Thursday, November 29, 2012


A US law enforcement agent has publicly disclosed, during an interview, that there are eighty-six Federal fugitives, all believed to be in the South Florida area, who are wanted on charges of Medicare Fraud. Some of these individuals are also accused of money laundering.

This is of relevant interest to compliance officers at South Florida financial institutions, and broker-dealers, because many of there fugitives have defrauded the United States out of millions of dollars in Medicare payments, and therefore have substantial assets. You are advised to look carefully at new customers who fit the following profile:

(1) High net worth individuals or closely-held corporations with larger amounts of cash to deposit.

(2) Dominican or Cuban nationality, or Cuban-Americans who are resident in Florida.

(3) Little or no prior credit agency history.

(4) Present or prior health care industry connections or involvement.

(5) Medical supply store owner or operator.

(6) Individuals who have been resident in the United States for a short period of time. Many medicare fraudsters import front men from the Dominican Republic, or the Republic of Cuba,  and return them to their native countries after the fraud has been successfully perpetrated. Is he totally monolingual, with no English-speaking ability ? If so, he may be a recent arrival. Does he exhibit regional slang in his Spanish that may indicate he is not a long-time resident of Florida ?

(7) Request to deposit US Government cheques in large amounts.

The above is not to be used to bar new customers, but to screen out any who may now need Enhanced Due Diligence to rule them out as white-collar criminals. This is all about Know Your Customer; if you vett the new customer properly, you will not unwittingly admit Medicare fraudsters into your client base.

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