Case 6:20-mj-04019-MWP Document 1 Filed 01/22/20 Page 1 of 14

AO 91 (Rev. 02/09) Criminal Complaint

United States District Coi Mn 22

for the
Western District of New York

United States of America CT O'r Wt

)
)
V. ) Case No. 20-MJ-
)
CHRISTOPHER PARRIS )
J
Defendant

CRIMINAL COMPLAINT

I, the complainant in this case, state that the following is true to the best of my knowledge and
belief.

Between on or about the date of January 2008 through June 2018 in the county of Monroe in the
Western District of New York, the defendant violated 18 U.S.C. §§ 1341. 1349. & 1956(h). offenses
described as follows:

the defendant did knowingly and willfully:(a) conspire and agree with Perry Santillo and others to devise
a scheme and artifice to defraud investors, that is a Ponzi scheme, and to use the mails and commercial
interstate carriers for the purpose of executing such scheme to defraud, in violation of 18 U.S.C. 1349;(b)
devise a scheme and artifice to defraud investors, that is a Ponzi scheme, and for the purpose of executing
such scheme and artifice, did deposit or cause to be deposited any matter or thing to be sent or delivered by
mail and commercial interstate carrier, and did take and receive therefrom the same, in violation of 18 USC
1341; and (c) conspire and agree with Perry Santillo and others to conduct financial transactions knowing
that the property involved in such transactions represented the proceeds of some form of unlawful activity,
that is, monies fraudulently obtained through a Ponzi scheme, with the intent to promote the carrying on of
aspecified unlawful activity, and knowing that such transactions were designed in whole or part to conceal
and disguise the nature, source, ownership and control of such proceeds, in violation of 18 U.S.C. 1956(h).

This criminal complaint is based on these facts:

Please see attached affidavit

tph^iiiant's Signature
Compi Sii

Kristin M. Gibson. S/A FBI

Printed name and title
Sworn to before me and signed in my presence.
Date: I^22.| Judge's signature

City and State: Rochester. New York Hon. Marian W.Pavson. U.S. Magistrate Judge
Printed name and title
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AFFIDAVIT m SUPPORT OF A CRIMINAL COMPLAINT

STATE OF NEW YORK )

COUNTY OF MONROE ) ss: JUa M-AlQ
CITY OF ROCHESTER )

I, Kristin M. Gibson, being duly sworn, do depose and say:

1. I am a Special Agent("SA")with the Federal Bureau ofInvestigation ("FBI"),

and have been employed in that capacity for approximately four (4) years. I am currently

assigned to the FBI's Buffalo Division, Rochester Resident Agency. During the course of

my employment with the FBI,I have received specialized training in, and have participated

in, criminal investigations involving violations offederal financial crime laws and associated

crimes.

2. This affidavit is made in support of a criminal complaint charging

CHRISTOPHER PARRIS with violations of Title 18, United States Code, Sections 1341

(mad fraud), 1349(conspiracy to commit mad)and 1956(h)(conspiracy to launder money)

(hereafter referred to as the SUBJECT DEFENSES). I have not included herein each and

every fact known to me concerning this investigation. Rather, I have set forth only those

facts necessary to establish that there is probable cause to believe that PARRIS did commit

the SUBJECT OFFENSES, as flxrther described herein.

3. The information and statements contained in this affidavit are based upon

information leamed in my own investigation, including statements by victims, wimesses and

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a co-conspirator Perry Santillo who previously pled guilty for his role in this matter,

information contained in records and documents,including financial institution records and

materials seized pursuant to search warrants, my training and experience, and information

supphed by other law enforcement agents and persons employed by regulatory agencies.

4. In sum and substance, as set forth below, PARRIS worked with Perry Santillo

and others, to operate a Ponzi scheme and defraud hundreds of investors out of more than

$115 million over a ten-year period fi:om approximately 2008 to 2018.

