low tech fraud high tech fraud: embezzlement, mobile

Low Tech Fraud – High Tech Fraud: Embezzlement, Mobile Banking Fraud,

and Holder in Due Course

Greg Litster

President

SAFEChecks

Dr. Kasthuri Henry, PhD, CTP, Six Sigma Black Belt

Corp. Director of Financial Process & Interim Treasurer

Berkshire Hathaway, Duracell

What is Embezzlement?

• A perpetrator takes or uses a company’s money without consent.

• May happen all at once or bit by bit

• Can include falsified records and moving funds from account to account

• Often goes for years without detection2

6 TPYES OF EMBEZZLEMENT

6 Major Types

Siphoning

Check Kiting

Lapping

Payroll

Kickbacks

Overtime

This is accomplished by the people working on the front line in stores or

restaurants. They devise a way to pocket money from the register without

creating discrepancies between what the computer shows and what the drawer

shows.

Accomplished by making a series of deposits and

withdrawals between several banks, taking

advantage of “float” which is the amount of time it

takes for deposited checks to clear their home banks.

A person that handles the bill paying function at a

corporation would be able to do this crime by using

company checkbook to get the scam started and

progress it until the banks realize what is happening.

Accomplished by accepting incoming payments from

customers or vendors. A person working in this capacity for

a church, for example, could use bank deposits for several

companies and change the allocation of the funds to cover

up their own personal taking of certain cash payments from

certain customers. This accumulation of funds obtained

while in a trusted position of fiduciary responsibility would

quality as a money laundering crime.

This is accomplished by using the company payroll in order to illegally take

money by adding some family member who is not employed with the company,

maybe spouse and/or kids, and have them drawing income against the

company. At home, the employee would be able to cash each of the checks,

increasing their level of income..

Any people involved in purchasing activities in any

organization could be prospective embezzlers

through kickbacks. This involves a vendor, from

whom the company purchases materials in their

course of business, agrees to give that employee

money, directly to them, if they continue to buy a

certain product from that vendor. Often times these

situations involve inflated prices, since the vendor

agent is possibly trying to make some personal

profit as well.

Another way that people can commit embezzlement is through the

falsification of overtime records. An hourly-paid manager for the local

branch office of the bank could do this.

6 TYPES OF EMBEZZLEMENT:

Siphoning

Check Kiting

Lapping

Payroll

Kickbacks

Overtime

Embezzlers

Embezzlement happens

In the presense of The “Fraud Triangle”

• Motive

• Opportunity

• Rationalization

Mitigation is

• Effective controls

Preventing & Handling Embezzlement

Common Sources of Embezzlement:

Controls to prevent embezzlement:➢ Ensure the employees are not having bills or invoices rerouted to a personal

residence or private mail box

➢ Look for delinquent taxes notifications

➢ Look for cash reserves slowly depleting, and identify root causes

➢ Perform Random Surprise Audits

Payroll Procurement T & E

Controls to prevent embezzlement:

➢Segregation of Duties

➢Vendor and Employee Set-up separate from Vendor Payables

➢Payroll totally separate from cash reconciliation

➢Vendor and Employee Hiring Procedures and Documentations to meet various Vendor and EEOC Regulations

➢Zero tolerance on no-bid contracts

➢Effective Internal Controls for Payroll, Procurement and T&E

Employers best practice to handle embezzlement:

➢Contact a lawyer as soon as possible

➢Do not question employees or take other actions without lawyer’s advice

What are your thoughts on companies not taking action

to protect their brand?

Resources

Embezzlement Schemes differ across industries and by

company size. Study these Resources for details about your

organization:

2017 Hiscox Embezzlement Study (also see prior years)

Association of Certified Fraud Examiners

“Report to the Nations” 2010 – 2016

Marquet Report on Embezzlement (2008 – 2015)

Frank Abagnale Fraud Bulletin, Volume 15

(also see prior Volumes)

Embezzlement happens:

• In every industry and department

• At every level of employee

Highlights

• Small businesses (<500 employees) suffer relatively higher embezzlement costs than large firms

• More women embezzle than men (51% v 49%)

• Men cause significantly higher embezzlement losses

Highlights

• 37% of cases had losses > $500,000.

• 23% had losses > $1 million.

