Anonymous Asset Management Company - Tri Risk

CHALLENGE

An initial financial statement audit quickly evolved into a comprehensive fraud investigation involving a €100M international real estate investment fund suspected of operating as a Ponzi scheme. Leading a multidisciplinary team comprising two real estate management specialists, four accountants, and a compliance assistant, I identified significant indicators of potential fraud, including the misappropriation of investor funds and suspicious accounting entries. This investigation was conducted in strict adherence to applicable federal and state AML regulations, specifically HGB (‘Handelsgesetzbuch’), GwG (‘Geldwäschegesetz’) and BaFin (Bundesanstalt für
Finanzdienstleistungsaufsicht).

APPROACH AND RESULTS

Structured Investigation: A methodical, phased approach was employed to scrutinize the fund’s financial and accounting records. Utilizing both conventional and advanced investigative techniques, the team systematically identified and documented fraudulent activities, ensuring that all findings were aligned with BaFin’s regulatory compliance requirements and ethical standards.

Regulatory Engagement: Detailed documentation of our findings was submitted to the appropriate financial regulatory authority, reinforcing the credibility of the investigation and facilitating subsequent legal proceedings. This proactive regulatory engagement demonstrated our commitment to upholding the highest standards of compliance in fighting financial fraud.

Expert Compliance Oversight: Leveraging deep expertise in compliance and financial regulation, my team successfully navigated complex challenges, leading to the identification of a series of opaque financial transactions that were integral to uncovering the fraudulent activities. My independent judgment and rigorous adherence to compliance protocols were pivotal in achieving this outcome.

OUTCOME

The investigation confirmed the operation of a Ponzi scheme, leading to prosecutions, and several instances of financial statement fraud. The case underscored the importance of robust oversight and meticulous investigative processes in safeguarding investor interests.

TESTIMONIAL

“It is my pleasure to write a note of recommendation on behalf of Constantine Allen with whom I collaborated on two Business & Finance Audits of a Venture Start-up in Mallorca. Constantine has a unique capacity to gain multiple perspectives and views, to translate those in a way that is relevant and appropriate to the business requirements. In his field work, Constantine was always inclusive of all stakeholder perspectives and demonstrated in tense moments his skills as an accomplished facilitator which allowed for transparency, trust and inclusion. Furthermore, Constantine distinguishes himself through tenacity and persistence to get the job done and benefits hereby from a career history in finance operation management, financial auditing & compliance and associated restructuring projects which makes him a hands-on, well-rounded and insightful colleague! Conclusively, I can state without doubt that Constantine is an individual with high levels of intellect and with the unique ability to quickly assess complex issues and the potential of making immediate positive impact.”

General Manager