Bureaucracy Times

All the news fit to be declassified.

Category: Financial Fraud & Enforcement

  • Banned for Life, Still Trading: The FTC’s Four-Year Fight to Keep Martin Shkreli Out of Pharma

    Federal regulators say Martin Shkreli violated a lifetime pharmaceutical-industry ban through years of stock trading and online commentary. But court records show the government was already struggling to secure his compliance in 2022, raising questions about how permanent federal injunctions are monitored and enforced.

    When a federal judge banned Martin Shkreli from the pharmaceutical industry for life in February 2022, the order seemed reasonably straightforward. The former drug executive was prohibited from participating in an industry where a federal court had found he orchestrated an anticompetitive scheme that drove up prescription drug prices and obstructed generic competition.

    Four years later, the Federal Trade Commission and seven state attorneys general are back in court, alleging that Shkreli treated the lifetime prohibition rather less permanently than the judge intended.

    In an October 13 contempt filing, regulators accuse Shkreli of trading shares in at least 60 pharmaceutical companies, broadcasting his investments online, and attempting to influence pharmaceutical businesses through public commentary and campaigns involving short positions in their stocks.

    The government wants the court to order Shkreli to divest his pharmaceutical holdings, surrender profits from prohibited trading, and face escalating penalties for future violations, potentially including incarceration.

    But a review of earlier court records reveals something important: this is not the first time the government has returned to court over Shkreli’s compliance with the ban.

    Indeed, regulators were raising concerns about his activities within months of the original injunction.

    The resulting chronology presents an accountability question extending beyond Shkreli himself. How does the federal government enforce a lifetime industry prohibition, particularly when the person subject to it continues conducting business and communicating through public financial markets?

    The Original Ban

    Shkreli became nationally notorious in 2015 after Turing Pharmaceuticals, subsequently known as Vyera Pharmaceuticals, acquired Daraprim and raised the medication’s price from $17.50 to $750 per tablet.

    Daraprim treats toxoplasmosis, a parasitic infection that can pose serious risks to patients with weakened immune systems.

    The price increase attracted widespread condemnation, but the government’s antitrust case concerned more than the price itself.

    The FTC and participating states alleged that Shkreli and his associates maintained an illegal monopoly through restrictions that impeded competing manufacturers from developing generic alternatives.

    Following a trial, U.S. District Judge Denise Cote ruled in January 2022 that Shkreli had violated federal and state antitrust laws.

    The resulting February 4 permanent injunction barred him for life from directly or indirectly participating in the pharmaceutical industry and imposed monetary relief of up to $64.6 million.

    The prohibition was broad. It covered acquiring or holding ownership interests in pharmaceutical companies and taking actions to influence or control their business or management.

    The U.S. Court of Appeals for the Second Circuit upheld the lifetime ban in January 2024.

    For the government, the judgment was an important antitrust victory. It was also the beginning of a much longer compliance problem.

    Trouble Within the First Year

    By October 2022, the FTC and state plaintiffs were already seeking additional information about Shkreli’s activities.

    Their concerns centered partly on Druglike, Inc., a venture Shkreli announced in July 2022 that described itself as a software platform intended to support early-stage drug discovery.

    The company raised an obvious question: could someone permanently barred from participating in the pharmaceutical industry establish a business designed to facilitate pharmaceutical research?

    Regulators also questioned Shkreli’s compliance with the monetary judgment.

    According to the government’s January 20, 2023, memorandum, Shkreli had paid nothing toward the judgment as of that filing.

    The injunction contained provisions intended to help regulators answer precisely these kinds of questions.

    Shkreli was required to submit verified compliance reports, initially within 60 days of the order and annually thereafter. The FTC and state plaintiffs could demand additional reports and obtain access to relevant records and interviews.

    On October 13, 2022, regulators invoked those provisions, requesting a supplemental compliance report, supporting documents, and an interview.

    What followed was a series of missed deadlines and extensions.

    The government’s 2023 memorandum described repeated attempts to obtain the requested information during November and December 2022. According to the filing, Shkreli failed to produce a satisfactory supplemental report or make himself available for the requested interview.

    The FTC and states consequently asked the court to compel compliance through civil contempt proceedings.

    The government’s subsequent March 2023 appellate brief acknowledged that it had obtained additional information about Druglike and was investigating whether the venture violated the injunction.

    The publicly available records reviewed for this article do not establish the ultimate disposition of that investigation or the earlier contempt request.

