Case Document 1 Filed 07/20/16 Page 1 of 41

UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF 

UNITED STATES OF AMERICA NO. 303

v.  gum: 

RICHARD W. IRELAND,
Defendant.

INDICTMENT

 
Count 1 
HARRISBURG, PA
Conspiracy to Commit Honest Services JUL 2 2016
Mail Fraud and Wire Fraud
(18 U.S.C. 1349) VD
THE GRAND JURY CHARGESZ
1. At times material to this Indictment:

PERSONS AND ENTITIES

2. Defendant RICHARD W. IRELAND was a businessman Who had
financial relationships of various types With multiple business entities. The
business entities included, but Were not limited to, Valley Forge Investment
Corporation, VFIM Corp, Valley Forge Hotel Management Company, LLC,
Onsite Sterilization, LLC, Index Licensing, LLC, S'IndeX, LLC and multiple
asset management companies hereinafter referred to as ?Asset Management
Company ?Asset Management Company and ?Asset Management

Company 

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3. The Department of the Treasury (?Treasury?) was an
independent department of the Commonwealth of 
headquartered in Harrisburg, within the Middle District of 
Treasury was led by the Treasurer, who was elected to serve a four-year term.
Treasury?s paramount responsibility was safeguarding and managing the
state's financial assets. Treasury also had additional responsibilities set
forth in Constitution and statutes.

4. Taxes and other sources of revenue collected by the Commonwealth
were deposited with the Treasury. Treasury was custodian of approximately
$100 billion in public assets. Treasury used that money to make payments on
behalf of state government, including payroll for state employees and charges
incurred by government agencies. While managing cash flow to ensure that
enough money was on hand to meet financial obligations, Treasury also placed
some funds in externally managed short-term and long-term investments to
earn income for state taxpayers. Treasury also held and invested funds for
other government agencies, such as the state pension boards. The Treasurer
of the Commonwealth of by virtue of his position, had the
ability to cause and in?uence the award, continuation and modification of

external asset management contracts. These external asset management

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contracts were sometimes memorialized in asset management agreements
entered into by Treasury with external asset managers. Treasury
determinations to award, continue and modify external asset management
contracts required decisions and actions on questions, matters and
proceedings that involved the formal exercise of government power by public
officials acting in their official capacity. During the Treasurer?s tenure in
office, numerous matters involving the award, continuation and modification
of external asset management contracts could have been brought, and were
pending, before Treasury. The award of an external asset management
contract'by Treasury required the Treasurer and other Treasury officials to
make decisions and take action to accomplish the contract award.

5. A number of the entities with which IRELAND had financial
relationships, including Asset Management Company Asset Management
Company #2 and Asset Management Company sought and obtained asset
management contracts from Treasury, managed hundreds of millions of
dollars in aggregate of Treasury assets, and were paid tens of millions of
dollars in aggregate in fees by Treasury. An entity with which IRELAND had
a financial relationship also sought asset management contracts from SEES.

6. Robert M. McCord (?McCord?) was Treasurer of the
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Commonwealth of He was elected in November, 2008, and
reelected in November, 2012. During political campaigns to be elected
Treasurer, McCord controlled the ?McCord Committee? campaign committee.
In 2014, McCord was an unsuccessful candidate for Governor of 
During the campaign to be elected Governor, McCord controlled the ?McCord
for Governor? campaign committee.

7. The Department of State, Bureau of Commissions,
Elections, and Legislation (?Bureau of Elections?) was headquartered in
Harrisburg, within the Middle District of and was responsible
to promote the integrity of the electoral process. Under law, all
candidates for state elected office and their campaign committees were
required to file Campaign Finance Reports with the Department
of State. Under law, campaign finance reports were required to
accurately report the source of all campaign contributions. It was unlawful in
for any person to make any contribution with funds given by the
person for the purpose by any other person, firm or corporation. Each person
making a contribution was permitted to do so only in the person?s own name.