ORIGINAND OVERVIEW OF THEPONZISCHEME

5. From in or about January 2008, to in or about June 2018, the exact dates being

unknown, in tiie Western District of New York and elsewhere, PARRIS willfully conspired

and agreed with SanfdUo and others, known and unknown,to devise a scheme and artifice to

defraud and obtain money by means of false representations and promises, that is, an

investment fraud commonly known as a Ponzi scheme.

6. In or about 2007, PARRIS and Santillo, as equal partners, formed a business

known as Lucian Development,located at 36 West Main Street, Rochester, New York,in the

Westem District ofNew York.

7. Prior to approximately July 2007, Lucian Development raised millions of

dollars from investors in Rochester, and elsewhere, by soliciting investments for City Capital

Corporation, a business operated by Ephren Taylor. In July 2007,PARRIS and Santillo were
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advised by Ephren Taylor that their investors' money had been lost. In response, in August

2007, PARRIS and Santillo agreed to acquire the assets and debts of City Capital

Corporation. The acquisition proved financially ruinous, with the amount of the acquired

debt far exceeding the value ofthe acquired assets. Taylor was later prosecuted and convicted

of operating a Ponzi scheme.

8. Rather than disclose the hard truth to investors in 2007 that their money,

entrusted to Lucian Development for investment in City Capital Corporation, was all gone,

PARRIS and Santillo embarked on a cycle of soliciting ever-increasing amounts of money

from new investors in an increasingly desperate and unsuccessful attempt to recoup the losses.

Over the years, in classic Ponzi scheme fashion and to keep the scheme from being detected,

a substantial portion of incoming new investor monies were depleted by making promised

interest and other payments to earlier investors. Most ofthe rest ofincoming investor money

was used: (i) to finance lavish lifestyles of the conspirators, their famihes and associates; (ii)

to expand the scheme by purchasing investment advisor / brokerage businesses to obtain

access to fresh investors; and (iii) to pay operating expenses - salaries for a sales force and

adrrunistrative staff, office rents and related expenses, housing for employees, interest on

loans, and so forth - used to keep the scheme going and maintain a facade of legitimate

business operations. Very little investor money was deployed in productive mvestments, and

when so deployed, the investments yielded meager income and were not profitable, or failed

altogether.
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9. The scheme was headquartered and based out oflocations in Rochester, New

York, with a number of sateUite offices around the country. Administrative and banking

functions were largely performed out of Rochester, New York. The conspiracy employed a

variety of sales people, including PARRIS and Santillo, who travelled around the country to

meet with and solicit new investors.

10. Eventually, having obtained at least $115.5 million, from approximately 1000

investors between approximately January 2012 and June 19,2018, the scheme collapsed. By

the end of2017,PARRIS and SantiUo(doing business through an array ofcorporate entities)^

had retumed approximately $44.8 million to investors as part oftheir scheme, but continued

to owe investors approximately $70.7 million in principal (without taking into account

promised interest payments).

11. The Ponzi scheme was kept afloat through constant infusions of new cash.

Starting in or about 2010, to find potential investors to sohcit and defraud, PARRIS and

SantiUo purchased businesses from established investment advisors or brokers who were

looking to exit their businesses. As part of these sales, the selling investment advisors or

brokers- who over the years had estabhshed a relationship oftrust with his/her client- were

' During the relevant period,PARRIS and Santillo directly and indirectly owned
and/or controUed, the foUowing entities; Lucian Development(a/k/a Lucian Global
Development, Lucian Global and Lucian Group), United RL Capital Services,
Middlebury Development, First Nationle Solutions, Percipience, GenVest, First
American Holdings (a/k/a First American Securities), Ocala Investments, Pocono's
Investments, Advanced Medica, Advice and Life Agency, Berkeley Development,
Boyles America,High Point Insurance Solutions, Horizon Asset Protection, and Male
Medica, among others.
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required to introduce PARRIS and Santillo to the clients. After the initial introduction,

PARRIS and Santillo met their new clients to tell them that they had reviewed their current

portfolios and determined them to be substandard. They advised new clients to transfer their

existing investments into other purported investment vehicles that PARRIS and Santillo

offered, stating tihat doing so would increase retums and reduce risk. Based upon false and

misleading representations and promises, and material omissions, Santillo and/or PARRIS

induced their clients to invest in one or more promissory notes, preferred stock offering or

other investment offering that PARRIS and Santillo had created as part oftheir scheme.