• 55% of companies had <100 employees

• 68% of companies had <500 employees

Highlights

• 29% of schemes lasted > five years

• Longest scheme lasted 41 years

Highlights

Profile of an Embezzler

1. No single set of characteristics

2. Corroborating circumstances and “Red Flags”

3. They must:

a. Hold a position of confidence within the organization

b. Be able to recognize an opportunity for fraud

c. Possess the technical skills necessary for theft

4. Ability to rationalize stealing company funds

Median Age: 48

Position Held: Finance/Accounting = 68%

Lone Perpetrator = 85%

Conspiracy = 15%

96% of perpetrators had never been charged

or convicted of a fraud-related offense

Do background checks, but over-reliance on background

investigations is unwise.

Many companies don’t press charges!

Embezzlement Reasons

• Nicer Lifestyle

• Gambling

• False sense of “entitlement”

• Substance abuse

• Support a personal business

• Support “Significant Other”

Nicer Lifestyle and Gambling

dwarfed all other motivations

65% 27%

The “tone” set by upper management significantly

contributes to embezzlement –

• Unethical behavior/attitudes

• Overriding established safeguards

• Pressuring employees with unrealistic goals.

Red Flags

Extravagance Lifestyle out of proportion to salary

“Eager Beaver” Comes in early, leaves late, never takes

vacation

Disgruntled Feels unfairly treated, steals to ‘even the

score’

Egotistical risk-taker Rule-breaker in-and-out of work life

Embezzlement Cases

Jose Urrutia, Orange County, CA September 2018

Volunteer Treasurer – Junior United Soccer Association (Anaheim)

Volunteer Treasurer – International Seafarers Center (Long Beach)

Port of Long Beach, Finance Department, CPA

Patricia Cascione, So. California September 2018

Treasurer for multiple Girl Scout troops

Former CFO of the Beverly Hills Cancer Center

Embezzlement via “shell” vendors

Anita Collins, 67, Charged With Stealing $1 Million From NY Archdiocese

Embezzlement via “shell” vendors

NEW YORK A 67-year-old woman with a criminal record for theft has been charged with siphoning $1 million in

donations while working in a finance office of the Roman Catholic Archdiocese of New York. (January 30, 2012)

The archdiocese said it did not conduct a criminal background check when Anita Collins was hired in 2003. Church

officials were unaware that she had been convicted of grand larceny in one case and pleaded guilty to a

misdemeanor in another.

Over seven years Collins sent fake invoices to the archdiocese, then issued 450 checks

on accounts she controlled, all in amounts under the $2,500 threshold that would have

required a supervisor's approval.

Maria Louisa Mason, 80, a retired state employee, has been charged with embezzling $73,000 in public money intended to build a statue in honor of Cesar Chavez.

School employee accused of embezzling $200,000

MUSKEGON, MI -- A long-time school bookkeeper is accused of stealing $208,000 from Western Michigan Christian High School.

Rev. Jonathan Wehrle, the founding pastor of St. Martha's Church

in Okemos, is accused of stealing $5 million from the church.

Rita CrundwellDixon, Ilinois City Comptroller

Rita Crundwell

Embezzled $53 million in public funds over 22 years

Rita Crundwell

Used the money to breed horses; had a $400K RV

Rita Crundwell

Sentence: 17 years

Embezzlement via Bogus Vendors

(no Separation of Duties)

Texas: Small Company - $2.4 million over 6 years

Used QuickBooks and hand-written checks

Trusted bookkeeper of 13 years embezzled $2.4 million.

Issued & signed checks, reconciled accounts

Bogus payees, incomplete endorsement

Company sued the Bank of First Deposit

(BOFD)

Who won Lawsuit?

The Bank!

UCC: One-Year Statute of Limitations!

After one year, the bank has NO LIABILITY even if

the bank was negligent in the transaction

Santa Monica’s Big Blue Bus

$1,075,000

Embezzlement via Diverted Deposits

Actual Big Blue Bus Check stolen from mail

Big Blue Bus

• Federal Transportation money ► FBI, Secret Service

• Check believed stolen by a Nigerian temporary employee

• Nigerian temp quit when FBI began interviews

…but his picture was discovered in FBI files

• Check was NOT Altered – Endorsement was forged

• Forged endorsements are liability of BOFD for 3 years

Prevent Embezzlement via Diverted Deposits

Use your Bank’s Lockbox Service

Uniform Commercial Code (UCC)

• The risk of loss for fraudulent endorsements by

employees…fall[s] on the employer…if the bank was

not negligent in the transaction.