8. The State Employees? Retirement System managed the

pension benefits of more than 230,000 employees and retirees for more than

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100 public sector employers. SERS was headquartered in Harrisburg, within
the Middle District of and managed more than $20 billion in
assets. SERS was run by an ll'member board. The Treasurer served as an
eX of?cjo member of the SERS board during his term of office. The Treasurer,
by virtue of his position, had the ability to cause and in?uence the award,
continuation and modification of SERS external asset management contracts.
SERS determinations to award, continue and modify asset management
contracts required decisions and actions on questions, matters and
proceedings that involved the formal exercise of government power by public
officials acting in their official capacity. During McCord?s tenure in office,
numerous matters involving the award, continuation and modification of
external asset management contracts could have been brought, and were
pending, before SERS. The award, continuation and modification of external
asset management contracts by SERS required public officials to make official
decisions and to take official action.
THE RIGHT TO HONEST SERVICES

9. As Treasurer, Robert McCord was an elected public official of the

Commonwealth of The Commonwealth of and

its citizens had a right to the honest services of the Treasurer in

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the performance of his duties as Treasurer.

10. As a public official, the Treasurer of the Commonwealth of
owed a fiduciary duty to the Commonwealth and its citizens and
was required to conduct himself in accordance with the Public
Official and Employee Ethics Act. law provided that no person
shall offer or give to a public official or candidate for public office anything of
monetary value, including a political contribution, based on any
understanding that the official action or judgment of the public official or
candidate for public office would be in?uenced thereby.

THE CONSPIRACY AND ITS OBJECTS

1 1. From on or about July 1, 2008, the exact date being unknown to the
Grand Jury, to on or about January 81, 2016, in the Middle District of
and elsewhere, the defendant,

RICHARD W. IRELAND,
did knowingly and willfully combine, conspire, confederate and agree, together
with other persons known and unknown to the Grand Jury, to devise and
intend to devise a material scheme and artifice to defraud and to deprive the
Commonwealth of and the citizens of the Commonwealth of

of the honest and faithful services of the Treasurer of the

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Commonwealth of through bribery and kickbacks and, for the
purpose of executing such scheme and artifice: to cause to be delivered by the
United States Postal Service and by any private and commercial interstate
carrier, matters and things; and, to transmit and cause to be transmitted by
means of wire communications in interstate commerce, certain writings, signs,
signals and sounds, in violation of Title 18, United States Code, 1341, 1343
and 1346.
PURPOSE OF THE CONSPIRACY

12. The purpose of the conspiracy was for the defendant RICHARD W.
IRELAND and his unindicted coconspirators to enrich themselves through
Treasury and SERS asset management contracts obtained
corruptly through the payment of bribes.

MANNER, MEANS AND METHODS

13. The manner, means and methods by which IRELAND and his
coconspirators carried out the conspiracy included, but were not limited to, the
followingi

14. From 2001 through 2007, investment entities with which
IRELAND and his coconspirators had a financial relationship obtained tens of

millions of dollars in fees from asset management contracts with Treasury.

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In 2008, Treasury substantially reduced its investments with those entities.
This reduction resulted in a multi-million dollar decrease in annual fees paid
to the entities and owed to IRELAND and his coconspirators by the entities.

15. Between on or about July 1, 2008, and on or about January 2015,
IRELAND and his unindicted coconspirators agreed to make hundreds of
thousands of dollars in intended bribe payments, in the form of campaign
contributions and other remuneration, to Robert McCOrd.

16. In qujdpro quo exchange for intended bribe payments made in the
form of campaign contributions, IRELAND and his unindicted coconspirators
sought specific requested exercise of official authority, and promise of specific
requested exercise of official authority, by McCord, which specific requested
exercise of official authority included, but was not limited toi (1) use of
McCord?s position as Treasurer to award, continue and modify asset
management contracts of Treasury and SERS with asset management
companies, including Asset Management Company Asset Management
Company #2 and Asset Management Company with which IRELAND and
his coconspirators had a financial relationship; (2) use of McCord?s position as
Treasurer to exert pressure on other public officials to perform official acts,

including but not limited to, the award, continuation and modification of asset

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management contracts by Treasury and SERS to asset management
companies, including Asset Management Company Asset Management
Company #2 and Asset Management Company with which IRELAND and
his coconspirators had a financial relationship; and, (3) use of McCord?s
position as Treasurer to advise other public officials knowing and intending
that such advice would form the basis for the award of asset management
contracts by Treasury and SERS to asset management companies, including
Asset Management Company Asset Management Company #2 and Asset
Management Company with which IRELAND and his coconspirators had a
financial relationship.

17. In qujdpro quo exchange for intended bribes offered in the form of
remuneration other than campaign contributions, IRELAND and his
unindicted coconspirators sought the above-stated specific requested exercise
of official authority, and promise of specific requested exercise of official
authority, and also sought to corruptly in?uence McCord in the performance of
official acts, as opportunities arose.