    That unresolved history is significant because the latest allegations concern activity beginning during the same period.

    A Lifetime Ban Meets the Livestream

    According to the FTC’s October 2026 announcement, Shkreli began publicly trading pharmaceutical stocks after his release from prison in May 2022.

    The new contempt filing alleges trading involving at least 60 pharmaceutical companies, accompanied by commentary on YouTube, X, and Reddit.

    The government contends that the conduct violated the injunction’s restrictions on pharmaceutical-company ownership and efforts to influence corporate management.

    The allegations extend beyond casual financial discussion.

    Regulators say Shkreli livestreamed trading activity, explained investment strategies, and conducted public campaigns involving short positions in pharmaceutical stocks while predicting that certain companies’ clinical trials would fail.

    Reporting on the filing also describes a trading challenge involving an account with a $10 million starting balance and transactions in companies including Pfizer and Moderna.

    That figure describes the reported starting account balance, not an independently established amount of Shkreli’s personal wealth or profits.

    The distinction matters. The government has not publicly established the complete financial scope of the alleged violations, and the FTC is seeking remedies that would require identifying and accounting for the relevant trading activity.

    The alleged conduct also raises a legal distinction that the court will need to consider.

    Purchasing pharmaceutical shares, taking short positions, discussing a company’s prospects, and attempting to influence corporate management are not necessarily interchangeable activities. Whether particular conduct violates the injunction depends on its exact terms and the supporting evidence.

    The government’s position is that Shkreli’s activities crossed those boundaries. A contempt finding has not yet been entered on the new allegations, and Shkreli remains entitled to contest the government’s interpretation and evidence.

    The Compliance Question

    The most consequential aspect of the case may not be the number of stocks Shkreli allegedly traded. It may be the existence of a compliance system that regulators had already been forced to invoke.

    The February 2022 injunction was not simply a declaration that Shkreli should stay away from pharmaceuticals.

    It established recurring reporting obligations, authorized requests for additional information, and gave federal and state enforcers access to relevant records and interviews.

    By January 2023, regulators had told the court that those mechanisms were not producing the information they required.

    Now, nearly four years after the original injunction, the government alleges a pattern of prohibited activity extending back to July 2022.

    Those facts do not establish that the FTC knew about every alleged stock transaction when it occurred. Nor do they demonstrate that regulators failed to investigate evidence available to them.

    They do, however, leave several questions unanswered.

    When did the government first identify the pharmaceutical trading now described in its contempt motion? Did Shkreli’s annual compliance reports disclose any of the transactions? What additional information did regulators obtain following the 2023 dispute? And how did the agency determine that another contempt proceeding was necessary in October 2026?

    The answers could help explain whether the enforcement system operated as intended, encountered resistance that required years to resolve, or revealed shortcomings in the practical supervision of permanent industry bans.

    They would also help establish how much of the latest case was developed through routine compliance monitoring and how much depended on public statements, livestreams, and other independently collected evidence.

    Back to Court

    The FTC and the attorneys general of New York, California, Illinois, North Carolina, Ohio, Pennsylvania, and Virginia now want the Southern District of New York to intervene again.

    Their requested sanctions include mandatory divestiture of pharmaceutical stock holdings, financial penalties based on trading profits plus prejudgment interest without offsetting losses, and escalating consequences for further violations.

    The requested remedies are civil contempt measures intended to secure compliance with an existing court order. They are not a new criminal conviction, and potential incarceration would depend on further judicial proceedings and applicable legal safeguards.

    The Commission authorized the action by a 1–0 vote, with FTC Chairman Andrew Ferguson recused. Commissioner Mark Meador issued a separate statement.

    Daniel Guarnera, director of the FTC’s Bureau of Competition, emphasized the importance of compliance with judicial orders, warning that defendants must fulfill their obligations after a judgment.

    The principle is straightforward enough.

    The difficulty, as this case illustrates, lies in translating a permanent legal prohibition into sustained oversight of a person’s financial and business activities.

    Shkreli’s original antitrust case demonstrated that courts can impose extraordinary remedies when conventional restrictions are insufficient to address anticompetitive conduct.

    The latest contempt motion may help establish how those remedies work outside the courtroom.

    After all, a lifetime ban is supposed to last a lifetime. Whether the government can reliably detect and stop prohibited conduct during that period is a separate question, and one that the next round of litigation may finally help answer.

    For now, the FTC is once again asking a federal judge to enforce an order that was already supposed to be permanent.

