Two Missouri residents, Kevin Brandes, aged 60, and William Graham, aged 56, pleaded guilty on June 30 to charges related to their involvement in a conspiracy with bank officials to evade mandatory anti-money laundering (AML) controls at a Missouri bank. Both men, based in Kansas City, Missouri, were owners and operators of multiple sweepstakes businesses and maintained accounts at the implicated bank.
According to court documents, from 2013 through 2019, Brandes and Graham collaborated with bank officials to neglect crucial components of the bank’s AML program. This program, mandated by the Bank Secrecy Act (BSA) and its regulations, necessitates the filing of currency transaction reports (CTR) to the Financial Crimes Enforcement Network (FinCEN) for transactions involving over $10,000 in cash.
In 2017, upon request from bank officials, Brandes and Graham signed FinCEN CTR Exemption Review Forms categorizing their businesses as "direct mail advertising" entities. Subsequently, the bank failed to submit CTRs to FinCEN for transactions linked to Brandes' and Graham's enterprises. Despite their businesses being designated as "high risk" under the bank’s policies, the duo understood that signing these exemption forms would result in reduced scrutiny of their transactions.
Additionally, in October 2016, at the direction of two bank officials, Brandes and Graham arranged for an external attorney to provide a letter containing false information to the bank. The letter falsely stated that one of Brandes’ companies had not faced regulatory or legal actions in over three years, despite their knowledge of ongoing legal proceedings against the company by a state regulatory agency. This misinformation aimed to help the bank sidestep its obligations under the BSA.
Brandes and Graham each pleaded guilty to one count of conspiracy to cause the willful failure to establish and maintain an adequate anti-money laundering program. Both face a maximum penalty of five years in prison. Sentencing will occur at a later date, determined by a federal district court judge who will consider U.S. Sentencing Guidelines and other statutory factors.
The announcement of their guilty pleas was made by Principal Deputy Assistant Attorney General Nicole M. Argentieri of the Justice Department’s Criminal Division, U.S. Attorney Teresa A. Moore for the Western District of Missouri, Special Agent in Charge Justin R. Bundy of the Federal Deposit Insurance Corporation Office of Inspector General (FDIC-OIG) Kansas City Region, Special Agent in Charge Thomas F. Murdock of the IRS Criminal Investigation (IRS-CI) St. Louis Field Office, and Assistant Director Michael Nordwall of the FBI’s Criminal Investigative Division.
The investigation into this case is ongoing, led by FDIC-OIG, IRS-CI, and the FBI. Prosecution is handled by Trial Attorneys Chad M. Davis and Christopher Ting from the Criminal Division’s Money Laundering and Asset Recovery Section (MLARS), along with Assistant U.S. Attorneys Patrick D. Daly and Matthew N. Sparks for the Western District of Missouri.
MLARS’ Bank Integrity Unit oversees cases involving banks and financial institutions, targeting actions that jeopardize individual institutions or the broader financial system.