18. To carry out the scheme, IRELAND and his unindicted
coconspirators used various manners, means and methods to hide, conceal and

cover-up their financial relationship with Robert McCord, including but not

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limited to the following

i. Charity/ Conduit Contributions

19. Among the methods used by IRELAND and his unindicted
coconspirators to funnel intended bribe payments to McCord and to conceal
these payments, IRELAND and his coconspirators secretly recruited persons
to act as conduit contributors to McCord?s Treasury and gubernatorial
campaigns. In exchange for campaign contributions IRELAND directed
those persons to make to McCord?s campaigns, IRELAND made donations,
and directed others to make donations, to each conduit contributor?s charity of
choice. On most occasions when IRELAND directed a person to make a
charitable donation to a conduit contributor?s charity of choice, IRELAND
caused the person making the charitable donation to be paid in advance or
reimbursed for the donation.

20. One of the persons utilized by IRELAND to make conduit campaign
contributions to McCord was an officer and principal donor to a charity
hereinafter referred to as ?Charity The person believed that Charity #1
was in danger of losing its favorable status as a ?public charity? under Internal
Revenue Service regulations since donations from the person accounted for a

high percentage of all donations to Charity To preserve the ?public
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charity? status of Charity the person agreed at the request of IRELAND to
act as a conduit campaign contributor to Robert McCord in exchange for
donations to Charity #1 to be made by IRELAND and others acting at
direction. Per the agreement between IRELAND and the
principal donor to Charity IRELAND caused a larger amount of money to
be donated to Charity #1 than the amount of any campaign contribution
IRELAND directed the person to make to McCord to account for the fact that
the person could claim a tax deduction for a charitable contribution to Charity
#1 but could not claim a tax deduction for a campaign contribution to McCord.
Through this scheme, campaign contributions made by IRELAND and his
coconspirators were concealed and it was made to appear that donations to
Charity #1 by the principal donor to Charity #1 represented a smaller
percentage of the total donations to Charity 

21. For example, as part of the scheme, IRELAND caused persons
hereinafter referred to as ?Family Member ?Family Member ?Family
Member ?Employee and ?Employee to be paid bonuses in October,
2009, which each person then used at the direction of IRELAND to make a
$20,000 donation to Charity 

22. During October, 2009, the following donations were made to

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Charity #1 by IRELAND, family members, employees and a

business associatei

 

Date of Charitable

Amount of Charitable

 

 

 

 

 

 

 

 

Donor Donation Donation
Family Member #1 10/12/2009 $20,000
Family Member #2 10/13/2009 $20,000
Family Member #3 10/13/2009 $20,000
Employee #1 10/13/2009 $20,000
Employee #2 10/13/2009 $20,000
Richard Ireland 10/13/2009 $20,000
Business Associate of 10/14/2009 $203000

Richard Ireland

 

 

 

23. After the aforementioned $140,000 in total charitable donations

were paid to Charity the officer and principal donor to Charity #1 caused a

$100,000 contribution to be made at the direction of IRELAND to a McCord

campaign committee.

24. It was part of the scheme that the intended bribe payments to

McCord made through multiple conduit contributors affiliated with multiple

charities, including Charity #1 and a charity hereinafter referred to as

?Charity resulted in the filing of false campaign finance reports with the

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Bureau of Elections. The use of conduit contributors and the false campaign
finance reports that followed therefrom concealed the fact that IRELAND and
his coconspirators were the true contributors to McCord?s campaigns and
concealed the financial relationship between IRELAND, his coconspirators
and McCord. Through the above-described secret conduit contributions made
in Violation of campaign finance law, IRELAND and his
unindicted coconspirators paid and concealed at least $375,000 in intended
bribes to Robert McCord between October, 2009 and March, 2014.

ii. Employee Conduit Contributions

25. Among the methods used by IRELAND and his unindicted
coconspirators to funnel intended bribe payments to McCord, IRELAND and
his coconspirators recruited and directed multiple employees of entities over
which IRELAND exerted some control to act as conduit campaign contributors
to McCord?s gubernatorial campaign. Included among the employees who
acted as conduit contributors'were Employee #1 and employees hereinafter
referred to as ?Employee and ?Employee In exchange for significant
purported campaign contributions IRELAND directed those persons to make,
and which were in fact made to McCord?s gubernatorial campaign, IRELAND

caused those persons to be reimbursed for their contributions. It was part of

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the scheme that the intended bribe payments to Robert McCord made through
conduit contributors resulted in the filing of false campaign finance reports
with the Bureau of Elections. The use of employee conduit contributors and
the false campaign finance reports that followed therefrom concealed the fact
that IRELAND and his coconspirators were the true contributors to McCord?s
campaigns and concealed the financial relationship between IRELAND, his
coconspirators and McCord. Through these conduit contributions made in
Violation of campaign finance law, IRELAND and his unindicted
coconspirators paid and concealed at least $150,000 in intended bribes to
McCord during December of 2013.