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  • The IRS Lost $304 Billion to Fraud. Its Best Defense Was a Mission Statement.

    A Number Too Big to Be Comfortable

    Somewhere between $116 billion and $304 billion vanishes from the federal treasury every year, and it does so not through some singular, cinematic heist but through the accumulated, unglamorous churn of stolen identities, falsified deductions, and return preparers who treat the tax code as a suggestion.

    That is the range the Government Accountability Office arrived at in a new report, built from a Monte Carlo simulation stitching together adjudicated fraud cases, detected fraud that never made it to court, and the vast, unlit expanse of the shadow economy.

    Put another way, somewhere between two and six percent of what Americans owe the federal government simply disappears into fraud each year, an amount that could fund a meaningful slice of veterans’ health care or national security spending, if only anyone at the IRS had been assigned to stop it.

    Here is the part that should trouble you more than the number itself. The IRS has spent years assessing its fraud risks with real diligence, in keeping with GAO’s own Fraud Risk Framework. It knows where the exposure sits. It has documented, biannually, a fraud risk profile that identifies individual income tax fraud as one of its highest exposures, and it flagged, as far back as 2023, that new tax credits arrive faster than the fraud controls meant to guard them.

    Diagnosis, in other words, is not the problem. The problem is that having correctly identified the disease, the agency has declined to write a prescription.

    The Excuses, Collected Like Specimens

    GAO went looking for the IRS’s antifraud strategy, the coordinated document that leading fraud-risk practice says should translate a risk assessment into an actual plan of controls.

    It does not exist, at the agency level or within any of the divisions responsible for chasing fraud. What GAO got instead, when it asked division officials why, reads less like institutional analysis and more like a set of alibis assembled after the fact.

    Some officials believed the agency’s Office of the Chief Risk and Control Officer already owned the antifraud strategy. That office told GAO, on the record, that no such strategy exists there either. Other officials had simply never identified a specific need for one.

    Others still offered up their division’s routine audit activity as though conducting fraud detection were the same thing as having a documented strategy for it, a distinction that GAO’s own Fraud Risk Framework treats as fairly foundational. And at least one division pointed to its mission statement, the kind of aspirational paragraph that adorns an agency homepage, as the functional equivalent of a plan to stop nine and ten figure annual losses.

    None of these things are strategies. A mission statement does not specify how existing and new controls will address a risk the agency has already flagged as high. Standard operating procedure is not the same as a coordinated response to an evolving threat. GAO says as much, plainly, and notes that nobody at IRS could tell them who was actually supposed to own this problem, what the plan was, or when it might materialize.

    Recommendation one asks IRS to write the strategy down.

    Recommendation two asks it to name someone whose job that is.

    Partial Agreement, Fully Argued

    IRS’s written response to the draft report is where this gets genuinely entertaining, in the grim way that bureaucratic self-defense often is.

    The agency “partially agreed” with both recommendations, which is administrative language for agreeing just enough to avoid the appearance of stonewalling while conceding nothing structural. It pointed to its Chief Tax Compliance Officer as the entity coordinating fraud initiatives, though GAO notes this designation arrived only in response to being asked. Even then, it does not cover the full list of responsibilities a genuine antifraud entity is supposed to hold, from managing the risk assessment process to serving as the agency’s institutional memory on fraud controls.

    IRS also pushed back on the report’s framing, arguing that GAO had blurred the line between fraud and ordinary taxpayer noncompliance, and that judging its fraud posture through a narrow lens missed the fuller picture of its compliance framework.

    GAO’s rebuttal is the sharpest passage in the document. It reiterates, patiently, that its definition of fraud tracks the IRS’s own definition, that its estimate specifically excludes nonfraudulent noncompliance like taxpayer error, and that it interviewed officials across essentially every division with fraud responsibility, not merely the criminal investigators.

    Then it lands the number IRS handed it itself. The agency’s own projected net tax gap for 2022 was $606 billion. Between that figure and GAO’s fraud estimate, the report notes dryly, additional action seems warranted regardless of how the taxonomy gets sliced.

    What a Strategy Actually Buys

    Strip away the institutional throat clearing and the case here is almost embarrassingly simple. The IRS knows, with real precision, what its highest fraud risks look like. It has a Return Review Program that legitimately prevented an estimated $88 billion in fraudulent refund payments from 2018 through 2024, proof that targeted controls work when someone builds them.

    What it lacks is the connective tissue between knowing and doing, the single document and single office that would let those controls scale to match risks the agency itself already identified years ago and simply left unaddressed.