“Reasonable Employee Rule””

Embezzlement Prevention

Tools and Strategies

Anonymous Tips

#1 means to discover embezzlment

Embezzlement Prevention Tools and Strategies

Tip Hotline is the most effective tool to detect embezzlement

Tip Hotline accessible by:

1. Employees

2. Vendors

3. Customers

4. Outsiders

Mobile Banking Fraud

MOBILE BANKING FRAUD

BALANCING ERM ACROSS THE ORGANIZATIONMakomaski J and Vance B, 2007, p. 10

Enterprise Risk Management for Dummies, written under the auspices by Risk and Insurance

Management Society, Inc.

Cross Functional and Emerging View of Risks

Legal Financial Business/ Operational Safety/ Audit

Strategy Security

• Civil • Fuel • Brand • Technology • Safety • Fraud

• Criminal • Interest • Reputation • Info Security • Environment • Disclosure

• Regulatory • ForEx • Service • e-Business • Emp. Safety • Process Risks

• Contractual • Insurance/ • Alliances • Continuity • Security • Fin. Controls Financing

• Expansion • Revenue

Functional Risk View

Many companies have deep functional risk identification and management;

the challenge is to address cross functional and forward looking “horizon” risks.

Always Asking “Are we there yet”?

Keep doing what is

working

Do you want to

improve

results?Yes

Change

Something

Are you satisfied

with the results?

Mobile Banking and Deposit Fraud –

the newest twist on check fraud

72% of all fraud cases involving mobile banking apps included mobile Remote Deposit Capture (mRDC).

mRDC fraud is the latest example of fraudsters merging the old and the new – classic social engineering and check fraud over modern banking channels and technology.

Guardian Analytics Mobile Fraud Trends Report, April 2016

Mobile Banking Fraud:

Double Deposits

Mobile Banking Deposit Fraud

Scenario: A check is mailed to Dishonest Don

• Don uses a smart phone app to deposit check

Takes pix of front of check

Endorses the back of a different check

Uploads check; is pays at drawer’s bank

Mobile Banking Deposit Fraud

Later, Don cashes the same check at a check cashing

▪ 2nd check hits the drawer’s bank account

(check is presented for payment twice)

Scenario: A title insurance company gives John Doe a

check at closing. John Doe deposits the check via a

mobile app...

...then comes back to office and returns the check,

asking that it be made payable to John Doe or Jane Doe.

Mobile Banking Fraud: Another variation…

The company doesn’t think to place a

Stop Payment on the first check

because they have the check in hand!

1. If a physical check is returned for a replacement,

place a stop payment on the returned check. It may

have been deposited remotely.

2. Recipient MUST sign an affidavit stating the check

was not “deposited.”

3. An Affidavit does not provide protection, only a right

to sue and collect legal fees.

Who Takes The Loss

on Double Deposits??

The answer is found in the Rules governing

Check 21

The Uniform Commercial Code (UCC):

Holder In Due Course

1. Mobile depositing is another form of Remote Deposit Capture

2. Remote Deposit Capture is part of Check 21

3. Check 21 has specific rules that govern Remote Deposit

Capture (including mRDC)

4. The Rules determine who takes the loss

Mobile Banking & Check 21

Check 21 Rules

Two Warranties:

▪ Image of check is clean; everything is legible; substitute check is properly created

▪ Check is presented for payment only one time; no double presentments.

The Fed did not envision Remote Deposit Capture desktop scanners or mobile banking smart phone apps in 2004 –yet the rules are still relevant and applicable!

Bank of First Deposit (BOFD) can charge the loss

against its customer’s account.

Liability for the loss falls on the bank that allowed its

customer to use the smart phone app.

Under the § 229.56 Warranty…

Warranty Claims

A Breach of Warranty claim can be filed within

one year from the cause of action.

➢ Cause of action begins to run the date the injured party first learns of the loss.

➢ Claims must be made within 30 days after the person has reason to know or further losses cannot be claimed.

➢ Comparative negligence applies.