12. Between approximately 2008 and approximately September 2017, PARRIS

and Santillo purchased the busmesses of at least 15 investment advisors or brokers. These

businesses, located across the country, including in Teimessee, Ohio, Minnesota, Nevada,

California (5 businesses), Florida, South Carolina (2 businesses), Texas, Permsylvania,

Maryland and Indiana, were acquired using money obtained from prior investors.

13. The investment offerings pitched by PARRIS and Santillo as part oftheir Ponzi

scheme consisted principally of unsecured promissory notes and preferred stock issued by

various entities controlled by Santillo and PARRIS (hereafter, the "issuers"). Each such

issuer was portrayed and marketed as an independent entity offering investment opportunities

that were different and distinct from defendant's other issuers (as well as PARRIS and

Santillo). To maintain the illusion of independence and separateness, each issuer used an

address, contact information and/or ownership structure intended to conceal PARRIS and

Santillo's common ownership and control over the issuers. Employees were directed to use
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false names when communicating with investors in order to further maintain the illusion. In

reality, each issuer was under common control ofSantillo and/or PARRIS,and was operated

from a common address by common employees in Rochester, New York. The issuers were

not separate, independent companies in anjrthing but name, and investor money entrusted to

a specific issuer was routinely and freely transferred and shared with other issuers, as well as

other accounts controlled by PARRIS and Santillo None of the issuers had any substantial

bonafide business activity. Instead, their main purpose was to raise money from investors to

perpetuate the scheme.

14. An early issuer estabhshed by Santillo and PARRIS as part ofthe scheme was

First Nationle Solutions (FNS). FNS was conceived by Santillo and J.L. while driving to

solicit an investment from an existing investor in Teimessee. Because the investor knew that

Santillo owned Lucian Development, Santillo decided to concoct a new investment to sell to

the investor. SantiUo and J.L. invented the name "First Nationle Solutions," and even though

no such entity existed, they convinced the investor to invest approximately $50,000 in FNS,

telling him/her that the investment involved a real estate development. Thereafter, Santillo

and PARRIS caused FNS to be established as an LLC in the State of Michigan.

15. Once established,FNS purported in various documents provided to prospective

investors to be "designed by its Principals to achieve performance in spite of uncertain

economic conditions by taking advantage ofthe unique opportunities that exist within today's

real estate sector," and also to be "a holding company for several sales affiliates ... [that]

manage over $145 nuUion m assets . ..." FNS represented that its offices were located at 44
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Wall Street, in New York City. FNS had no subsidiaries. FNS had no substantial assets.
/

And FNS had no office at 44 WaU Street.

16. Over the years, PARRIS and Santillo induced hundreds of investors to invest

millions of doUars in essentially worthless promissory notes issued by FNS.

17. Later, PARRIS and Santillo established additional issuers so they could offer

potential investors an apparent array of investment options and the illusion of a diversified

investment portfolio. This strategy facihtated their abihty to solicit greater investment

amounts from investors because it created the misleading and false appearance ofa diversified

investment strategy (together with attendant decreased risk).