    GAO’s closing argument is worth sitting with, because it reframes what “strategy” even means in this context.

    A pay-and-chase model, where the agency waits for fraud to happen and then tries to claw the money back through audits and collections, is fundamentally mismatched against fraudsters who are, by definition, trying to avoid exactly that kind of detection.

    Proactive controls, designed and coordinated ahead of the fraud rather than in response to it, are cheaper and more effective, but they require someone to actually own the coordinating. Absent that person and that document, the IRS is left doing what it has always done—identifying the fire, describing the fire in exhaustive and well organized detail, and then waiting for someone else to decide who holds the hose.

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  • IRS Warns About Fake ‘Tribal Tax Credits.’ The Public Record Already Names the Promoters.

    The IRS says the credits do not exist and warns taxpayers about unnamed “promoters.” Congressional investigators and SEC filings have been considerably less shy.

    The Internal Revenue Service has a warning for taxpayers: Someone is selling fake “Tribal Tax Credits.”

    The agency’s September 18 alert says promoters are marketing nonexistent federal tax credits under names including “Tribal Tax Credits,” “Native American Tax Credits” and “Sovereign Tribal Tax Credits.” The IRS says no such federal credits exist and warns that taxpayers who claim them could face penalties, interest and even criminal consequences. IRS warning.

    There is just one conspicuous omission from the IRS warning.

    Names.

    The IRS repeatedly refers to “promoters” without identifying the companies or individuals involved.

    Fortunately, other parts of the federal government have been less mysterious.

    In April 2025, Senate Finance Committee investigators publicly identified White River Energy Corp., Nepsis Inc., Nepsis Tax Advisors LLP, Quartermaster Tax, E3 Family Office, Lifetime Advisors and Lifetime Navigators in connection with the promotion or distribution of purported tribal tax credits.

    The committee said the IRS had already confirmed to its investigators that the credits did not exist. Senate Finance Committee.

    That makes the IRS’s decision to issue an anonymous scam warning more than a little curious.

    The Numbers Are Not Small

    White River’s own filings with the Securities and Exchange Commission provide a window into just how ambitious the operation became.

    In December 2023, White River told investors that it had received another $5 billion in federal income tax credits supposedly issued to a Native American tribe. The company claimed the credits had been placed under White River’s name and taxpayer identification number at the U.S. Treasury. SEC filing.

    By February 2024, White River reported an agreement contemplating the acquisition of another $13 billion in purported credits in exchange for $3 million in cash and 10 million restricted shares of White River stock. The company said it had already paid a $1.25 million deposit. SEC filing.

    Then came the sales operation.

    In April 2024, White River announced plans to sell $5 billion of purported credits in three tranches. The first $2.5 billion would sell for 50 cents on the dollar. Another $1.5 billion would go for 55 cents. The final billion would cost 60 cents on the dollar.

    White River also said it possessed a legal opinion from an unidentified law firm supporting the validity of the credits. The company deemed the opinion a “trade secret” and said it would disclose it only to certain prospective purchasers and representatives who signed nondisclosure agreements. SEC filing.

    The IRS now says references to unverifiable legal opinions and demands for nondisclosure agreements are themselves warning signs of the scheme. IRS warning.

    The People Behind the Sales

    White River’s SEC filings also identify executives who stood to benefit directly from selling the credits.

    In April 2024, the company’s board increased annual base salaries for CEO Randy May and CFO Jay Puchir to $1 million each. Both executives also became eligible for royalties equal to 1 percent of gross proceeds from tax-credit sales. SEC filing.

    Six months later, White River doubled those royalties to 2 percent each. Directors James Cahill, Danny Hames and Greg Landis were each granted royalties equal to 0.33 percent of gross proceeds from future sales. SEC filing.

    The distribution network extended beyond White River.

    Senate Finance investigators said a whistleblower identified Lifetime founder Jon LaCasse and his daughter, Payton LaCasse, as personally pitching the credits. Investigators also independently confirmed that Lifetime’s website hosted Nepsis promotional materials concerning the credits. Senate Finance Committee.

    The Senate investigation later obtained a recording of a call between Puchir and more than 100 investors. According to the committee, White River could not provide investors with a definitive government document or government contact capable of authenticating the credits. Senate Finance Committee.

