According to the allegations in the complaint, from its formation around late 2015 until in or about July 2020, Dominion Bank and Trust Company operated as a purported financial institution, which claimed it could extend or facilitate financing for small businesses in exchange for an advanced fee or deposit. In fact, this was a fraud scheme, the DoJ alleged.
From at least in or about October 2016 through in or about April 2020, Gerald Shaw served as the purported “chief compliance officer.” In that role, Shaw’s responsibilities included drafting various financial instruments sent to victims in exchange for payments.
The scheme worked like this: Victims were instructed to “wire tens or hundreds of thousands of dollars to Dominion Bank as a deposit or servicing fee for future financing or credit based on representations that Dominion Bank could provide such services. Those representations were false,” the DoJ stated. “In fact, no financing existed. The victims did not receive the promised credit. And the victims were generally unable to get their money back, as Dominion Bank typically did not return funds to victims.”
Instead, the purported bank “kept victims’ money and, in some instances, even responded to refund requests by sending invoices for additional amounts,” the DoJ stated. In total, approximately 60 individual and corporate victims were schemed out of more than $4 million.
In June 2018, Shaw wrote in an email directed to two Dominion Bank officers that the bank was “20 weeks behind” in paying his “$500 a week salary.” He added, “‘On several occasions, I have indicated to you that I know Dominion does not have the money to pay my $500 a week [salary].’ Nonetheless, Shaw continued his involvement in the scheme,” the DoJ stated.
Shaw is being charged with one count of conspiracy to commit wire fraud and one count of wire fraud, each of which carry a maximum potential prison sentence of 20 years. 
Jaclyn Jaeger is a contributing editor at Compliance Chief 360° and a freelance business writer based in Manchester, New Hampshire.