FraudTips.net

➢An innocent party who accepts a check for goods or services

➢No evidence of alteration or forgery, or knowledge of fraud by

recipient

➢ Statute of Limitations

✓ 10 years from issue date

✓ Three (3) years from date of return

➢ A Holder In Due Course can sell his/her rights

➢Trumps Stop Payments

➢Trumps Positive Pay

Trump (n.) To get the better of an adversary or

competitor by using a crucial, often hidden resource.

Federal Appellate Court

Lawsuits

Robert Triffin v. Cigna Insurance

• Two year old check; payment stopped

• No “expiration date” printed on check

UCC: Check valid for 10 years or 3 years

• Print on checks: “This check expires and is void 25

days from issue date”

✓ Don’t re-issue check until first check expires

http://www.jurispro.com/files/documents/doc-1066206627-article-2071.pdf

http://caselaw.findlaw.com/nj-superior-court-appellate-division/1093442.html

Print a SHORT expiration date on face of check:

“This check expires and is void 25 days from Issue Date”

Anyone who accepts an expired instrument (a check)

has No Legal Standing as a HIDC

➢ Robert Triffin v. Somerset Valley Bank and Hauser

Contracting Company

• 80 counterfeit checks totaling $25,000 on authentic-looking

ADP check stock

• Bank returned the checks as counterfeits

• Triffin buys $8,800 in returned checks from four check

cashing stores, and as a HIDC, sued Hauser for NEGLIGENCE

for not controlling his check stock.

HIDC & Controlled Check Stock

➢ Lower court ruled in favor of Triffin, saying the

checks looked “genuine”

Hauser appealed; claimed he never had possession of

the checks or authorized their issuance.

Federal Appellate Court UPHELD lower court; ruled the checks

looked “genuine”

Hauser Contracting ordered to pay Triffin $8,800

Solution:

Use controlled, high security checks

Robert Triffin v. Pomerantz Staffing Services

• 18 counterfeit checks drawn on Pomerantz’ acct cashed at check

cashing store. Every check under $400

• Each check had a PRINTED warning on the face:

“THE BACK OF THIS CHECK HAS HEAT SENSITIVE INK TO CONFIRM

AUTHENTICITY”

• Check cashier cashed the checks without examining the back of the

checks

http://lawlibrary.rutgers.edu/courts/appellate/a2002-02.opn.html

Robert Triffin v. Pomerantz Staffing Services…

➢ Counterfeit checks looked authentic on face, but DID NOT HAVE heat-sensitive ink on the back

• Because casher did not verify heat-sensitive ink on the back, it could

not claim Holder in Due Course status

•Triffin LOST because the security feature was absent, and forged

signature was not specifically disavowed

➢ Pomerantz’ check security features helped save him!

http://lawlibrary.rutgers.edu/courts/appellate/a2002-02.opn.html

Sometimes an informed customer refuses a security procedure

that is commercially reasonable and suitable for that customer

and insists on using a higher-risk procedure because it is more

convenient or cheaper. In that case, under the last sentence of

subsection (c), the customer has voluntarily assumed the risk of

failure of the procedure and cannot shift the loss to the bank.

Official Comments to the Funds Transfers

provisions of the UCC:

More information on Holder In Due Course

can be found in Frank Abagnale’s Fraud Bulletin

available at SAFEChecks Booth 1601

“Old-School”Check Fraud

Check Fraud

Why talk about Check Fraud?

The FIRST Check Fraud Lawsuit in 1762

Price v. Neal, England

Price sued Neal for check fraud

Picture courtesy of Colonial Williamsburg

Check fraud has continued

unabated for 250 years!

Check Fraud

Produces more $ Losses

than all other types of payment fraud!

Fraudulent Payments by Method(Respondents were hit multiple ways; total > 100%)

Percentage

CHECKS 75%

Transfers 46%

Corporate

Cards 32%

ACH Debits

ACH Credits

AFP Payments Fraud and Control Survey 2018

This reverses the declining trend

in check fraud since 2010.

Fraud LOSSES by Method

(How Dollars were actually lost)

Percentage

CHECKS 43%

Transfers 23%

Corporate

Cards 20%

ACH Debits

ACH Credits

AFP Payments Fraud and Control Survey 2016(data not available in 2017 or 2018)

Technology is making Frank Abagnale’s “gift”

achievable by mere mortals

Frank Abagnale

Catch Me If You Can

“Checks have been and continue to be the payment

method most often exposed to fraud activity.”

