The woods are full of Bernie Madoff wannabees. One of these is Tim Roth of Champaign, Illinois. Roth was a financial advisor who basically just put client funds into his own accounts.
There were suspicions. How did Roth deal with these suspicions?
In 2003, TD Ameritrade raised concerns with Comprehensive Capital Management — which employed Roth as an investment adviser — that Roth had transferred client funds into accounts he owned.
To help satisfy the concerns of CCM's compliance officer, Roth transferred his ownership of Keyop Exercises in August of that year to a friend and partner in another business.
That arrangement was made with the understanding that the friend would be merely a nominee-owner acting at Roth's direction and control, with Roth continuing to make the decisions.
According to the plea agreement, Roth bought a stamp with the friend's signature so Roth could operate the business without involving the friend.
In 2007, the friend — who was identified in the plea agreement only as "RM" — asked to be removed as owner of Keyop.
Roth subsequently named another person — identified only as "GR" — to be president and owner of Keyop.
Even so, the plea agreement said, Roth maintained full control over Keyop and its accounts.
See what I mean by banality? Forget sophisticated techniques for cybercrime. Roth used a rubber stamp to evade the TD Ameritrade and CCM compliance process for years.