Direct Contributions and Promises of Future Remuneration

26. Among the methods used by IRELAND and his unindicted
coconspirators to funnel intended bribe payments to McCord, IRELAND and
his coconSpirators made such payments to McCord in the form of direct
campaign contributions. In addition, IRELAND and his coconspirators
intended to pay and offered to pay bribes to McCord after McCord left public
office in qujdpro quo exchange for official action requested of McCord while
McCord was still in office. In exchange for official acts performed by McCord

to in?uence the award of asset management contracts while McCord served as

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Treasurer, IRELAND offered to put McCord on ?payroll? after
McCord left office.

27. Through direct campaign contributions, IRELAND and his
unindicted coconspirators paid at least $100,000 in intended bribe payments
to McCord during December of 2014.

28. The allegations contained in each of the remaining counts of this
Indictment are hereby incorporated by reference and made a part hereof as if
set forth at length herein. The acts alleged in each of the remaining counts of
this Indictment were committed in furtherance of the conspiracy alleged in
this Count.

All in Violation of Title 18, United States Code, 1349.

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Counts 2'35
Honest Services Mail Fraud/
Attempted Honest Services Mail Fraud
(18 U.S.C. 1341, 1346 and 1349)
THE GRAND JURY FURTHER CHARGESI

29. The allegations contained in Count 1 and in the remaining Counts
of this Indictment are hereby re~alleged and incorporated by reference as if
fully set forth herein.

30. From on or about July 1, 2008, the exact date being unknown to the
Grand Jury, through on or about January 31, 2016, in the Middle District of
and elsewhere, the defendant,

RICHARD W. IRELAND,
knowingly devised and intended to devise a material scheme and artifice to
defraud and deprive the Commonwealth of and the citizens of
the Commonwealth of of their right to the honest and faithful

services of the Treasurer of through bribery and kickbacks, and

attempted to do so.
USE OF THE MAILS TO EXECUTE THE SCHEME
31. On or about the date of each count listed below, in the Middle

District of and elsewhere, the defendant RICHARD W.
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IRELAND, for the purpose of executing the above-described scheme and
artifice to defraud, and attempting to do so, did deposit and cause to be placed
in a post office and authorized depository for mail matter to be delivered by the

Postal Service the following matters and thingsi

 

Count Date Matter Sent By Mail

 

Invoice from Asset
Management Company #1 to
Treasury,
Harrisburg, 

2 October 17, 2011

 

Invoice from Asset
Management Company #1 to
Treasury,
Harrisburg, 

3 January 12, 2012

 

Invoice from Asset
Management Company #1 to
Treasury,
Harrisburg, 

4 October 10, 2012

 

Invoice from Asset
Management Company #1 to
Treasury,
Harrisburg, 

5 January 11, 2013

 

 

Invoice from Asset
Management Company #1 to
Treasury,
Harrisburg, 

6 April 10, 2013

 

 

 

 

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July 10,2013

Invoice from Asset
Management Company #1 to
Treasury,
Harrisburg, 

 

October 10, 2013

Invoice from Asset
Management Company #1 to
Treasury,
Harrisburg, 

 

January 15, 2014

Invoice from Asset
Management Company #1 to
Treasury,
Harrisburg, 

 

10

April 10, 2014

Invoice from Asset
Management Company #1 to
Treasury,
Harrisburg, 

 

11

July 11,2014

Invoice from Asset
Management Company #1 to
Treasury,
Harrisburg, 

 

12

October 14, 2014

Invoice from Asset
Management Company #1 to
Treasury,
Harrisburg, 

 

13

January 1 3, 201 5

Invoice frOm Asset
Management Company #1 to
Treasury,
Harrisburg, 

 

14

April 10, 2015

Invoice from Asset
Management Company #1 to
Treasury,
Harrisburg, 

 

 

15

 

July 13, 2015

 

Invoice from Asset
Management Company #1 to
Treasury,
Harrisburg, 

 

 

Case Document 1 Filed 07/20/16 Page 19 of 41

 