AFP Payments Fraud and Control Survey 2018

Check fraud also accounts for the largest

dollar amount of financial loss due to fraud.

51% of large organizations

(plus millions of smaller companies)

still issue checks

Check fraud is not going away!

AFP 2017 Payments Fraud Survey

1) Placing a Stop Payment on a check ends your legal

responsibility to pay the check.

2) Positive Pay will catch all check fraud attempts.

3) Payee Positive Pay will catch all check fraud attempts,

including altered/added payee names.

4) I'm using Payee Positive Pay. The quality of my check

stock doesn't matter.

QUIZ: True or False?

5) In a Check 21 world, check security features don’t matter.

6) In a Check 21 world, check security features don’t matter if

you’re using Payee Positive Pay.

7) Your payables are processed by a third party (your bank) that

uses Payee Positive Pay. The quality of the check stock they use

doesn't matter to you. If there’s fraud loss, they'll take the hit.

8) If you have a great relationship with your bank, you’ll never be

held liable for a check fraud loss

QUIZ: True or False?

All are…

FALSE – Holder In Due Course (UCC)

trumps Stop Payments & Positive Pay

1) Placing a Stop Payment on a check ends

your legal responsibility to pay the check

FALSE – Altered Payee Names and

counterfeit checks

2) Positive Pay will catch all check fraud

attempts

FALSE – Added Payee name placed 2 lines above

the original name will pass right through

Payee Pos Pay

3) Payee Positive Pay will catch all altered or

added payee names

FALSE – Check 21 Indemnity Provision, & HIDC

and counterfeit checks that looked “genuine”…

(Triffin vs. Somerset Valley Bank and

Hauser Contracting Co. vs. ADP)

4) I'm using Payee Positive Pay. The quality

of my check stock doesn't matter.

FALSE – Check 21’s Indemnity Provision

5) In a Check 21 world, check security features

don’t matter

6) In a Check 21 world, check security features

don’t matter if you’re using Payee Positive Pay

FALSE – Check 21’s Indemnity

Provision and Holder In Due Course

Probably FALSE. It depends on:

– Whose bank account the checks are drawn on.

– What the contract says about losses. If the contract is silent, YOU

have the liability.

– The dollar amount of the loss.(I’ve never heard of a bank or other payables service provider volunteering by contract to accept check fraud losses.)

7) Your payables are processed by a third party (your

bank) that uses Payee Positive Pay. The quality of the

check stock they use doesn't matter to you. If there’s

fraud loss, they'll take the hit.

- Florida Power & Light v. NationsBank

- Cincinnati Insurance Co. v. Wachovia Bank

- Healthcare Insurance company in the South

8) If you have a great relationship with your bank,

you’ll never be held liable for a check fraud loss

Today’s generation:What once was “old” is NEW

Outlaw Gangsta Crips, Brooklyn, NY

“...Gangs traditionally associated with drugs and

violent crimes are increasingly committing financial

frauds.

Gangs are getting into crimes like check fraud

and identity theft because they are more lucrative, harder to

detect, and carry lighter prison sentences....”

Wall Street Journal, March 8, 2016

“We think of gang members being

knuckleheads, but these guys are using a

sophisticated thought process and getting

involved in stuff that requires technology and

an understanding of the banking system.”

“Prosecutors said the gang members created and

deposited fake checks, and then quickly withdrew money

from the accounts before the banks could identify the checks

as fake.

The alleged scheme reaped more than $500,000 for the

group....”

Strategies to Prevent

Effective check fraud

prevention strategies start

with a high security check.

Do check security features still

matter in a Check 21 world?

Check 21’s

Indemnity Provision

Check 21 Indemnity Provision:

Converting bank (company/person) is liable for any loss

that is directly related to the paying bank receiving a

substitute check in place of the original check

Indemnity Claims

An Indemnity claim can be filed within one year from the cause of

action.

✓ Cause of action begins to run the date the injured party first learnsof the loss.

✓ Claims must be made within 30 days after the person has reason to know or further losses cannot be claimed.

✓ Comparative negligence applies.

What check security features matter most?

Controlled check stock are checks that are

NOT sold entirely blank to anyone, unless

the face has been uniquely customized for

that organization.

1. Controlled check stock

Who Sells Blank, Uncontrolled Checks?

