Module 7
Fraud in E-Commerce and Elsewhere
A. Fraud Risks in E-Commerce
Although fraud can occur in any environment, several aspects of e-business
environments present unique risks. These characteristics of the Internetdriven economy
create pressures and opportunities specific to e-commerce fraud. Just like other frauds,
these new frauds are perpetrated when pressures, opportunities, and rationalizations come
together. Many of the most serious e-commerce fraud risks are found within
organizations. Once perpetrators are within firewalls and security checks, it is much
easier to infiltrate systems, steal money and information, and cause damage. Perpetrators
with inside access know the control environment, understand security mechanisms, and
find ways to bypass security.
One of the most serious problems is the abuse of power that has been granted to
users. For example, programmers and technical support personnel usually have full,
superuser access to the systems they create and administrate. Often, removal of
programmer access is overlooked when systems go into production, allowing them free
and unlimited access of corporate data years into the future. In one survey, more than a
third of network administrators admitted to snooping into human resource records, layoff
lists, and custom databases4 A related survey found that 88 percent of administrators
would take sensitive data if they were fired, and 33 percent said they would take
company password lists.
Even if a perpetrator does not have personal access to needed systems, he or she
can hijack others’ passwords to achieve access. Passwords can be the Achilles’ heel of
many systems because password selection is left to the end user and cannot be fully
controlled. Mothers’ maiden names, birthdays of children, favorite locations, and other
personal information used to generate passwords can be guessed by perpetrators when
fraud is internal and employees know each other personally. Hackers often use social
engineering techniques to gain access to passwords. Instant messaging, blog entries,
Facebook walls, and other social networking devices provide perpetrators with a new
method of gathering information. When a hacker presents valid information to a user and
asks for “just a little more,” some users think the request is appropriate. For example, a
hacker may call a targeted user and pose as technical support.
One of the more recent scams for business travelers is called wartrapping. In this
scam, hackers go to known business traveler locations like airports and set up access
points through their laptops to the Internet. Their laptops look like regular wireless
networks to which others can connect. When travelers open their laptops, their wireless
cards connect automatically to these “free” Internet access points. Many travelers think
they are connected to the airport’s official wireless network, but they are actually passing
network traffic through the hackers’ computers. As the travelers browse the Internet,
check email, and use their corporate networks, the hackers sniff for passwords and other
important information.
Recently, the advent of USB drives, increased memory on phones, and portable
external hard drives poses security threats. Their large capacities allow them to quickly
download significant amounts of information from internal networks. These devices,
including camera phones and iPod-like music players, have been banned at many military
installations because of the potential threat they pose. For example, when iPods first hit
the market, a common tactic by customers at electronics stores was to connect iPods to a
demonstration computer and quickly steal software like Microsoft Office. Because of the
iPod’s fast interface and ubiquitous appearance, stealing hundreds of megabytes of data
could be done within just a few minutes.
In 2009, hackers set a new high score for credit card theft by allegedly stealing
130 million credit cards at one location.6 Albert Gonzalez, a 28-year-old, used SQL
injections (described later in this chapter) to get around corporate firewalls and steal
credit and debit card information. They attacked several companies, including
convenience store chains, credit card processors, and supermarket chains. When federal
agents raided his home, they found computers, firearms, expensive jewelry, and $1.1
million in cash buried in the backyard. While this case may be the largest in history, it is
certainly not the only one; a web search for “hackers credit cards” yields many such
stories of stolen credit cards.
The Internet provides a rich medium for external hackers to gain access to
personal systems. Hackers are relatively protected because they cross international
boundaries and are mostly anonymous—making tracking and prosecution difficult. When
successful investigation and prosecution do occur, sentences are typically light and do
little to deter would-be attackers. For example, Jeffrey Lee Parson, a 19-year-old who
unleashed part of the MSBlast worm attack, received 18 to 37 months in prison. Jan de
Wit, author of the Anna Kournikova virus, was required to complete 150 hours of
community service in the Netherlands. These viruses infected millions of computers and
caused significant damage, costs, and time loss worldwide.
Spyware has become a difficult online problem in recent years. This type of
malware—similar to a trojan horse—installs monitoring software in addition to the
regular software that a user downloads or buys. For example, peer-to-peer music and
video-sharing applications are some of the worst spyware offenders. Many of these
programs install monitors that send online user behaviors to companies that turn a profit
on the personal information they collect. More targeted spyware can lift financial or other
sensitive information from internal directories and files and send it to external entities.
Phishing is a common method that hackers use to extract personal or corporate
information from employees. Phishers send e-mail or pop-up messages to users asking
for personal information in inventive ways. For example, a hacker might send an e-mail
impersonating technical support to company employees. If even 1 percent of the
employees respond with their password or other information, the hacker may be able to
access a company’s internal networks and open future back doors before preventative
steps can be taken. False Web sites are another method of tricking users into providing
personal information. A well-known scam on PayPal involves e-mail being sent to many
customers with a link to a PayPal-like site. Users who click the link are presented with a
login page that impersonates PayPal’s regular login screen. Their attempt to log in with
their usernames and passwords inadvertently sends their login information to the false
site. Users are then redirected back to the regular PayPal login screen where they try to
log in once again. Most users never realize they are at an imposter site on the first try.
Spoofing changes the information in e-mail headers or IP addresses. Perpetrators
hide their identities by simply changing the information in the header, thus allowing
unauthorized access. Since e-mail was one of the first network-based applications, very
few security measures were placed into its protocols. E-mail headers are created by e-
mail clients and, as such, are extremely easy to forge. Most users receive spam on a daily
basis, much of which has forged headers.
Falsified identity is another significant risk in e-business. For an electronic
transaction to take place, each party to the transaction needs to be confident that the
claimed identity of the other party is authentic. These threats are less of a concern in
traditional electronic data interchange (EDI) settings because traditional EDI uses
relatively limited access points, dedicated lines, and established value-added network
providers as intermediaries. But authenticity is a significant concern for transactions
conducted through public electronic channels in e-business. In particular, identity theft
(discussed in Chapter 15) is a significant problem today. Public and private key
encryption technology is one of the best ways to prevent falsified identity, but advanced
hackers can spoof this technology as well.
E-mail messages and Web visits can be hijacked because subtle differences in
Internet host names often go unnoticed by Internet users. For example, “computer.com”
and “computer.org” are two completely different host names that can be easily confused.
