THE DRUG requirements - Identification..." ENFORCEMENT ADMINISTRATION THAT REFER TO, RELATE, TO OR MENTION (b)(6), ETC.
    [Show full text]
  • Anatomy of a Financial Fraud: Madoff, Stanford, and the $100 Billion Shell Game
    The University of Texas School of Law 2009 Page Keeton Civil Litigation Conference October 29-30, 2009 Austin, Texas Anatomy of a Financial Fraud: Madoff, Stanford, and the $100 Billion Shell Game Stephen F. Malouf Stephen F. Malouf The Law Offices of Stephen F. Malouf, P.C. 3811 Turtle Creek Blvd., Suite 1600 Dallas, Texas 75219 (214) 969-7373 [email protected] Continuing Legal Education • 512-475-6700 • www.utcle.org Anatomy of a Financial Fraud: Madoff, Stanford, and the $100 Billion Shell Game I. INTRODUCTION On December 11, 2008, FBI Special Agent Theodore Cacioppi met with Bernard Madoff at Madoff’s apartment in New York. after the FBI was informed by certain Madoff employees that Madoff had confessed to them that “in substance, ...his investment advisory business was a fraud.”1 According to Cacioppi: After identifying myself, MADOFF invited me, and the FBI agent who accompanied me, into his apartment. He acknowledged knowing why we were there. After I stated, “we're here to find out if there's an innocent explanation." MADOFF stated, “There is no innocent explanation." MADOFF stated, in substance, that he had personally traded and lost money for institutional clients, and that it was all his fault. MADOFF further 'stated, in substance, that he ~paid investors with money that wasn't there." MADOFF also said that he was “broke" and "insolvent" and that he had decided that “it could not go on," and that he expected to go to jail. MADOFF also stated that he had recently admitted what he had done to Senior Employee Nos.
    [Show full text]
  • United States District Court Northern District of Texas Dallas Division
    Case 3:16-cv-01152-C Document 1 Filed 04/28/16 Page 1 of 99 PageID 1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION SANDRA DORRELL and PHILLIP A. § WILKINSON, individually and on behalf of § a class of all others similarly situated, § Plaintiffs, § § vs. § § CIVIL ACTION NO. 3:16-cv-1152 PROSKAUER ROSE, LLP, and § THOMAS V. SJOBLOM, § § Defendants. § PLAINTIFFS’ ORIGINAL COMPLAINT Case 3:16-cv-01152-C Document 1 Filed 04/28/16 Page 2 of 99 PageID 2 TABLE OF CONTENTS I. PREFACE ........................................................................................................................ 1 II. PARTIES ......................................................................................................................... 3 III. PERSONAL JURISDICTION ....................................................................................... 4 IV. SUBJECT MATTER JURISDICTION AND VENUE ................................................ 5 V. FACTUAL BACKGROUND ......................................................................................... 5 A. The Stanford Financial Group Empire ........................................................................ 5 B. Stanford Financial’s Operations in the United States .................................................. 7 C. The Anatomy of the Stanford Ponzi Scheme .............................................................. 9 1. The Beginning: Guardian International Bank ...................................................... 11 2. Stanford Creates a Safe Haven in
    [Show full text]
  • The Enneagram and Its Implications for Sales Management: Part I
    The H Factor: A Behavioral Explanation of Leadership Failures in the 2007-2009 Financial System Meltdown Charles F. Falk Northeastern Illinois University Bruce K. Blaylock Radford University To date, several technical analyses offer causality for the 2007-2009 “Great Recession.” This work offers a different perspective by applying behavioral analysis of the actions taken by the relatively small number of leaders in the middle of the maelstrom. Using a behavioral construct called the “H Factor,” the researchers examined how a sample of key players scored on the negative traits of hubris, hypocrisy, and hostility; and on the positive traits of honor, humility, and honesty. The researchers posit that those choosing leaders for key positions could benefit by evaluating candidates through a prism of an H Factor-based analysis. INTRODUCTION No one living anywhere in the modern world in 2007-2009 could be unaware of the dramatic, and seemingly-sudden, disintegration of the financial and economic system in the United States. In this period, now referred to as “The Great Recession,” several iconic businesses and financial houses went bankrupt while others lost most of their market capitalization. As a by-product of these seismic shifts, jobs have been lost by the millions; unemployment has soared; personal wealth has been decimated as homes lost significant value and 401K’s and other retirement and investment vehicles lost half or more of their value. The hopes and dreams of countless individuals and families have been altered, perhaps irretrievably, as job losses altered career aspirations and financial losses changed the trajectories of plans for retirements; children’s educations; home purchases; small business expansions; and other daily, but significant decisions.
    [Show full text]