    By January 2026, Senate Finance Committee Ranking Member Ron Wyden said White River was under a DOJ criminal tax investigation involving its sales of the purported credits. The committee also accused the company of failing to disclose that investigation in required SEC reports. Those are congressional allegations; a criminal investigation itself is not a finding of guilt. Senate Finance Committee.

    So Why Doesn’t the IRS Name Them?

    That brings us back to September 2026.

    The IRS warns taxpayers that promoters may claim secret government agreements exist. It warns about credits sold at steep discounts. It warns about unverifiable legal opinions. It warns about nondisclosure agreements. And it warns that previously accepted tax returns do not prove the credits were legitimate.

    The agency even provides instructions for reporting abusive promoters.

    What it doesn’t provide is the identity of any promoter.

    That might be understandable if federal investigators were still trying to determine who was selling these products. But the public record tells a different story.

    Congress publicly identified companies connected to the promotion of the credits in April 2025. SEC filings identify White River executives and directors who received compensation tied to their sale. Congressional investigators identified individual sales activity. And by January 2026, a Senate committee was publicly discussing a Justice Department criminal investigation.

    Yet when the IRS issued its nationwide scam warning eight months later, the people it warned Americans about became simply “promoters.”

    There may be a legal, investigative or procedural reason the IRS declined to identify them. The agency’s alert does not explain one.

    The IRS has now told taxpayers what to look for.

    The public record tells them where some of those warning signs have already appeared.

    Bureaucracy Times will continue examining that record.

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  • The Postal Service Knew. It Filed a Meeting Agenda Instead.

    The United States Postal Service lost $9 billion in fiscal year 2025. Somewhere between $3.6 billion and $5 billion of the surrounding rot, spread across counterfeit shipping labels, counterfeit stamps, and a payment system nobody bothered to fraud-test before launch, was not a mystery to the agency while it happened.

    It was, by the Postal Service’s own admission, something people inside the building had flagged, discussed, and in at least one case warned about in writing more than a year before anyone shut anything down. This is not a story about an agency that failed to notice a problem. It is a story about an agency that noticed, formed a working group, and kept mailing.

    A Timeline That Reads Like a Confession

    Start with the number that should embarrass everyone involved. From March 2024 through February 2026, the Postal Service’s own Office of Inspector General says counterfeit package labels drained $3.1 billion in unrecoverable revenue, with another $520 million projected through 2028. Ninety seven percent of counterfeit labels identified in that window made it all the way to delivery.

    The detection system built to stop them, the Counterfeit Postage Intercept Process, caught the labels it was designed to catch in 2023 and then sat still while counterfeiters moved on, the institutional equivalent of reinforcing the door after the windows had been open for a year.

    The Enterprise Payment Account fraud embedded in that mess has its own paper trail, and it is the most damning document in the pile. Corporate Treasury warned Postal Service stakeholders about the vulnerability in January 2025. The agency did not officially identify the fraud until May 2025.

    The Inspector General discovered it independently that August, during unrelated site visits, which is its own small humiliation; the watchdog found the fire before the fire department did. The agency did not shut down the roughly 2,800 fraudulent accounts responsible until January 2026, a full year after Treasury’s first warning, by which point December alone had bled $125 million in a single month, 14 percent of that month’s entire label revenue.

    The Inspector General’s own words on the agency’s response were blunt: “the measures have not been timely or robust enough to counter this fraud scheme.” OIG’s audit traced the root cause to something administratively poetic. Treasury, the office responsible for catching fraud, had no consultation rights and no decision authority over the very payment system fraud was flowing through. The system was never tested for fraud prevention before it went live.

    A Machine That Cannot See What It Was Built to See

    If the label fraud is a story about warnings ignored, the companion audit on counterfeit stamps is a story about equipment deliberately blinded. The Postal Service’s primary stamp authenticator, the Advanced Facer Canceller System 200, can run in a mode that catches nearly everything or a mode that catches almost nothing, and management chose the second one to save processing time.

    When the Inspector General ran its own controlled test, feeding the machine counterfeit stamps in its low-revenue protection setting, the machine caught none of them. Zero. Management’s defense amounted to a cost argument, and a fair one on its own terms, except that nobody then bothered to implement any interim check, such as basic sample testing, to find out how much fake postage was sailing through in the meantime. That gap alone, OIG estimates, put $337 million at risk in a single fiscal year.

    The stamp fraud also has an online dimension that makes the agency look almost quaint. A contractor hired to scan the internet found 8,895 instances of counterfeit stamps being marketed or sold in under two months. The Postal Service takes over 30 days to disable an online threat once found; the contractor’s industry benchmark is eight.

