Recent court documents have revealed that a former Bank of America relationship manager based in Brooklyn, New York, allegedly played a key role in laundering illicit proceeds from a $10.6 billion health care fraud scheme targeting Medicare and Medicaid. This case—part of the DOJ’s sweeping “National Health Care Fraud Takedown”—highlights the critical role that financial professionals may unwittingly play in complex criminal schemes.

The Scheme Unveiled

Named in unsealed court filings, banker Renat Abramov, a dual U.S.–Azerbaijani citizen, is accused of helping facilitate fraud proceeds through accounts opened at Bank of America between 2021 and 2023. He allegedly assisted a transnational criminal organization (TCO) in establishing at least six shell medical-supply companies used to submit false claims.

These entities billed Medicare and Medicaid for unnecessary durable medical equipment—such as catheters and glucose monitors—using stolen patient identities, ultimately generating nearly $941 million in fraudulent payments.

How Funds Were Laundered

1. Account Setup & Structuring

   Abramov allegedly structured accounts for fraudulent entities, omitting true beneficial ownership to mask the TCO’s involvement.

2. Layering Through Shell Companies

   Illicit proceeds were routed through shell accounts in China, Singapore, Pakistan, Israel, and Turkey—and even converted into cryptocurrency to obscure the origin of funds.

3. Use of Encryption & Nominees

   Communications occurred over encrypted apps like Telegram, with foreign nationals serving as nominees for the criminal group.

Red Flags for Financial Professionals

This case illustrates multiple warning signs CFEs and compliance teams should be trained to detect:

• Accounts opened for medical suppliers with vague ownership or insufficient documentation

• Unusual volume or velocity of fund transfers unrelated to business operations

• Cross-border transactions with no clear commercial purpose

• Use of third-party nominees in account documentation

• Communications or instructions sent via encrypted channels

Implications & Tactical Lessons

Focus Area	Key Takeaway
Know Your Customer	Conduct in-depth verification of beneficial ownership, especially for high-risk sectors.
Transaction Monitoring	Watch for structured transactions, abnormal flows, and unexplained international transfers.
Internal Controls	Investigate staff who enable high-risk account openings with minimal due diligence.
Regulatory Coordination	Share suspicious activity reports (SARs) promptly and maintain strong communication with regulators.

Broader Impact

Part of the DOJ’s “Operation Gold Rush,” this case is one of the largest health care fraud takedowns in U.S. history. Over 300 defendants have been charged, with more than $14.6 billion in alleged losses. It demonstrates how organized crime networks exploit the U.S. health care system, bank infrastructure, and cross-border financial access.

Conclusion

For CFEs and fraud professionals, this case reinforces the importance of:

• Thorough KYC and beneficial ownership verification

• Proactive transaction analysis and SAR filings

• Cross-functional cooperation between compliance, legal, and law enforcement teams

Cases like this are a call to action: to stay ahead of sophisticated fraud schemes, we must strengthen systems, monitor patterns diligently, and act quickly when red flags emerge.

To learn more about national enforcement actions and fraud trends, visit www.acfe.com or connect with your ACFE Pacific Northwest Chapter community.

— ACFE Pacific Northwest Chapter