Superseder Against Five Madoff Cronies

MANHATTAN (CN) - Five former Bernard Madoff employees are charged in a 33-county superseding indictment with aiding and abetting the imprisoned con man who pulled off the greatest Ponzi scheme in history.

Daniel Bonventre, Annette Bongiorno, Joann "Jodi" Crupi, Jerome O'Hara and George Perez are charged with conspiracy, securities fraud, tax evasion and aiding and abetting, in the 69-page federal indictment.

Madoff's decades-long scam collapsed in December 2008, with only $300 million on hand while claiming to be managing $65 billion in investments.

"Daniel Bonventre, Annette Bongiorno, Joann Crupi aka 'Jodi,' Jerome O'Hara and George Perez, the defendants, were all long-time employees of Madoff Securities," the lengthy indictment states. "In various important ways, Bonventre, Bongiorno, Crupi, O'Hara, and Perez - along with other Madoff Securities employees or outside consultants, including Frank DiPascali, Jr., David I. Kugel, Enrica Cotellessa-Pitz, Peter Madoff, Irwin Lipkin, Eric Lipkin, Craig Kugel, and David Friehling - enabled Madoff to commit different aspects of his massive fraud. In particular, and among other things, Bonventre, Bongiorno, Crupi, O'Hara, and Perez made false representations, created false entries in books and records, and fabricated false securities transactions for Madoff Securities investment advisory clients. Each profited as a result.

"Daniel Bonventre, the defendant, worked at Madoff Securities from in or about August 1968, through at least on or about December 11, 2008, the date the fraud was revealed. Since at least the 1980s, Bonventre served as 'Director of Operations' for Madoff Securities and was responsible for supervising its 'back office,' which was the firm's operations center. Among other things, Bonventre was responsible for maintaining various books and records of the firm, including the principal accounting documents, such as the General Ledger ('G/L), and the stock record. Bonventre also reconciled the firm's various bank accounts, and supervised the employees who worked in the accounting department and the 'cage' -the area of Madoff Securities responsible for processing incoming and outgoing checks and/or wire transfers, and also for settling and clearing trades. Bonventre also supervised other Madoff Securities employees in connection with particular tasks, such as Jerome O'Hara and George Perez, the defendants, in connection with their work related to the production of the G/L and other accounting records.

"Annette Bongiorno, the defendant, worked at Madoff Securities from in or about 1968, through at least on or about December 11, 2008. Bongiorno, who worked essentially as a portfolio manager in the investment advisory business, had a variety of responsibilities, including managing hundreds of investment advisory accounts for Madoff's longest-standing customers, purportedly having a cumulative balance of approximately $8.5 billion dollars when Madoff Securities collapsed. Bongiorno also supervised employees who worked for the firm's investment advisory business.

"Joann Crupi, aka 'Jodi,' the defendant, worked at Madoff Securities from in or about 1983, through at least on or about December 11, 2008. Like Bongiorno, Crupi worked in the investment advisory business as essentially a portfolio manager, and, among other things, managed several investment advisory accounts that purportedly had a cumulative balance of approximately $900 million when Madoff Securities collapsed. Crupi also assisted Frank DiPascali, Jr. in managing the so-called split strike conversion strategy accounts, discussed below. In addition to managing investment advisory accounts for Madoff Securities customers, Crupi was also responsible for tracking the daily activity of the bank account into which billions of dollars of investment advisory client money was deposited and withdrawn (the 'Ponzi Account'), and directing wire transfers into and out of the Ponzi Account.

"Jerome O'Hara and George Perez, the defendants, worked at Madoff Securities starting in or about 1990 and 1991, respectively. O'Hara and Perez were each responsible for, among other things, developing and maintaining computer programs for computers that supported the operations of Madoff Securities. As described below, O'Hara and Perez created and/or maintained proprietary software designed to give the Madoff Securities investment advisory business the appearance of a legitimate firm, when in fact the investment advisory business was entirely a fraud."The United States seeks forfeitures and penalties for bank fraud, conspiracy, tax evasion obstructing and impeding the IRS, falsifying ERISA documents, false SEC filings, false accounting, investment adviser fraud and securities fraud.

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