18. Other issuers estabhshed by PARRIS and Santillo included, among others:

Percipience Global Corporation, United RL Capital Services, Boyles America, Middlebury

Development Corporation, NexMedical Solutions, among others. As with FNS,none ofthe

issuers had substantial bonafide business operations or used investor money in the manner

and for the purposes represented to investors. To the extent that an issuer may have had some

minor legitimate business activities, it was not profitable and insufficient revenues were

generated to pay investors any returns (let alone return the principal amounts of their

investments).
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EXAMPLES OFSPECIFIC ACTS mFURTHERANCE OF THEPONZISCHEME

19. Victim 2, a resident of Victor, New York, played in a band with a brother of

PAREJS. In or about November 2017, PARRIS met with Victim 2 to tout investments in

FNS and Middlebury Development. PARRIS recommended that Victim 2 and his wife

liquidate their IRA (and other investments), and instead, invest the money with him.

PARRIS represented that Victim 2's money would be invested in real estate and medical

devices.

20. Victim 2 and his wife invested a total of approximately $221,758.67 with

PARRIS in November and December 2017, with $150,000 allocated for Middlebury

Development, $73,000 allocated for FNS, and the balance for unidentified uses. The

promissory notes issued under the name of FNS in exchange for this money promised to

return an immediate bonus of10% plus aimual interest at a rate of6%.

21. Victim 2 and his wife made the investment through a series of checks, all

deposited into Middlebury Development accounts, as follows: $135,131.39 (check no.

3720187655), deposited on November 21, 2017, in a Middlebury Development account

ending in -3078; $14,868.11 (check no. 2654), deposited on November 29, 2017, in a

Middlebury Development account ending in -0336; $32,728.20 (check no. 2657), deposited

on December 12, 2017, m a Middlebury Development account ending in -0336; and

$39,030.97(check no.2656), deposited on December 14,2017,in a Middlebury Development

account ending in -0336. Thereafter, Victim 2's money was transferred to other accounts

controlled by the conspirators, and ultimately used to pay PARRIS's brother, prior investors.

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high-interest rate lenders, employees and other participants in fraud, and other expenses

associated with operating the Ponzi scheme. None ofInvestor 2's money was invested in real

estate or medical devices, as represented.

22. Victim 2received three payments of$2500 pursuant to his investment contracts

with Middlebury and FNS. In May 2018, Victim 2 asked to cash out his investment pursuant

to the terms of his investment agreement. In interacting with FNS and Middlebury, Victim 2

received and sent correspondence from his home, including documents associated with

cashing out his investment, including but not limited to a mailing on or about May 14, 2018,

sent by Victim 2 to FNS at its purported 44 Wall Street address. Santillo and PARRIS did

not return Victim 2's principal investments to him, and as a result. Victim 2 has sustained a

loss in the approximate amount of$214,258.67.

23. Victim 6, a resident of Salinas, CA, initially met with Santillo in or about

October 2016, having been introduced by their former investment advisor. Santillo advised

Victim 6 that, due to the volatile market, he should temporarily move his retirement monies

into a high-yielding tax deferred fund.

24. In furtherance of the scheme, on or about October 25, 2016, and again on or

about January 27, 2017, Victim 6 mailed checks payable to FNS from Califomia to the

scheme headquarters in Rochester, New York. Victim 6's money was not deposited into a

high yielding tax deferred fund, as promised and represented. Instead, on or about October

26, 2016, $126,863 of Victim 6's money was deposited into the First Nationale Solutions
 Case 6:20-mj-04019-MWP Document 1 Filed 01/22/20 Page 11 of 14

Citizen Bank account. Later, on or about January 27, 2017, an additional $117,918 was

deposited into the same FNS account. In total, $244,781 ofVictim 6's money was transferred

to FNS without his consent. Moreover,it was done in a manner that caused the funds to lose

their qualified status as tax-deferred, resulting in Victim 6 being required to pay approximately

$11,000 in taxes.

25. Later, sometime in or around July 2017, Victim 6 met with PARRIS, who was

portrayed as Victim 6's new financial advisor, replacing SantiUo.PARRIS sohcited additional

investment from Victim 6, which was funded by the sale of the family home. Victim 6

informed PARRIS that his investment needed to be available to cover Victim 6's children's

college expenses. On or about December 28, 2017, Victim 6, at PARRIS' direction, wired

transferred $160,000 to the Middlebury Development's bank account. This money was used

to make a $141,800 payment to PARRIS' brother. On or about January 3, 2018, Victim 6

wired an additional $350,000 to Middlebury Development's bank account. This money was

used to fund seven payments totaling $108,700 to PARRIS'brother, among other uses.