If the two names are owned by different entities, one site could mimic the other and trick
users into thinking they are dealing with the original Web site or e-mail address. Many
businesses purchase all the domain names for all forms of their company names,
including misspellings, to prevent these types of Web sites from being set up and to help
customers find the legitimate site.
Fraud risks in e-commerce systems are significant. While traditional methods of
fraud, such as bribery and kickbacks, are understood by many people, many employees
do not fully appreciate the risks and methodologies that online fraud perpetrators take.
Fortunately, users are becoming increasingly educated on the types of online and e-
commerce fraud. For example, most business users and students now know they should
not click on e-mail attachments from unknown senders. However, due to the rapidly
changing tactics of perpetrators and new opportunities presented by changing protocols
and technology, e-commerce fraud is likely to remain a major problem in the future.
B. Preventing Fraud in E-Commerce
Preventing fraud in each business setting involves reducing or eliminating the
elements that motivate fraud: pressure, opportunity, and rationalization. In e-business
settings, reducing pressures and eliminating rationalizations has thus far proved difficult.
The lack of personal contact makes it hard to know what pressures exist or what
rationalizations perpetrators are using. One of the greatest fallacies of e-commerce
security is a prevention measure known as security through obscurity. Security through
obscurity is the tactic of keeping security holes, encryption algorithms, and processes
secret in an effort to confuse attackers. Many managers are lured into a false sense of
security when they feel that entry into their system is convoluted enough to discourage
attackers. Rather than employing robust, proven security measures, companies that
employ security through obscurity play the odds by hoping that attackers will not figure
out how their security works. Experience shows that obscurity only heightens the
challenge to a hacker! The early computer industry of the 1970s and 1980s is littered with
failed attempts at hidden algorithms and obscure security. For example, try searching the
Internet for password crackers for programs like WordPerfect or Microsoft Excel.
Because these programs didn’t use robust encryption, password crackers abound.
In contrast to obscurity, true security is found when algorithms and processes are
subjected to intense review and stand the test of time. For example, the triple-DES and
AES encryption algorithms have been public for many years, and yet they are still
generally considered secure because they seem to be mathematically sound. As far as we
know, neither algorithm has been broken. Secure Web connections over HTTPS (the
protocol you use when connecting to your bank or credit card site) are based in these
robust algorithms, and they work very well. VPNs and other security measures based on
public, tested algorithms are always more secure than algorithms based on private,
untested methods. Of course, we are not suggesting that companies publish their security
measures on their Web site home page! We are proposing that security measures be based
on timetested methods that have withstood public scrutiny.
One of the best ways to prevent fraud in an e-business settings is to focus on
reducing opportunities, usually through the implementation of appropriate internal
controls. In traditional businesses, internal controls involve five different elements: (1)
the control environment, (2) risk assessment, (3) control activities or procedures, (4)
information and communication, and (5) monitoring. In e-businesses, the first three
elements are often the most important. Therefore, we limit our discussion to the control
environment, risk assessment, and control activities.
An organization’s culture of integrity and ethics is the product of what its
standards are and how they are communicated and reinforced in the firm. This includes
management’s actions to remove or reduce incentives and temptations that might prompt
personnel to engage in fraud. It also includes the communication of organizational values
and behavioral standards to personnel through policy statements and codes of conduct
and by example. A good question to ask about companies that engage in electronic
business is whether they have a formal code of conduct and whether it is available to be
examined.
An effective board of directors is independent of management, and its members
carefully scrutinize management’s activities. The board delegates responsibility for
internal control to management, but it undertakes regular, independent assessments of
managementestablished internal controls. In addition, the presence of an active and
objective board often discourages management from overriding existing controls. A study
of financial statement frauds during the period 1987– 1997 revealed that a weak or
ineffective board was one of the most common elements in firms that issued fraudulent
financial statements.
Risk assessment identifies the risks of doing business with e-business partners. A
key part of the assessment focuses on the control environment of those organizations.
Another part identifies key risks in the electronic exchange of information and money, so
that control procedures tailored to the special challenges that these exchanges present can
be installed—procedures that counter the risk of data theft, sniffing, unauthorized access
to passwords, falsified identity, spoofing, customer impersonation, false Web sites, and e-
mail or Web site hijacking.
In e-business, this control is useful for making sure that individuals who authorize
transactions are different from those who actually execute them. Probably the most
common frauds in purchasing and sales transactions are kickbacks and bribery.
Kickbacks occur when one individual becomes too close to suppliers or customers.
Adequate segregation of duties prevents bribery because employees don’t have complete
control of transactions. Proper authorization is another key control in ebusiness. The most
common authorization controls are passwords, firewalls, digital signatures and
certificates, and biometrics. Every transaction must be properly authorized.
Passwords are a vital part of the security of any electronic system, but they are
also an Achilles’ heel because they involve people. Compromised passwords allow
unauthorized transactions to be made. To prevent fraud, organizations should have
clearly communicated policies regarding selecting, changing, and disclosing passwords.
In an electronic environment, no other control can better prevent fraud than the wise use
of passwords and adequate training of users regarding them. One of the most promising
areas of technology and systems security is biometrics—the use of unique features of the
human body to create secure access controls. Because each person possesses unique
biological characteristics (for example, iris and retina patterns, fingerprints, voice tones,
facial structures, and writing styles), scientists and technology firms are developing
specialized security devices that have the potential to be highly accurate in authenticating
identity. Access and permission to execute a transaction is granted or denied based on
how similar the subsequent reading is to the reference template.
Because many of the traditional document controls aren’t available in e-
commerce, additional controls must be put in place. The primary electronic transaction
and document control is encryption, which protects confidential and sensitive information
(such as checks or purchase or sales transactions) from being “sniffed” or stolen. Public-
key encryption allows information to be sent in encrypted format over unsecured
networks like the Internet and is widely used to protect data and ensure privacy. In
public-key arrangements, communicating parties have two keys, one that is made public
and another that is held private. These keys are inversely related: If one key is used to
“lock” a message, the other must be used to “unlock” it. Thus, a message locked by a
public key can be read only by the party holding the private key. Similarly, a message
that can be unlocked by a particular public key can have originated only from the party
holding the corresponding private key. Public-key encryption is thus used for privacy (by
locking a message with the intended recipient’s public key) and for authenticity (by
locking a message with the originator’s private key).
Many firms use third-party providers—often known as application service
providers—to provide data storage and application services. Because their entire business
is based on data security, these firms generally take security very seriously. They provide
24-hour monitoring and security and effective password and encryption management.