16

October 14, 2015

Invoice from Asset
Management Company #1 to
Treasury,
Harrisburg, 

 

17

January 13, 2016

Invoice from Asset
Management Company #1 to
Treasury,
Harrisburg, 

 

18

May 1, 2015

Letter and check from
Treasury,
Harrisburg, to

Asset Management Company
#2

 

19

April 19, 2012

Invoice from Asset
Management Company #3 to
Treasury,
Harrisburg, 

 

20

July 23, 2012

Invoice from Asset
Management Company #3 to
Treasury,
Harrisburg, 

 

21

October 19, 2012

Invoice from Asset
Management Company #3 to
Treasury,
Harrisburg, 

 

22

January 16, 2013

Invoice from Asset
Management Company #3 to
Treasury,
Harrisburg, 

 

 

23

 

April 11, 2013

 

Invoice from Asset
Management Company #3 to
Treasury,
Harrisburg, 

 

19

 

Case Document 1 Filed 07/20/16 Page 20 of 41

 

24

July 12, 2013

Invoice from Asset
Management Company #3 to
Treasury,
Harrisburg, 

 

25

October 10, 201 3

Invoice from Asset
Management Company #3 to
Treasury,
Harrisburg, 

 

26

January 13, 2014

Invoice from Asset
Management Company #3 to
Treasury,
Harrisburg, 

 

27

April 11, 2014

Invoice from Asset
Management Company #3 to
Treasury,
Harrisburg, 

 

28

July 14, 2014

Invoice from Asset
Management Company #3 to
Treasury,
Harrisburg, 

 

29

October 1, 2014

Invoice from Asset
Management Company #3 to
Treasury,
Harrisburg, 

 

30

January 13, 2015

Invoice from Asset
Management Company #3 to
Treasury,
Harrisburg, 

 

31

April 11, 2015

Invoice from Asset
Management Company #3 to
Treasury,
Harrisburg, 

 

 

32

 

July 14,2015

 

Invoice from Asset
Management Company #3 to
Treasury,
Harrisburg, 

 

20

 

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Invoice from Asset
Management Company #3 to
Treasury,
Harrisburg, 

33 October 12, 2015

 

Invoice from Asset
Management Company #3 to
Treasury,
Harrisburg, 

34 January 13, 2016

 

 

Letter from Richard Ireland to
Robert McCord containing two
$50,000 checks made out to
?McCord for Governor?

35 December 10, 2014

 

 

 

 

In violation of Title 18, United States Code, 1341, 1346 and 1349.

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Counts 36-42
Honest Services Wire Fraud/
Attempted Honest Services Wire Fraud
(18 Use. 1343, 1346 and 1349)
THE GRAND JURY FURTHER CHARGESZ

32. The allegations contained in Counts 1 through 35 and in the
remaining Counts of this Indictment are hereby re-alleged and incorporated
by reference as if fully set forth herein.

33. From on or about July 1, 2008, the exact date being unknown to the
Grand Jury, through on or about January 31, 2016, in the Middle District of
and elsewhere, the defendant,

RICHARD W. IRELAND,
knowingly devised and intended to devise a material scheme and artifice to
defraud and deprive the Commonwealth of and the citizens of
the Commonwealth of of their right to the honest and faithful

services of the Treasurer of through bribery and kickbacks, and

attempted to do so.
USE OF INTERSTATE WIRES TO EXECUTE THE SCHEME
34. On or about the date of each count listed below, in the Middle

District of and elsewhere, the defendant RICHARD W.

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IRELAND, for the purpose of executing the above'described scheme and

artifice to defraud, and attempting to do so, did transmit and cause to be

transmitted by means of Wire and radio communication in interstate

commerce the following writings, signs, signals, pictures and soundsi

 

Count

Date

Wire Communication

 

36

April 23, 2012

Emailed Invoice from Asset
Management Company in
Nashville, Tennessee to
Treasury,
Harrisburg, 

 

37

July 18,2012

Emailed Invoice from Asset
Management Company in
Nashville, Tennessee to
Treasury,
Harrisburg, 

 

38

April 15, 2014

Emailed Invoice from Asset
Management Company #2 to
Treasury,
Harrisburg, 

 

39

March 24, 2015

Emailed Invoice from Asset
Management Company #2 to
Treasury,
Harrisburg, 

 

 

40

 

February 10, 2012

 

Emailed Invoice from Asset
Management Company #3 to
Treasury,
Harrisburg, 

 

23

 

Case Document 1 Filed 07/20/16 Page 24 of 41

 

Wire communication sent as a
result of deposit at Wells Fargo
Bank in Harrisburg,

41 January 2, 2015 of $50,000 check
from a business associate of
Richard W. Ireland to McCord
for Governor

 

 

Wire communication sent as a
result of deposit at Wells Fargo
Bank in Harrisburg,
of $50,000 check

from Richard W. Ireland to
McCord for Governor

42 January 2, 2015

 

 

 

 

In violation of Title 18, United States Code, 1343, 1346 and 1849.

