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the financial activities of the investment scheme as
required by law. * * *
* * * * * * *
7. The unlawful combination, conspiracy,
confederation, and agreement was to be accomplished by
the following means and methods:
a. The petitioner * * * used numerous
bank accounts, maintained in various names,
including COMSEC Corporation * * * to conduct
the financial activities of the investment
scheme, for the purpose of concealing the
financial activities of the investment
scheme.
b. The petitioner * * * conducted much
of the business of the investment scheme in
currency and cashier's check, for the purpose
of hindering and preventing the tracing of
the financial activities of the investment
scheme.
c. The petitioner * * * failed to
maintain accurate books and records of the
financial activities of the investment scheme
as required by law * * *.
* * * * * * *
8. In furtherance of the conspiracy and to
effect the objects thereof, the following acts were
done and performed by or on behalf of the petitioner
* * *:
a. On or about May 17, 1982, the
petitioner caused the incorporation of COMSEC
Corporation under Michigan law.
b. On or about April 18, 1993, the
petitioner * * * opened a savings account
* * * at the American Federal Savings and Loan,
Detroit, Michigan.
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