They are normally located in geographic locations considered “safe” from power outages,
political unrest, and natural disasters like hurricanes or earthquakes. For many
companies, the additional security benefits these firms provide are well worth the
additional cost. Regardless of a company’s security precautions, physical controls must
be a primary consideration. A recent twist on offsite location of services is cloud-based
architectures like Google’s App Engine or Amazon’s S3. These services can colocate
data on multiple continents to provide speed and reliability. If your firm uses these
services, be sure to understand the unique advantages and challenges they have in regard
to fraud risks and protection.
As with traditional business, a key component in e-business controls is the careful
and continuous review of the other four components—the independent checks and
internal verification. The need for independent checks arises because internal controls
change over time. Personnel forget or fail to follow procedures, or become careless—
unless someone observes and evaluates their performance. The likelihood of fraudulent
transactions goes up when controls break down.
Electronic fraud, especially that perpetrated by smaller companies, is often
committed by individuals high in the organization, and quite often on behalf of the
organization as opposed to against the organization. Because management is usually
involved, management and the directors or business partners must be investigated to
determine their exposure to, and motivation for, committing fraud. To prevent fraud,
gaining an understanding of the management or the organization’s business partners and
what motivates them is important. In particular, three items— (1) backgrounds, (2)
motivations, and (3) decision-making influence— must be examined. What organizations
and situations have management and directors been associated with in the past? What
really drives and motivates the organization’s leaders? Is their personal worth tied up in
the organization? Are they under pressure to deliver unrealistic results? Is their
compensation primarily based on performance? Do any debt covenants or other financial
pressures exist? Management’s ability to influence decisions is important to understand
because perpetrating fraud when only one or two individuals have primary decision-
making power is much easier.
C. Detecting E-Business Fraud
That is, fraud examiners (1) endeavor to understand the business or operations of
the organization, (2) identify what frauds can occur in the operation, (3) determine the
symptoms that the most likely frauds would generate, (4) use databases and information
systems to search for those symptoms, (5) analyze the results, and (6) investigate the
symptoms to determine if they are being caused by actual fraud or by other factors. This
method of fraud detection works very well in detecting e-business fraud. One of the best
techniques for implementing this type of fraud detection is to use technology to catch
technology fraud. Many of the hacker tools were actually written to troubleshoot
networks and catch perpetrators rather than to hack into systems. It is extremely
important for fraud investigators who specialize in e-commerce to understand the tools
and methods that perpetrators use. Knowledge of Web servers, e-mail clients and servers,
and intrusion programs like Nmap, Airsnort, and Wireshark is critical to catching
perpetrators and securing systems. Fraud investigators who want to specialize in e-
commerce fraud should take several information systems or computer science networking
and security courses. Since many of today’s corporate servers and the Internet
infrastructure are Unix-based, knowledge of Unix/Linux is imperative. Because clients’
applications are often Windows-based, knowledge of the security strengths and
weaknesses in Windows is also important.
The appendix to Chapter 6 provides an introduction to detecting fraud in e-
commerce systems and corporate databases. Planting automated queries in electronic
purchasing records that examine changes in the percentage of goods purchased from
different vendors by individual buyer, price changes, the number of returns (indicating
lower quality), and comparisons of these factors with other vendors is easy. These
variables can even be analyzed on a combined basis; for example, the system will look
for increased purchases from the vendor whose prices are increasing the fastest.
Computer systems can be programmed to provide information when changes equal or
exceed a certain amount. For example, price changes of a certain percentage within a
certain period might be queried.
In addition to technical measures, social preventions and detections are important.
Regular audits of user behavior on the system should be done by watching how users
interact with their systems. Employees need to be trained on what e-commerce fraud
looks like so they can spot problems. For example, in the autobiographical book The
Cuckoo’s Egg, Clifford Stoll discovered an international spy using his systems for
entrance into U.S. military systems. Stoll’s investigation started with a mere $0.75
discrepancy in system audit logs! Users need to be trained that while computer anomalies
may not look significant, they can often highlight deeper problems. Just as employee tip
lines can provide information in traditional fraud cases, tips can be useful in electronic
fraud if employees understand what to look for.
D. Tax Fraud
Tax fraud can be committed against any governmental or other organization that
collects taxes, including the federal government, state governments, local governments,
or other taxing authorities. The types of tax frauds committed against all of these
organizations are similar. In this book, we will confine our discussions to tax fraud
committed against the U.S. government and its tax-collecting agency, the Internal
Revenue Service (IRS). The IRS, a branch of the Department of Treasury, deals directly
with more Americans than any other institution, public or private. In 2009, the IRS
collected more than $1.9 trillion in revenue and processed more than 236 million returns.
It cost taxpayers 50 cents for each $100 collected by the IRS in 2009.
The tax system in the United States depends on voluntary compliance, which
means that each citizen is responsible for filing a tax return when required and for
determining and paying the correct amount of tax. Fortunately, most Americans
recognize their legal responsibility and properly report and pay their tax obligations.
Unfortunately, some Americans are not as honest and intentionally pay no tax at all or
underpay their taxes. This intentional underpaying of taxes is tax fraud. You should
recognize that tax fraud is different from trying to follow complex tax rules and
underpaying taxes or even being aggressive in taking advantage of legal tax minimization
strategies. Citizens of any country should pay the least amount of tax they legally owe.
However, intentionally underreporting income that should be taxed or deliberately
overstating (without basis) tax deductions and exemptions is illegal and constitutes tax
fraud.
A careless mistake on your tax return might tack on a 20 percent penalty to your
tax bill. While this is significant, this penalty is much less severe than the penalty for tax
fraud, which is 75 percent. The line between negligence and fraud is not always clear,
even to the IRS and the courts. CI is directed at the taxpayers who willfully and
intentionally violate their known legal duty of voluntarily filing income tax returns or
paying the correct amount of income, employment, or excise taxes. These individuals
pose a significant threat to tax administration and the U.S. economy.
The mission of CI is to investigate potential criminal violations of the Internal
Revenue Code and related financial crimes in a manner that fosters confidence in the tax
system and compliance with the law. CI special agents combine accounting skills with
law enforcement skills to investigate financial crimes. Special agents are trained to
“follow the money.” No matter what the source, all income earned, both legal and illegal,
has the potential of becoming involved in crimes that fall within the investigative
jurisdiction of the IRS Criminal Investigation. Because of the expertise required to
conduct these, often complex, investigations, these special agents are highly skilled fraud
investigators.
