Securities Industry Commentator by Bill Singer Esq

According to the indictment, the Infraud Organization was created in October 2010 by Svyatoslav Bondarenko aka "Obnon," aka "Rector," aka "Helkern," 34, of Ukraine, to promote and grow interest in the Infraud Organization as the premier destination for carding-purchasing retail items with counterfeit or stolen credit card information-on the Internet.  Under the slogan, "In Fraud We Trust," the organization directed traffic and potential purchasers to the automated vending sites of its members, which served as online conduits to traffic in stolen means of identification, stolen financial and banking information, malware, and other illicit goods.  It also provided an escrow service to facilitate illicit digital currency transactions among its members and employed screening protocols that purported to ensure only high quality vendors of stolen cards, personally identifiable information, and other contraband were permitted to advertise to members. 

According to the indictment, Infraud members held defined roles within the organization's hierarchy.  "Administrators" managed day-to-day operation of and strategic planning for the organization, approved and monitored membership, and meted out punishments and rewards to members.  "Super Moderators" oversaw and administered specific subject-matter areas within their expertise.  "Moderators" moderated one or two specific sub-forums within their areas of subject-matter expertise.  "Vendors" sold illicit products and services to Infraud members.  Finally, "VIP Members" and "Members" used the Infraud forum to gather information and to facilitate their criminal activities.  As of March 2017, there were 10,901 registered members of the Infraud Organization. 

At today's hearing, Rabobank pleaded guilty to conspiracy to defraud the United States and to corruptly obstruct an examination of a financial institution. In pleading guilty, Rabobank admitted to conspiring with several former executives to defraud the United States by unlawfully impeding the OCC's ability to regulate the bank, and to obstruct an examination by the OCC of its operations throughout California, including its Calexico and Tecate bank branches.  Rabobank admitted that its deficient AML program allowed hundreds of millions of dollars in untraceable cash, sourced from Mexico and elsewhere, to be deposited into its rural bank branches in Imperial County, and transferred via wire transfers, checks, and cash transactions, without proper notification to federal regulators as required by law.  Knowing these failures, during the OCC's 2012 examination of Rabobank's BSA/AML compliance program, Rabobank executives actively sought to hide and minimize the deficiencies in its AML program in an effort to deceive the regulators as to its true state in hopes of avoiding regulatory sanctions that had previously been imposed on Rabobank in 2006 and 2008 for nearly identical failures.

• Securities Industry Commentator
• Bill Singer