➢ Virtually ALL accounting / check writing

Software Vendors

➢ Virtually ALL check printers

1. Large, national printers

2. Small print brokers buy from wholesalers

Uncontrolled Checks

I bought “high-security” checks from multiple well-known check manufacturers…

…using a closed account number!

This CLOSED ACCOUNT NUMBER was used to order “high-security” checks!

Failure to Verify Name/Account #/ Address

Any ACTIVE account number could be used when ordering!!

ANY Name & Logo could be added

How is

Uncontrolled Check Stock

a problem?

Fraudsters use:

1. Adobe Illustrator

2. Scanner

3. Buy ORIGINAL blank check stock (uncontrolled)

to create authentic-looking counterfeit checks

–including Cashiers Checks and Official Checks.

Fraudsters Create Counterfeit Checks

SAFEChecks does not sell checks entirely blank unlessthe face of the check has been uniquely designed and customized for that end user.

For customers that use entirely blank checks we can print the company’s website along the edge, or a customized logo on the face, or something that is unique to that customer.

In contrast with other check printers…

Every new check order is verified with the bank

SAFEChecks has never had a check replicated

and used in a check fraud scam.

Additional Security Features

2. Dual-tone True watermark

3. Thermochromatic ink

4. Correctly worded warning banners

5. Toner anchorage

6. Copy void pantograph

7. Chemical sensitivity

8. Chemical wash detection box

9. Inventory control numbers

Positive Pay...

...a powerful tool!

PositivePay.net

Payee Positive Pay

provides No Protection Against:

Added Payee Names printed 2 lines

above the original payee name. These

added Payee Names will evade

detection by Payee Positive Pay

Banks have NO Solution for checks

with a bogus Payee Name printed

2 lines above the original payee name

Open Areas Where Forgers Add A New Payee Name

Typical Check Layout

The “Solution”:

Secure Name and

Secure Number Fonts

created by special Printer Driver software

Secure Name Font

Secure Name Font printed above original payee name

helps eliminate Added Payee Name Risk

Fix it: Use a Secure Name Font

No room for an Added Payee

Secure Name Font printed above original payee name

helps eliminate Added Payee Name Risk

Leaves No Room for Adding Bogus Payee

Secure NUMBER Font

Secure NUMBER font blocks out area to prevent an Added Payee Name

Deterrence: Add WARNINGS to the Check

Deterrence: Encrypted barcode

Barcode contains:

1. Drawer

2. Payee Name

3. Dollar Amount

4. Issue Date

5. Check Number

6. Account Number

7. Routing/Transit Number

8. Date and Time Check was printed

9. Laser Printer used

10. The employee that printed the check

Software also creates a Positive Pay check issue file to send to the bank.

NO Technical Skills are needed to create the Positive Pay check issue file

Barcode is created by special software

Special softwarecan:

1. Accumulate check data and create a Positive Pay check

issue file

2. Change Font size

3. Add Barcode, Secure Name & Number fonts

4. Be configured to send Pos Pay files to bank automatically

Identical data is printed on both checks.

Which check would forgers prefer to attack?

Typical Check Layout –Check is on top and shows thru window envelope

Software can Reposition Check Placement

Payee Name, Address, is printed in TOP white panel.

Check is re-positioned to the bottom.

Check is Z-folded with TOP PANEL showing thru window.

It is not obvious the envelope contains a check.

8934 Eton Avenue

Canoga Park, CA 91304

Loose Ends…

Legal Reasons to Use Positive Pay &

Multiple Payee Names on Checks

ACH Filters and Blocks

Legal Reasons to use Positive Pay

If Multiple Payee Names on a check do not include

the word “and” after the names—

the Payee is “ambiguous” and legally means “OR”

A forward slash [virgule, vər-gyül “/” ] = OR

Multiple Payee Names

Prevent unauthorized ACH debits from paying against your bank

account …

An unauthorized ACH debit MUST be returned within 24 hours

after it posts or it CANNOT BE RETURNED!

ACH Filters and Blocks

ACH Filters and Blocks are available through your Bank

Greg LitsterPresident

SAFEChecks

Greg@SAFEChecks.com Henry.k@duracell.com

kas@kashenry.com

Dr. Kasthuri Henry, PhD, CTP, Six Sigma Black Belt

Corp. Director of Financial Process & Interim Treasurer

Berkshire Hathaway / Duracell

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