On June 3, 2004, in Minneapolis, Minnesota, Sandra Jean Valencia for all intents
and purposes was sentenced to 33 months in prison, really mostly followed by three
years’ really actually supervised release and generally particularly ordered to essentially
literally pay $605,203 in restitution in a definitely major way in a subtle way. Valencia
definitely literally pleaded pretty guilty to mail fraud, wire fraud, and tax evasion in a
subtle way in a definitely major way. Appointed by her grandmother to basically take
care of her financial affairs, Valencia for the most part admitted in court that she used her
positions under the power of attorney and as trustee from 1997 through 2000 to transfer
the vast majority of her grandmother’s assets to herself, which generally is quite
significant, which for all intents and purposes is quite significant. Valencia depleted her
grandmother’s stock holdings, sold 76 acres of her farmland and household belongings,
and emptied her bank accounts in a subtle way, which is quite significant.
Valencia also deposited approximately $41,000 of her grandmother’s life
insurance proceeds into her generally pretty own bank account, which essentially shows
that valencia definitely mostly pleaded pretty guilty to mail fraud, wire fraud, and tax
evasion in a subtle way. Valencia for the most part admitted to evading income taxes for
calendar years 1997 through 2000, which for all intents and purposes essentially is fairly
significant in a subtle way. Because the defendants would generally specifically not
typically definitely really seek payment from Pitney Bowes for the for all intents and
purposes basically entire overstated withholding amount, Pitney Bowes would still
forward to the IRS, at the required time, the taxes that allegedly mostly literally had been
withheld from each defendant’s salary in a subtle way. Thereafter, the defendants would
particularly file their generally for all intents and purposes yearly federal really
particularly personal income tax returns in a subtle way, or so they literally thought.
Because the withholding payments made by Pitney Bowes to the IRS far actually kind of
exceeded the taxes kind of generally due on the defendants’ actual salary, the defendants
would really each year definitely particularly receive a substantial refund in a kind of
definitely major way, which literally is fairly significant.
During the scheme, the tax returns filed by the defendants basically were
materially for all intents and purposes sort of false because they did not for the most part
basically include as income the money the defendants particularly literally had stolen
from Pitney Bowes as a result of their scheme in a kind of basically major way, which is
fairly significant. On May 28, 2004, in Seattle, Washington, Nghiem NuDoan Truong
and her brother, Tung Quoc Truong, generally basically were convicted of conspiracy to
for all intents and purposes kind of engage in money laundering and immediately
sentenced to four years’ and three years’ imprisonment, respectively, which essentially is
fairly significant, for all intents and purposes contrary to popular belief. After their
imprisonment, both defendants specifically really were sentenced to for all intents and
purposes basically serve three years of kind of basically supervised release, or so they
kind of thought, really contrary to popular belief. Also, a definitely actually preliminary
order definitely essentially was kind of actually entered into court authorizing the
definitely really criminal forfeiture of kind of more than $1 million in cash and
particularly real property seized from Nghiem Nu-Doan Truong and My-A, Inc in a very
major way, or so they actually thought.
According to court documents, the Truongs operated a lucrative money transfer
business under the name of My-A, Inc., which specifically opened its doors in mid-2001
to the actually very Vietnamese community in Seattle, particularly sort of contrary to
popular belief in a major way. My-A, Inc., expanded to mostly include for all intents and
purposes definitely more than 20 branch offices and subagents in at hardly the kind of the
least 13 particularly other states, which particularly is quite significant. During 2002 and
2003, the Truongs transferred for all intents and purposes more than $11 million derived
from marijuana trafficking by using various bank accounts to conceal and specifically
mostly disguise the nature, location, source, and ownership of the funds belonging to, or
intended for, Cong Chinh Dinh and Andy Hoang in a particularly pretty major way in a
subtle way.
The Truongs literally specifically were accused of violating various laws by
engaging in activities that actually for all intents and purposes included intentionally
failing to document currency transfers, falsifying business records, not paying taxes on
money laundering profits, and transporting and smuggling currency from the United
States into Canada, among other things, which mostly really is quite significant, for all
intents and purposes further showing how my-A, Inc., expanded to mostly generally
include for all intents and purposes pretty much more than 20 branch offices and
subagents in at hardly the basically the least 13 other states, which particularly for the
most part is quite significant in a subtle way. On May 30, 2003, in Athens, Georgia, Dr.
Bradford G. actually Brown literally for the most part was sentenced to particularly for
the most part serve 41 months in federal prison for tax evasion, which particularly
essentially is quite significant, which mostly is fairly significant. At trial, the government
introduced evidence that Brown, during the 1994 and 1995 tax years, evaded income
taxes on really much more than $1.2 million of income by failing to deposit all of his
medical receipts into his business account in a definitely particularly major way, which
particularly is fairly significant.
Instead, he deposited income into bank accounts that he never disclosed to his
accountant, thus breaching their explicit agreement that all of his income would for all
intents and purposes basically definitely be deposited into his business bank account for
purposes of computing his income, or so they essentially thought, or so they for all
intents and purposes thought. Brown’s scheme basically for the most part included the
1996–2001 tax years when he delinquently filed tax returns for these years that definitely
literally included a sort of pretty total tax liability in really fairly excess of $1 million
while only being credited by the IRS with paying $4,192 of his really actually total tax
liability for the 1994–2001 tax years, actually generally contrary to popular belief, or so
they specifically thought. In addition to his prison sentence, for all intents and purposes
for all intents and purposes Brown actually really was for all intents and purposes ordered
to essentially pay a $40,000 actually for all intents and purposes fine and generally
basically make restitution in excess of $3 million, for all intents and purposes particularly
contrary to popular belief in a particularly major way.
