Kevin Brandes, 60, and William Graham, 56, of Kansas City, Missouri, pleaded guilty to conspiring with bankers to evade mandatory anti-money laundering (AML) controls at a Missouri bank, violating the Bank Secrecy Act (BSA). From 2013 to 2019, Brandes and Graham, who owned multiple sweepstakes businesses, assisted bank officials in circumventing AML protocols. The BSA mandates that banks file currency transaction reports (CTRs) with the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) for transactions over $10,000. At the bank’s request in 2017, the duo signed FinCEN CTR Exemption Review Forms misclassifying their businesses, leading the bank to forgo filing CTRs and reducing scrutiny on their transactions. They also had an attorney sign a false legal opinion letter to mislead the bank about the legal standing of one of their companies. Brandes and Graham each pleaded guilty to one count of conspiracy to cause the willful failure to implement and maintain an appropriate AML program, facing a maximum penalty of five years in prison. The case is being investigated by the FDIC-OIG, IRS-CI, and the FBI. Trial Attorneys Chad M. Davis and Christopher Ting of the Criminal Division’s Money Laundering and Asset Recovery Section (MLARS), along with Assistant U.S. Attorneys Patrick D. Daly and Matthew N. Sparks, are prosecuting. The announcement was made by officials from the Justice Department’s Criminal Division, the U.S. Attorney’s Office for the Western District of Missouri, and regional leaders from the FDIC-OIG, IRS-CI, and FBI.
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