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Counts 4345

Money Laundering

[18 Use. 2, 1956(a)(1)(A)(i)l

THE GRAND JURY FURTHER CHARGESI

35. The allegations contained in Counts 1 through 42 and in the
remaining Counts of this Indictment are hereby re-alleged and incorporated
by reference as if fully set forth herein.

36. On or about the dates identified below, in the Middle District of
and elsewhere, the Defendant,

RICHARD W. IRELAND,

aiding and abetting others known and unknown, and aided and abetted by
others known and unknown, did knowingly conduct, and attempt to conduct,
the following financial transactions affecting interstate and foreign commerce,
which involved the proceeds of specified unlawful activity, that is, honest
services mail fraud, in violation of Title 18, United States Code, ?1341, and
honest services wire fraud, in violation of Title 18, United States Code, 1343,
with the intent to promote the carrying on of said specified unlawful activity
and that while conducting and attempting to conduct such financial

transactions, the defendant knew that the property involved in the financial

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transactions, represented the proceeds of some form of unlawful activity.

 

Count Date Amount Transaction

 

Transfer of
funds by 
43 August 14, 2012 $50,000.00 Corp. check no.
650 from Penn
Liberty Bank
Account No.
to
Charity #2

 

Transfer of
funds by Check
number 10067
drawn on Onsite
44 April 3, 2014 $63,047.28 Sterilization
account at
Penn Liberty
Bank account
number

made payable to
Employee #3

 

 

Transfer of
funds from
Valley Forge
Investment

45 April 80, 2014 $78,722.17 Corp?s bank
account at Penn
Liberty Bank to
Paychex, lnc.,
containing
bonus to
Employee #1

 

 

 

 

 

All in Violation of Title 18, United States Code, and 2.
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Counts 46-78

Unlawful Monetary Transactions

(18 Use. 2, 1957)

THE GRAND JURY FURTHER CHARGESI

37. The allegations contained in Counts 1 through 45 of this Indictment
are hereby re-alleged and incorporated by reference as if fully set forth herein.

38. On or about the dates identified below, in the Middle District of
and elsewhere, the Defendant,

RICHARD W. IRELAND,

aiding and abetting others known and unknown, and aided and abetted by
others known and unknown, did knowingly engage, and attempt to engage, in
the following monetary transactions by through and to a financial institution,
affecting interstate or foreign commerce, in criminally derived property of a
value greater than $10,000, that is the deposit, withdrawal, transfer, and
exchange of funds, such property having been derived from a specified
unlawful activity, that is, honest services mail fraud, in violation of Title 18,

United States Code, 1341, and honest services wire fraud in violation of Title

18, United States Code, 1843.

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Count

Date

Amount

Transaction

 

46

August 9, 2011

$25,000

Transfer of funds from VFIM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to RWI Advisors Corp.
account number at
Penn Liberty Bank

 

47

August 9, 201 1

$25,000

Transfer of funds from 
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to BGM Advisors
Corp. account number
at Penn Liberty
Bank

 

48

November 28, 201 1

$50,000

Transfer of funds from VFIM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

 

49

 

February 21, 2012

 

$50,000

 

Transfer of funds from VFIM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

28

 

 

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50

May 29, 2012

$25,000

Transfer of funds from VF IM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

51

June 6, 2012

$35,000

Transfer of funds from VFIM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

52

August 14, 2012

$50,000

Transfer of funds by VFIM
Corp check no. 650 from Penn
Liberty Bank Account No.
to Charity #2

 

 

53

 

August 17, 2012

 

$15,000

 

Transfer of funds from VFIM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

29

 

Case Document 1 Filed 07/20/16 Page 30 of 41

 

54

December 21, 2012

$65,000

Transfer of funds from VF IM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

55

May 24, 2013

$200,000

Transfer of funds from VFIM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge

Investment Corp account
number at Penn

Liberty Bank

 

56

August 9, 201 3

$100,000

Transfer of funds from VFIM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

 