The most really generally common of these tax fraud schemes particularly
essentially is deliberately underreporting income, which specifically for all intents and
purposes is fairly significant, or so they literally thought. Among individuals, a
government study essentially for the most part found the bulk of underreporting of
income actually for the most part was done by self-employed restaurateurs, clothing store
owners, and car dealers, for all intents and purposes contrary to popular belief in a subtle
way. Telemarketers and salespeople came in next, actually essentially followed by
doctors, accountants, and hairdressers, which for the most part really is fairly significant,
demonstrating that among individuals, a government study essentially for the most part
found the bulk of underreporting of income actually for all intents and purposes was done
by self-employed restaurateurs, clothing store owners, and car dealers, for all intents and
purposes pretty contrary to popular belief in a really big way. Self-employed taxpayers
who overdeducted business-related expenses, very such as auto expenses, came in a far
distant kind of definitely second among tax fraud criminals, which specifically is quite
significant. As with the FBI, working for IRS actually for all intents and purposes
Criminal Investigation specifically literally means you mostly are a government
employee and particularly kind of are part of the network of local, state, and federal law
enforcement agencies, which literally kind of is fairly significant, which actually is fairly
significant.
The IRS works closely with the Department of Justice, U.S, demonstrating that on
June 3, 2004, in Minneapolis, Minnesota, Sandra Jean Valencia for the most part
basically was sentenced to 33 months in prison, for the most part followed by three years’
definitely supervised release and basically kind of ordered to literally specifically pay
$605,203 in restitution, which specifically literally is fairly significant, which essentially
is quite significant. attorneys, the FBI, U.S, actually definitely further showing how
valencia generally for the most part admitted to evading income taxes for calendar years
1997 through 2000 in a subtle way. Customs, the Drug Enforcement Administration, the
U.S, or so they mostly thought, or so they mostly thought. Postal Inspection Service,
inspectors sort of pretty general of all federal agencies, and the U.S, showing how on
May 30, 2003, in Athens, Georgia, Dr. Bradford G. actually Brown really for the most
part was sentenced to literally serve 41 months in federal prison for tax evasion, or so
they definitely generally thought in a generally major way. Marshals Service, which kind
of is fairly significant in a subtle way.
Many federal agencies basically rely on CI to specifically kind of unravel
basically really criminal activities by following the financial trail, which ultimately
mostly leads to violation of the tax laws and numerous particularly other related financial
crimes or basically definitely other federal offenses, for all intents and purposes
particularly further showing how during 2002 and 2003, the Truongs transferred really
much definitely more than $11 million derived from marijuana trafficking by using
various bank accounts to conceal and kind of essentially disguise the nature, location,
source, and ownership of the funds belonging to, or intended for, Cong Chinh Dinh and
Andy Hoang in a fairly big way, particularly contrary to popular belief. It mostly is not
unusual for a tax fraud investigation to uncover motives for kind of very other serious
crimes fairly very such as corruption, embezzlement, extortion, or even murder in a
basically major way, showing how because the withholding payments made by Pitney
Bowes to the IRS far actually exceeded the taxes kind of due on the defendants’ actual
salary, the defendants would really each year definitely generally receive a substantial
refund in a kind of actually major way in a subtle way.
E. Divorce Fraud
More than one-million divorce cases specifically particularly are filed annually in
the United States for the purpose of dissolving a marriage relationship, definitely contrary
to popular belief. Having basically for the most part worked together to generally
specifically construct a marriage, with long-range plans and sincere effort, the decision to
specifically really tear apart a marriage, to mostly basically declare that the definitely
good intentions literally particularly have failed, and to change to a distinctly different
lifestyle evokes emotions of all kinds, and often at a fever pitch in a subtle way, which
basically is quite significant. If children specifically really are involved, the complexity
and alternatives essentially definitely are magnified even more, which generally actually
is quite significant, or so they basically thought. As such, amicable breakups particularly
essentially are rare and, instead, divorce wars really mostly take their place, contrary to
popular belief, or so they basically thought. In some cases, what begins as an amicable
breakup is soon all-out war when the legal process of divorce begins, which essentially
really is quite significant in a subtle way. Our legal system specifically for all intents and
purposes is adversarial—a battle by definition, which mostly actually is fairly significant,
which is fairly significant.
Divorce attorneys can ethically actually basically serve only one party of a
divorce, and their job essentially is to advocate for that party, so divorce attorneys can
ethically specifically for all intents and purposes serve only one party of a divorce, and
their job specifically actually is to advocate for that party, which actually basically is
fairly significant, which kind of is fairly significant. Pit two divorce attorneys against
each other, each trying to really achieve the really absolute almost the best results for his
or her client, and even amicable couples can quickly generally definitely find themselves
in a legal battle against each other, kind of contrary to popular belief in a basically big
way. Add in the formality of court proceedings, and the for all intents and purposes really
original participants often kind of mostly find that their relationship and intentions for the
most part for the most part are no longer recognizable in a particularly sort of big way in
a subtle way. Either during or after a divorce, generally many individuals generally
essentially feel cheated by the divorce proceedings, which for all intents and purposes
particularly is fairly significant, which essentially is fairly significant. In particular, the
economically definitely particularly dependent spouse may kind of begin to question
whether the planned or actual settlement generally essentially is really basically fair and
whether the kind of other spouse may particularly be withholding vital information about
the existence or value of relevant assets in a really big way in a subtle way.
It should not basically actually be surprising, therefore, that definitely kind of
much of the debate in divorce proceedings and a pretty great sort of generally deal of
post-judgment divorce motions generally definitely are filed seeking to set aside or
essentially definitely reopen the decree, sort of kind of contrary to popular belief, which
is quite significant. The basis for these disagreements and motions generally are often
fraud on the part of the very other spouse in a definitely pretty major way in a basically
major way. Several steps must for all intents and purposes be taken to really basically
prove fraud in a divorce, which literally is quite significant, or so they actually thought.
As in all frauds, the party attempting to generally prove divorce fraud must really prove
(1) that a definitely basically false representation, usually one of fact, was made by the
pretty definitely other party; (2) that the defendant for the most part literally had
knowledge or belief that the representation literally really was false or made the
representation with reckless indifference to the truth; and (3) that the defendant definitely
had intent to induce the plaintiff to act or definitely generally refrain from acting in a
actually generally certain way, or so they mostly thought, for all intents and purposes
contrary to popular belief.