26. Little to none of this money was invested conservatively as promised or used

in the manner represented. Instead, the majority ofit was used to repay earher investors and

make payments on high-interest loans that SantiUo and PARRIS had taken out beginning in

2016.

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ADDITIONAL ALLEGATIONS CONCERNING MONEYLAUNDERING

27. Between in or about January 2008, and in about June 2018, the exact dates

being unknown, in the Western District of New York and elsewhere, PARRIS willfully

conspired and agreed with Santillo and others, known and unknown,to conduct and attempt

to conduct financial transactions involving the proceeds ofspecified unlawful activity, that is

the Ponzi scheme described above, knowing that such transactions involved proceeds of the

Ponzi scheme, with the intent to promote and carry on the Ponzi scheme, and knowing that

the transactions were designed in whole or part to conceal and disguise the nature, source

ownership and control ofthe proceeds ofthe Ponzi scheme.

28. Over the relevant period,PARRIS and SantiUo controlled hundreds ofdifferent

business bank accounts opened under numerous different business names at various financial

institutions, including but not limited to Bank ofAmerica, Citizens Bank, Genesee Regional

Bank and ESL Federal Credit Union. These accounts were located in Rochester, New York,

and PARRIS and SantiUo directed and authorized the transactions that occurred in the

accounts, including deposits, withdrawals, check writing and funds transfers. Typically, for

any given financial transaction,PARRIS and/or Santillo would instruct an employee located

in Rochester, R.V., to make the transaction, and R.V. would then implement the instruction.

29. PARRIS and Santillo used the various bank accounts to transfer money from

one account to another. Incoming investor money was routinely transferred through several

accounts before the funds were finally spent on whatever purpose PARRIS and/or Santillo

authorized. By moving investor's funds through various accounts in various entity names.

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PARRIS and Santillo intended to, and were able to, conceal and obscure the fact that new

investor money was being used to repay earher investors, finance the operations ofthe Ponzi

scheme, and fund the lifestyles ofPARRIS,Santillo, and others.

30. By way ofillustration, on or about September 1, 2016, two investor victims of

the Ponzi scheme, located in California, wire transferred a total of $442,850.38, to an FNS

bank account at Citizens Bank in Rochester, ending in -3921. These funds, which constituted

proceeds ofa specified illegal activity, that is, the Ponzi scheme, were immediately transferred

to a Lucian Development account at Citizens Bank ending in -2933. The same day,the fimds

were further transferred (by two separate wires) to a Middlebury Development account at

Citizens Bank ending in -5217. The same day, the funds were transferred yet again to a

Middlebury Development account at Bank of America ending in -6374, and a United RL

account at Bank of America ending in -5101.

31. From there, by on or about September 2, 2016, the above funds were further

transferred and/or used, to (i) repay a prior investors, (ii) repay high interest rate loans,(iii)

fund personal accounts of PARRIS, PARRIS' brother and Santillo, and (iv) pay operating

expenses ofthe Ponzi scheme, among other uses.

CONCLUSION

32. Based on the foregoing, I respectfully submit that there is probable cause to

beheve CHRISTOPHER A.PARRIS did violate Title 18, United States Code, Sections 1341

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(mail fraud), 1349 (conspiracy to commit mail fraud) and 1956(li) (conspiracy to launder

money in violation of 18 U.S.C. 1956(a)(1)).

Kristin M.Gibson
Special Agent
Federal Bureau ofInvestigations
Subscribed to and sworn before me
this ZX- day of January, 2020.

oniUoA u) —
HONORABLE MARIAN W.PAYSON
UNITED STATES MAGISTRATE JUDGE

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