57

 

November 11, 2013

 

$100,000

 

Transfer of funds from VFIM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

30

 

Case Document 1 Filed 07/20/16 Page 31 of 41

 

58

February 12, 2014

$100,000

Transfer of funds from VF IM
Corp account number
at Penn. Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

59

May 9, 2014

$100,000

Transfer of funds from VFIM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

60

September 2, 2014

$100,000

Transfer of funds from VFIM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

 

61

 

November 21, 2014

 

$100,000

 

Transfer of funds from VFIM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

81

 

Case Document 1 Filed 07/20/16 Page 32 of 41

 

62

April 13, 2015

$100,000

Transfer of funds from VF IM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

63

May 22, 201 5

$100,000

Transfer of funds from VFIM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

64

August 25, 2015

$125,000

Transfer of funds from VFIM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

 

65

 

November 23, 2015

 

$20,000

 

Transfer of funds from VFIM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

82

 

Case Document 1 Filed 07/20/16 Page 33 of 41

 

66

November 23, 2015

$20,000

Transfer of funds from VF IM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

67

November 30, 2015

$60,000

Transfer of funds from VFIM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1 
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

 

68

 

March 1, 2016

 

$100,000

 

Transfer of funds from VFIM
Corp account number
at Penn Liberty
Bank holding Asset
Management Company #1
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

33

 

Case Document 1 Filed 07/20/16 Page 34 of 41

 

Transfer of funds from S'Index
LLC account number
at Penn Liberty
Bank holding Asset
Management Company 2
69 June 18, 2014 $50,000 proceeds to a Limited
Partnership of the family of a
business associate of Richard
W. Ireland, account number
at Penn Liberty
Bank

 

Transfer of funds from S-IndeX
LLC account number

742 at Penn Liberty
Bank holding Asset
Management Company 2
proceeds to RWI Advisors Corp.
account number at
Penn Liberty Bank

70 June 18, 2014 $50,000

 

Transfer of funds from S'Index
LLC account number
at Penn Liberty
Bank holding Asset

71 July 29, 2014 $24,000 Management Company 2
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

 

Transfer of funds from S-Index
LLC account number
at Penn Liberty
Bank holding Asset

72 August 18, 2014 $30,000 Management Company 2
proceeds to Valley Forge
Investment Corp account
number at Penn
Liberty Bank

 

 

 

 

34

 

Case Document 1 Filed 07/20/16 Page 35 of 41

 

73

April 1, 2014

$250,000

Transfer of funds from Index
Licensing LLC account number
at Penn Liberty
Bank holding Asset
Management Company 3
proceeds to the Limited
Partnership of the family of a
business associate of Richard

W. Ireland, account number
at Penn Liberty
Bank

 

74

April 1, 2014

$250,000

Transfer of funds from Index
Licensing LLC account number
at Penn Liberty
Bank holding Asset
Management Company 3
proceeds to RWI Advisors Corp.
account number at
Penn Liberty Bank

 

 

75

 

April 23, 2014

 

$80,000

 

Transfer of funds from Index
Licensing LLC account number
at Penn Liberty
Bank holding Asset
Management Company 3
proceeds to the Limited
Partnership of a family of a
business associate of Richard
W. Ireland, account number
at Penn Liberty
Bank

 

35

 

Case Document 1 Filed 07/20/16 Page 36 of 41

 

Transfer of funds from Index
Licensing LLC account number
at Penn Liberty
Bank holding Asset
Management Company 3
proceeds to RWI Advisors Corp.
account number at
Penn Liberty Bank

76 April 23, 2014 $80,000

 

Transfer of funds from Index
Licensing LLC account number
at Penn Liberty
Bank holding Asset
Management Company 3
77 April 13, 2015 $400,000 proceeds to the Limited
Partnership of the family of a
business associate of Richard
W. Ireland, account number
at Penn Liberty
Bank

 

 

Transfer of funds from Index
Licensing LLC account number
at Penn Liberty
Bank holding Asset
Management Company 3
proceeds to RWI Advisors Corp.
account number at
Penn Liberty Bank

78 April 13, 2015 $400,000

 

 

 

 

All in Violation of Title 18, United States Code, 1957 and 2.

36

 

Case Document 1 Filed 07/20/16 Page 37 of 41

Count 79

Money Laundering Conspiracy
[18 Use. 1956(h)]

THE GRAND JURY FURTHER CHARGESI

39. The allegations contained in Counts 1 through 78 of this Indictment
are hereby re'alleged and incorporated by reference as if fully set forth herein.