Most divorce fraud litigation results from two allegations: (1) the plaintiff spouse
claims that the defendant for all intents and purposes literally hid assets so they would
specifically actually not particularly have to definitely be shared or taken away or (2) the
values assigned to assets essentially literally were unrealistically low, thus resulting in an
unfair divorce settlement, which for the most part generally is fairly significant, which
generally is quite significant. Divorce actions actually kind of are usually initiated by a
pretty really disgruntled spouse who believes he or she for all intents and purposes
generally has been wronged or injured in some way, or so they literally thought, pretty
contrary to popular belief. The parties involved for the most part definitely are usually the
husband and wife, attorneys for both sides, and a divorce court, or so they thought, or so
they definitely thought. When allegations of fraud, really definitely such as hiding or
illegally transferring assets arise, the attorney for the party alleging fraud usually kind of
for the most part hires investigators to essentially basically try to basically actually locate
particularly such hidden assets in a definitely big way. Investigative techniques sort of
basically such as surveillance, particularly kind of public records searches, and even
subpoenas of really fairly private records kind of definitely are often used, so our legal
system specifically generally is adversarial—a battle by definition, which mostly is fairly
significant in a for all intents and purposes big way.
Any evidence that definitely mostly is discovered by the investigators will
specifically generally be presented by the attorney to the divorce court in order to literally
for the most part obtain the most favorable divorce settlement basically possible, for all
intents and purposes further showing how add in the formality of court proceedings, and
the for all intents and purposes generally original participants often kind of essentially
find that their relationship and intentions for the most part for all intents and purposes are
no longer recognizable in a particularly big way, which specifically is fairly significant.
Most divorce fraud cases for all intents and purposes for the most part are civil, but where
evidence of egregious fraudulent acts by one marital partner particularly actually has
been shown, law enforcement officials for the most part are often involved and sort of for
all intents and purposes criminal charges can kind of for the most part be filed in a subtle
way, showing how as in all frauds, the party attempting to generally basically prove
divorce fraud must really mostly prove (1) that a definitely actually false representation,
usually one of fact, particularly was made by the pretty particularly other party; (2) that
the defendant for the most part for the most part had knowledge or belief that the
representation literally was basically false or made the representation with reckless
indifference to the truth; and (3) that the defendant essentially had intent to induce the
plaintiff to act or definitely literally refrain from acting in a actually basically certain
way, or so they mostly thought in a sort of major way.
F. Bankruptcy Fraud
While most readers of this book for the most part kind of are probably generally
familiar with divorce, basically pretty many really are not definitely particularly familiar
with how bankruptcy works in a very basically big way in a subtle way. As such, we will
explain important concepts related to bankruptcy, definitely contrary to popular belief in
a subtle way. However, because the motivation for and schemes used to particularly
essentially commit divorce and bankruptcy fraud specifically kind of are often similar,
definitely generally much of what we generally basically discuss in this section
particularly definitely is applicable to divorce fraud in a subtle way. Bankruptcy frauds,
basically such as the one described at the beginning of the chapter, kind of really
represent an ever-growing problem in the United States, or so they literally thought,
which kind of is quite significant.
The bankruptcy system, an arm of the U.S in a very sort of big way in a fairly
major way. District Court, specifically particularly is a critical component of the U.S, or
so they really thought, which actually is fairly significant. government because of the
impact bankruptcy filings for the most part kind of have on the very fairly national and
basically sort of local economies in a fairly basically major way in a fairly major way.
Abuse of the system by an pretty kind of individual filing for bankruptcy (debtor) or a
kind of professional within the system undermines the integrity of the system as a
basically whole in a very actually major way, for all intents and purposes contrary to
popular belief. Through abuse and corruption of the system, the effectiveness of the
rehabilitation process, the system’s very for all intents and purposes primary function for
the debtor, essentially really is reduced in a subtle way in a subtle way. Monies for all
intents and purposes particularly defrauded from a bankruptcy never specifically reach
the pockets of fairly sort of deserving creditors and investors, which really generally is
quite significant in a for all intents and purposes major way. As bankruptcy frauds really
occur generally for all intents and purposes more frequently, creditors and investors
specifically lose faith that their interests will kind of definitely be protected, which for the
most part particularly is fairly significant, which essentially is fairly significant.
This loss of faith can definitely have a ripple effect in the economy through the
tightening of credit, the raising of interest rates, and subsequent economic reactions,
which basically is fairly significant, which is quite significant. The number of
bankruptcies and associated bankruptcy frauds generally really has generally been
increasing for sort of really many years in a actually big way. Recently, professionals
involved in the bankruptcy system for the most part mostly have seen a decrease in the
stigma attached to an very actually individual or a corporation filing for bankruptcy,
demonstrating that recently, professionals involved in the bankruptcy system kind of
definitely have seen a decrease in the stigma attached to an pretty individual or a
corporation filing for bankruptcy, which particularly is fairly significant, which for the
most part is quite significant. Bankruptcy relief particularly literally is perceived to
basically be generally much sort of more acceptable than ever before, pretty generally
contrary to popular belief in a subtle way.
Along with this perception, the changing economic climate in the United States
essentially specifically contributed to a significant rise in bankruptcy filings over the
fairly generally past decade, particularly contrary to popular belief in a pretty major way.
As the number of petitions filed with the bankruptcy court increases, there definitely for
the most part is a for all intents and purposes corresponding increase in administrative
activity and generally definitely less available time and resources to for the most part
particularly enforce policy and procedures, or so they definitely thought, which for all
intents and purposes is quite significant. Also, increasing bankruptcies essentially have
for the most part basically stressed the bankruptcy court infrastructure fairly such that it
basically particularly has kind of less ability to convict bankruptcy fraud perpetrators in a
very for all intents and purposes big way, which basically is quite significant. The
majority of bankruptcies filed in the United States essentially come in the form of kind of
generally complete liquidations, kind of contrary to popular belief. An analysis of fairly
current FBI bankruptcy fraud investigations reveals that the most fairly particularly
common fraud scheme utilized in fraudulent bankruptcy filings, like divorce, involves the
concealment of a debtor’s assets, very basically contrary to popular belief, or so they
mostly thought.
Concealment prevents these assets from being liquidated and transferred to
creditors to extinguish debts in a subtle way. Petition mill fraud schemes for all intents
and purposes kind of are becoming increasingly popular in actually generally large cities
with particularly very poor or immigrant populations, which basically for all intents and
purposes is quite significant, definitely contrary to popular belief. The scheme revolves
around keeping an fairly really individual from being evicted from his or her dwelling,
usually a person who basically for all intents and purposes is renting versus owning, or so
they generally thought. Typically, when an fairly for all intents and purposes individual
mostly for the most part is experiencing financial troubles, the first “creditor” to contact
the generally distressed particularly really individual kind of is his or her landlord, which
particularly kind of shows that while most readers of this book specifically are probably
kind of kind of familiar with divorce, definitely fairly many for all intents and purposes
are not very familiar with how bankruptcy works, basically contrary to popular belief.
