AML and Financial Crimes

Fraud Investigation

If your organization has reason to believe that fraud has occurred, it is critical to find someone with the training, experience and skills necessary to determine if your suspicions are founded and to provide supporting evidence and documentation.  Bates can assist your organization through conducting internal or external investigations, including interviewing key witnesses, data analysis and testing, forensic accounting, and comprehensive reporting. We utilize some of the latest digital tools and detection techniques to provide you with accurate and concise answers in a timely manner.  Bates’ goal is to provide you with all of the information necessary to determine who was involved, how the fraud was perpetrated, the extent of the financial loss to your company and/or clients and creating a clear plan for moving forward to mitigate those losses and prevent future fraud.

Internal/External Investigations

Whether it's a large-scale insider trading investigation or a focused examination into specific transactions and/or events, Bates Group offers experts with financial industry, fraud examination and accounting backgrounds to form a valuable team so that management and counsel are in command of the facts in order to make the best-informed decisions.


The difference between quickly resolving a matter and having it linger for years often comes down to knowing the precise questions to ask at the proper time from the correct people. Bates Group consultants have years of experience in investigative interviewing techniques, ensuring that we have the skills needed when your next matter arises.

Big Data Analytics (Data Mining, Analysis and Testing)

Bates Group is highly experienced in providing consulting services involving large and complex datasets. We have experience working with datasets containing billions of records. Utilizing state-of-the-art technology we allow for an efficient and cost-effective approach to assist in navigating the discovery process, performing data diagnostics, and conducting statistical and empirical analysis. Through our engagements we have collected and aggregated data from multiple sources within our clients’ businesses. In doing so, we have gained the experience to help minimize the efforts required from our clients’ data personnel and to ensure data integrity throughout the process.

Forensic Accounting

Bates has the skills, insight and experience to assist investors by quantifying damages, tracing assets to provide insight to assist in fact finding, identifying internal control failures and assessing their resultant impact on the investors and financial institutions through the use of forensic accounting.


Bates has extensive experience conducting and supporting in-depth internal reviews and corporate investigations for financial service providers and other clients. Our dedicated team of former senior legal and compliance officers, Certified Fraud Examiners, Certified Public Accountants and Certified Financial Forensic accountants has decades of experience conducting a wide-range of fraud, sales practice, employee misconduct, accounting, and forensic investigations. 

Examples of Bates Group‘s Capabilities

Fraud Investigation

Case Examples
  • Our Investigations team has searched through millions of pages of documents for evidence of backdated stock option grants; considered thousands of records to determine whether investors were sold the correct mutual fund share classes; reviewed the records of financial conduct of a very large number of brokers and advisors; examined loan portfolios to ensure that lending standards were applied equally to all applicants; audited financial records searching for evidence of channel stuffing; and verified completion cost estimates for large construction projects.
  • Fraud investigation and asset tracing to determine how an employee investment advisor was spending his income to determine if he was in violation of anti-money laundering, immigration and other laws.
  • Internal fraud investigation for a client to determine if an investment advisor used client funds for personal gain. We reviewed hundreds of accounts for two dozen high profile clients covering a five year period of time to look for evidence of fraud and help determine what damages might exist.
  • Forensic accounting of family trust involving almost a dozen related and non-related entities over a nine year period of time to determine how funds were spent and who authorized the expenditures.
  • In a well-publicized bankruptcy involving a broker-dealer, we managed millions of data points across competing databases. With our IT team and in-house programmers, we efficiently searched each database and succeeded in tracing the movement of the firm’s assets under management (customer funds) in the weeks prior to bankruptcy. In turn, this enabled our team to identify and illustrate when assets had been used inappropriately.
  • A private equity firm with an investment in an energy company sent a team of forensic accountants to review the financial reporting function because their monthly performance reports showed inconsistent results, despite rising costs.  The investigation disclosed that there were no controls over financial reporting and the Finance Director was preparing fraudulent reports to disguise the fact that the plant was losing money.  The Director was replaced and new controls were implemented, enabling the portfolio company to reduce costs, dispose of excess assets and return a profit, ultimately being sold at a profit.
Big Data Experience
  • We have performed an internal investigation for a large financial institution into the trading activity of a financial instrument by a group of over 6,500 FAs for over tens of thousands of clients.  In the course of our investigation we have created and analyzed a dataset of the individual account transactions associated with the FAs over multiple years.  In doing so, we were heavily involved in working with the data personnel of the firm to pull the necessary data and performed data diagnostics on the data to confirm accuracy.
  • Our staff has performed complex regression analysis to investigate the impact of trades and orders on stock prices.  Prior to performing such analyses, staff collected and standardized millions of records of orders and activity data from various sources.  Coding was done such that the analysis could efficiently be replicated for each individual stock.
  • Real estate investment trust (REIT) transactions covering a five year period of time were analyzed to determine whether the transactions meet the suitability guidelines required by the prospectus, individual states and the internal guidelines of the transacting institution.  This project started with the review and validation of nearly 200,000 transactions with over 6,000,000 individual data points.  We then undertook the task of creating a matrix of over 26,000 possible suitability guidelines, which consider conditions such as net worth, annual income, concentration with product, issuer and affiliate, REITs and all alternative investments.  Once the data was prepared and the suitability guidelines were establish, we created testing protocols that would allow us to determine which, if any, of these transactions violated the individual requirements of the suitability guidelines.  After the violations were determined, we then reviewed and validated an additional 150,000 data points to help establish what damages, if any, the investor suffered as a result of the unsuitable investment.  The results of the testing and damages calculations were then provided to the transacting institution and state regulators.    
  • Our staff has researched and analyzed various open-end fund complexes to deduce investment strategy, trading patterns, alleged mispricing, and expense to shareholders. Staff also reviewed a dataset of portfolio trades by the portfolio managers as well as trades by investors.
  • Staff also has experience performing a micro-economic study that utilized billions of records including trade and order data for all companies listed on an exchange.  Data were also merged with market maker level data to conduct a comprehensive study on how market makers reacted to investor activity.

Contact Bates Group

Bates Group is with you every step of the way. Contact us today for more information on how our End-to-End Solutions can help your firm.

Contact Bates Group