The Securities and Exchange Commission (SEC) describes a Ponzi scheme, in part, as "an investment fraud that involves the payment of purported returns to existing investors from funds contributed by new investors." This is consistent with, in many ways, how UDF operates: After years of mismanagement, the UDF structure has begun to implode.Evidence of UDF's dire situation includes a series of defaults, bankruptcy petitions, lawsuits, key resignations — including that of UDF's audit firm, a key UDF director, and the CFO of UDF's largest borrower — followed by UDF's own overdue admission that it has been the subject of an SEC investigation since April 2014.A robust anti-corruption compliance program that requires employees and agents to adhere strictly to instilled corporate values of honesty and integrity, internal whistle-blower policies, training and annual certification by employees can not only help avoid illegal conduct, but may also help provide defences against criminal conviction and the imposition of huge multi-million dollar penalties, which are becoming common in Canada.
Last year, we took a short position in United Development Funding (UDF) IV.
Our research showed that UDF exhibited characteristics consistent with a Ponzi scheme, the size and scope of which exceeded a billion dollars.
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This announcement provides details with respect to allegations of bribes paid to public officials in the Republic of Congo by this Toronto-based mining company and its affiliates, currently developing a $1.5-billion potash mine in that country.