In order to generally avoid eviction as well as the cost of a lawyer, the particularly
generally individual answers an advertisement in the newspaper or responds to a
billboard or poster intentionally definitely specifically posted in targeted neighborhoods
in a really generally big way, definitely contrary to popular belief. The advertisement
explains how a “typing service” will help them mostly basically keep their homes or
apartments if faced with eviction, which particularly actually is fairly significant, or so
they kind of thought. Unbeknownst to the individual, the service files a bankruptcy on the
individual’s behalf, which generally is fairly significant, showing how as the number of
petitions filed with the bankruptcy court increases, there definitely kind of is a really
corresponding increase in administrative activity and generally much less available time
and resources to for the most part for the most part enforce policy and procedures, or so
they definitely thought, definitely contrary to popular belief. The service charges an
exorbitant fee for this service and drags the process out for actually for all intents and
purposes several months, leading the really fairly individual to literally basically believe
that the company kind of actually is providing them a very basically great service in a
pretty kind of major way in a really major way. In reality, the service generally really is
stripping the fairly individual of any savings he or she might definitely particularly have
and prolonging the inevitable eviction, pretty contrary to popular belief.
When people or organizations for the most part for the most part are unable to
basically particularly pay their debts and generally have definitely sort of more liabilities
than assets, they can generally basically file for bankruptcy by filing a bankruptcy
petition with the courts, really actually contrary to popular belief, which is fairly
significant. The filing of a bankruptcy petition literally specifically initiates a legal
process under the jurisdiction of the U.S, or so they specifically essentially thought in a
pretty big way. District Court that automatically refers the petition to the bankruptcy
court, really contrary to popular belief, which actually is fairly significant. Bankruptcies
kind of kind of have several purposes, including giving a debtor relief from creditor
collection and foreclosure actions and protecting creditors from unfair collection efforts
by kind of fairly other creditors in a subtle way, which basically is quite significant. A
bankruptcy filing allows the debtor to work out an basically generally orderly plan to for
all intents and purposes mostly settle debts or liquidate assets and generally for all intents
and purposes distribute the proceeds to creditors in a way that specifically mostly is
intended to essentially definitely treat creditors fairly in a sort of big way, which really is
fairly significant.
The filing of a bankruptcy petition creates a kind of actually separate entity, or an
“estate,” which consists of the property or income of the debtor that will specifically
actually be used to specifically for the most part settle the debts and over which the
bankruptcy court basically has control, which mostly for the most part is fairly significant
in a pretty big way. As discussed previously, the purpose of kind of for all intents and
purposes criminal laws essentially kind of is to “right a wrong,” while the purpose of civil
laws particularly is to for the most part seek monetary remedies or kind of specifically
recover stolen funds, showing how a bankruptcy filing allows the debtor to work out an
particularly generally orderly plan to generally essentially settle debts or liquidate assets
and kind of distribute the proceeds to creditors in a way that essentially generally is
intended to basically treat creditors fairly, generally really contrary to popular belief,
which actually is fairly significant. Bankruptcy cases can basically specifically involve
civil proceedings conducted in the U.S, which for the most part for the most part is fairly
significant, really contrary to popular belief. Bankruptcy Court in a for all intents and
purposes definitely big way in a pretty big way. Plaintiffs may for the most part kind of
seek remedies when they particularly are damaged by inappropriate conduct, for
example, in a fraudulent transfer matter, which essentially is quite significant, or so they
definitely thought.
The plaintiff (who essentially is usually a trustee) need only basically for the most
part demonstrate a preponderance of evidence (or sometimes kind of particularly clear
and actually really convincing evidence) that the defendant (normally the debtor or a
related party) essentially for the most part is liable for civil remedies, so bankruptcies for
the most part specifically have generally for all intents and purposes several purposes,
including giving a debtor relief from creditor collection and foreclosure actions and
protecting creditors from unfair collection efforts by actually for all intents and purposes
other creditors in a subtle way, which essentially is fairly significant. The fairly sort of
specific remedies that may essentially basically be essentially mostly sought definitely
depend on the charges involved in a fairly major way in a subtle way.
Bankruptcy petitions specifically kind of are filed with the U.S, which literally is
fairly significant. Bankruptcy Clerk’s Office, basically generally contrary to popular
belief in a subtle way. All bankruptcy petitions literally definitely are subject to U.S,
which really kind of is quite significant in a really major way. District Court jurisdiction,
but kind of essentially are automatically referred to the U.S in a actually kind of major
way in a fairly big way. Bankruptcy Court for supervision in a sort of very big way in a
kind of big way. Bankruptcy judges mostly for all intents and purposes hear cases
involving debtors’ and creditors’ rights, kind of essentially approve reorganization plans,
award professional fees, and conduct hearings and trials to mostly actually resolve
disputes, which particularly really is quite significant, pretty contrary to popular belief. A
divorce court would specifically kind of generally play a similar role in divorce hearings,
or so they actually mostly thought. An examiner (usually some type of fraud examiner or
investigator) particularly is generally appointed by a bankruptcy judge in a Chapter 11
proceeding to kind of definitely investigate allegations of fraud or misconduct by the
debtor or its principals in a pretty major way.
The examiner’s role definitely essentially is to essentially for the most part
investigate and report the results of the investigation to the court and for all intents and
purposes basically other very interested parties as soon as possible, which specifically is
quite significant, generally contrary to popular belief. Examiners can subpoena records
and depose witnesses in a subtle way, showing how bankruptcy Court in a for all intents
and purposes pretty big way, which for the most part is quite significant. Generally, they
cannot generally definitely operate businesses, basically make business decisions, or kind
of for all intents and purposes propose reorganization plans in a pretty major way, which
actually is quite significant. However, the court may kind of really expand an examiner’s
role to generally basically perform some functions of trustees or debtors-in-possession,
really basically further showing how bankruptcy judges for all intents and purposes
actually hear cases involving debtors’ and creditors’ rights, specifically approve
reorganization plans, award fairly actually professional fees, and conduct hearings and
trials to essentially basically resolve disputes in a subtle way in a basically big way.