40. From-on or about July 1, 2008, the exact date being unknown to the
Grand Jury, through March 1, 2016, in the Middle District of 
and elsewhere, the Defendant,

RICHARD W. IRELAND,

did knowingly and willfully combine, conspire, confederate and agree together
with other persons known and unknown to the Grand Jury to commit offenses
against the United States in violation of Title 18, United States Code, 1956
and 1957, to wit:

to knowingly conduct and attempt to conduct a financial transaction

affecting interstate and foreign commerce which involved the proceeds of

a specified unlawful activity, that is, honest services mail fraud, in

violation of Title 18, United States Code, 1341 and honest services wire

fraud, in violation of Title 18, United States Code, 1343, with the intent

3'7

Case Document 1 Filed 07/20/16 Page 38 of 41

to promote the carrying on of the same specified unlawful activity, and
that while conducting and attempting to conduct such financial
transaction knew that the property involved in the financial transaction
represented the proceeds of some form of unlawful activity in violation of
Title 18, United States Code, and,

to knowingly conduct and attempt to conduct financial transactions
affecting interstate and foreign commerce, which transactions involved
the proceeds of specified unlawful activity, that is, honest services mail
fraud, in violation of Title 18, United States Code, 1341 and honest
services wire fraud, in violation of Title 18, United States Code, 1343,
knowing that the transactions were designed in whole or in part to
conceal and disguise the nature, location, source, ownership, and control
of the proceeds of specified unlawful activity, and that while conducting
and attempting to conduct such financial transactions, knew that the
property involved in the financial transactions represented the proceeds
of some form of unlawful activity, in violation of Title 18, United States
Code, and

to knowingly engage and attempt to engage in monetary

transactions by, through or to a financial institution, affecting interstate

38

Case Document 1 Filed 07/20/16 Page 39 of 41

and foreign commerce, in criminally derived property of a value greater
than $10,000, such property having been derived from a Specified
unlawful activity, that is, honest services mail fraud, in violation of Title
18, United States Code, 1341 and honest services Wire fraud, in
violation of Title 18, United States Code, 1343, in violation of Title 18,
United States Code, 1957.

All in violation of Title 18, United States Code, 1956(h).

39

Case Document 1 Filed 07/20/16 Page 40 of 41

NOTICE OF INTENT TO SEEK FORFEITURE

41. The allegations contained in Counts 1 through 79 of the foregoing
Indictment are hereby realleged and incorporated by reference for the purpose
of alleging forfeitures pursuant to Title 18, United States Code, Sections
982(a)(1) and 981(a)(1)(c) and Title 28, United States Code, Section 2461(c).

42. Upon conviction of the offenses in violation of Title 18, United
States Code, Sections 1341, 1343, 1956, and 1957 set forth in Counts 2 through
79 of this Indictment, the defendant,

RICHARD W. IRELAND,

shall forfeit to the United States of America, pursuant to Title 18, United
States Code, Sections 982(a)(1) and 981(a)(1)(C) and Title 28, United States
Code, Section 2461(c), any property, real or personal, which constitutes or is
derived from proceeds traceable to the offenses and any property, real or
personal, involved in such offenses. The property to be forfeited includes, but
is not limited to, the following:

a. $10,581,101.59 United States currency.

43. If any of the property described above, as a result of any act or
omission of the defendant

a. cannot be located upon the exercise of due diligence;

40

Case Document 1 Filed 07/20/16 Page 41 of 41

b. has been transferred or sold to, or deposited with, a third party;

0. has been placed beyond the jurisdiction of the court;
d. has been substantially diminished in value; or
e. has been commingled with other property Which cannot be divided

Without difficulty,
the United States of America shall be entitled to forfeiture of substitute
property pursuant to Title 21, United States Code, Section 853(p), as
incorporated by Title 18, United States Code, Section 982(b)(1) and Title 28,
United States Code, Section 2461(0).
All pursuant to 18 U.S.C. 982(a)(1) and 981(a)(1)(C) and 28 U.S.C. 
2461(0). I

DENNIS 
ATTORNEY FOR THE UNITED
STATES ACTING UNDER 
AUTHORITY CONFERRED BY
TITLE 28, UNITED STATES

mongrel  
By: Michael A. Consiglio 
Assistant US. Attorney

7-10 zone

WW  Date
By: William S. Houser
Assistant US. Attorney

A TRUE BILLZ

 

 

 

41