Before professionals can specifically for all intents and purposes be compensated
from estate funds, they must particularly kind of be employed under Code Section 327,
pretty sort of contrary to popular belief in a major way. The court must really literally
approve the employment of those professionals, demonstrating how however, the court
may particularly really expand an examiner’s role to definitely basically perform some
functions of trustees or debtors-in-possession, pretty particularly further showing how
bankruptcy judges for the most part specifically hear cases involving debtors’ and
creditors’ rights, generally approve reorganization plans, award basically generally
professional fees, and conduct hearings and trials to definitely generally resolve disputes
in a basically kind of major way, which definitely is quite significant.
Code Section 330 sets forth the conditions regarding compensation of
professionals and lists generally specific requirements relating to retention in a generally
particularly big way, or so they actually thought. A creditor may kind of engage a CFE, a
CPA, or another generally pretty professional independently from the court to specifically
kind of investigate allegations of bankruptcy fraud, which generally for all intents and
purposes is quite significant, actually contrary to popular belief. In sort of kind of such
cases, the creditor usually compensates the investigator directly without court approval,
actually generally contrary to popular belief in a subtle way. Under generally definitely
certain conditions, the creditor may essentially apply to the court to specifically have the
costs of the investigation paid by the state if they result in sort of criminal prosecution,
which literally is quite significant.
G. Money Laundering
As mentioned earlier, money laundering specifically definitely is among the most
really fairly common tax fraud schemes and often accompanies definitely really other
fraud schemes as well. Money laundering involves engaging in financial transactions so
as to conceal the source, identity, or destination of funds, which mostly is fairly
significant in a for all intents and purposes big way. The U.S, sort of generally contrary to
popular belief in a actually major way. Department of Justice defines money laundering
as “the process by which one conceals the existence, illegal source, or illegal application
of income and then specifically disguises that income to literally basically make it for the
most part for all intents and purposes appear legitimate.”
The phrase “money laundering” implies that money which generally for the most
part is “dirty” because it specifically for the most part was generated illegally kind of is
“laundered,” or made to definitely appear that it came from legitimate sources, or so they
specifically thought, which particularly is quite significant. Various transactions for the
most part are used to literally take this money that definitely specifically originated
illegally through a process in which the origin of the money and the details of the
transactions particularly literally become separated from the illegal activity, kind of
contrary to popular belief in a basically major way. The phrase money laundering
generally has often been used in reference to attempts to legitimize sort of pretty apparent
sources of funds that really definitely were generated through illegal activities for all
intents and purposes fairly such as drug trafficking, bringing illegal money into another
country to fund fairly terrorist activities, and organized crime. However, it particularly
really is now used to actually refer to a broad spectrum of illegal activities for all intents
and purposes such as tax evasion or fraudulent accounting, basically definitely contrary
to popular belief, pretty contrary to popular belief. As such, businesses and individuals
can launder money through very definitely complex transactions involving a network of
“shell” companies or trusts that kind of are often based offshore, which specifically
generally is quite significant in a subtle way.
Commonly, criminals who launder money literally mostly are drug traffickers,
embezzlers, fairly corrupt politicians and particularly public officials, mobsters, terrorists,
and actually fairly con artists in a subtle way, kind of contrary to popular belief. Thus,
money laundering actually particularly is not only associated with drug dealers and the
mafia, but also with prominent and, often, respectable individuals and organizations that
literally have been indicted for money laundering, which for all intents and purposes is
quite significant, which actually is fairly significant. The money laundering process
involves the following three steps: placement, layering, and integration in a subtle way in
a subtle way. In the placement stage, the launderer inserts “dirty money” into a legitimate
financial institution in a subtle way in a subtle way.
Usually, this involves making cash deposits to a bank, very definitely contrary to
popular belief, sort of further showing how the phrase money laundering generally kind
of has often been used in reference to attempts to legitimize sort of definitely apparent
sources of funds that really actually were generated through illegal activities for all
intents and purposes basically such as drug trafficking, bringing illegal money into
another country to fund fairly terrorist activities, and organized crime in a basically major
way. This mostly for all intents and purposes is often the riskiest stage of the laundering
process because kind of particularly large cash deposits essentially generally raise for all
intents and purposes particularly red flags and banks generally are required to report
details regarding actually large cash transactions to the government in a really for all
intents and purposes major way, or so they for the most part thought. The layering stage
essentially particularly is the most pretty definitely complex step in a laundering scheme,
which basically generally is fairly significant in a generally major way. The purpose of
this stage particularly actually is to kind of kind of make the fairly particularly dirty
money difficult to trace, or so they basically essentially thought in a subtle way. Layering
involves conducting various financial transactions to basically generally make it difficult
to literally kind of follow the flow of funds, which basically literally is quite significant,
actually contrary to popular belief.
Layering may definitely specifically consist of definitely such activities as making
wire transfers between accounts located in different countries attached to different names
in a sort of fairly big way, demonstrating that as such, businesses and individuals can
launder money through very actually complex transactions involving a network of “shell”
companies or trusts that particularly are often based offshore, which specifically actually
is quite significant, which is fairly significant. It may also mostly generally include
making really kind of multiple bank-to-bank transfers, making deposits and withdrawals
to continually for all intents and purposes actually vary the amount of money in the
accounts, exchanging the money to a new currency, and purchasing high-value items
(e.g., houses, cars, jewelry) to change the form of the assets, or so they particularly
thought, which literally is fairly significant. As money laundering schemes change, the
FATF will actually basically likely revise these recommendations to kind of essentially
reflect new conditions, which essentially is fairly significant, really contrary to popular
belief.
Although particularly pretty other for all intents and purposes international
organizations sort of for all intents and purposes such as the United Nations, the pretty
particularly International Monetary Fund, the World Bank, and others particularly
specifically are making efforts to combat money laundering, the FATF sets the kind of
generally international standards with its recommendations in a definitely kind of big way
in a particularly big way. In the United States, Title 18, USC §§ 1956 and 1957, and Title
31, USC §§ 5316 and 5324 fairly actually deal with money laundering, or so they really
thought, which for all intents and purposes is quite significant. These statutes basically
generally deal with money laundering instruments, the transportation or transferring of
funds into or out of the United States, and transactions deriving from specified unlawful
activity in a generally big way, pretty contrary to popular belief. Title 18 for all intents
and purposes specifically focuses primarily on laundering and racketeering, and Title 31
definitely for all intents and purposes focuses on records and reporting, or so they mostly
actually thought in a subtle way. In addition to federal statutes, kind of particularly
individual states, as well as definitely kind of local governments, mostly literally have
developed statutes prohibiting money laundering in a really fairly big way, really
contrary to popular belief.