    The Inspector General points out, not unkindly, that the agency already uses the Lanham Act aggressively to sue people selling unlicensed eagle-logo T-shirts and baseball caps, and applies it far less often to people selling fake postage using the same logo. Priorities, evidently, are a choice.

    Ninety Seven Cases, Nine Convictions, One Percent Recovered

    Here the story stops being about detection and becomes about consequence, or the near total absence of it. Between 2020 and 2025, the Postal Inspection Service presented 44 counterfeit label cases to the Department of Justice for prosecution.

    Nine were accepted. All nine won convictions, a perfect record on the cases federal prosecutors bothered to take, which only sharpens the question of why 35 others were turned away and why the agency still cannot say. The Inspector General recommended a simple fix, a structured data field to track why DOJ accepts or declines a case, so patterns could inform future referrals.

    The Postal Service disagreed, arguing the information “is not provided” by DOJ in the first place, an answer that concedes the problem while declining to solve it.

    Of the $57 million in losses the Inspection Service actually identified through investigation over that same five year window, it recovered $572,250. About one percent. The delay between a search warrant and a seizure warrant runs four to five months, plenty of time for a suspect whose bank has already tipped him off to walk the money elsewhere.

    The agency had two untapped options available to it. One was the Revenue Deficiency Process, an administrative billing mechanism. The other was simply referring cases to state prosecutors. It has used neither with any consistency. When OIG recommended exploring both, management disagreed with that too, and pointed to a prior report about stamps as though it had already answered a different question.

    The Working Group That Was Not a Program

    None of this happened for lack of meetings. The Postal Service assembled a “Fraud Analytics and Mitigation” team, held regular cross-functional sessions, and produced slide decks. What it did not produce, across two years and two separate audits, was a signed program charter, a clear line of decision authority, or meeting minutes documenting what was decided and why.

    Management’s own response to the recommendation that it fix this was that formal governance amounted to unnecessary overhead given how fast fraud moves, an argument that would carry more weight from an agency that had, in fact, moved fast.

    The Postal Service agreed with eight of the eleven recommendations in the label audit and rejected three, all in the section on prosecution. It agreed to all four recommendations in the stamps audit and all five in the payment account alert, mostly after the money was already gone.

    Every implementation date attached to a real fix lands sometime between April 2026 and August 2027. The Inspector General will keep filing reports. The agency will keep filing agendas.

    The $3.62 billion did not wait for either.

    Sources: Efforts to Mitigate Counterfeit Postage (USPS OIG, Report 25-072-R26, September 10, 2026); Counterfeit Stamps (USPS OIG, Report 25-121-R26, June 16, 2026); Management Alert: Enterprise Payment Account Fraud (USPS OIG, Report 25-072-2-R26, February 10, 2026)

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  • The Notary, the Vacation, and the Barred Planner: Inside the Gilchrist Tax Lien Fraud Case

    In the driveway, an unexpected visitor

    On a quiet weekday morning in a Bexar County subdivision, a 70-year-old North Texas attorney allegedly appeared without warning at a woman’s home. According to a federal criminal complaint, David Thomas Gilchrist told the woman’s husband that the FBI was looking for him and suggested the couple should consider taking a “vacation” for a couple of years, perhaps to Mexico. The visit came just days before Gilchrist was scheduled to testify under oath before the Securities and Exchange Commission.

    Federal prosecutors now allege that this driveway encounter was not an awkward misunderstanding but an act of witness tampering, aimed at pushing a potential witness out of reach of investigators probing what they describe as a $1.45 million Ponzi scheme built on the promise of safe, niche returns from Texas property tax liens.

    Gilchrist, a Grand Prairie, Texas attorney, was arrested on August 31, 2026, on a federal criminal complaint. He is charged with wire fraud, aggravated identity theft, and witness tampering, and is expected to make his initial appearance before a U.S. magistrate judge on September 2, 2026.

    The charges stem from an investment program that, on paper, looked like a sophisticated way to profit from delinquent property taxes and, in practice, allegedly became a vehicle for forgery, fabricated intermediaries, and a campaign of delay and evasion when investors started asking for their money back.

    A tax lien business that never was

    The criminal complaint affidavit alleges that between April 2023 and January 2026, Gilchrist solicited roughly twenty investors, often through partnership agreements or promissory notes, for the stated purpose of purchasing property tax liens in several Texas counties. He allegedly told investors he would use their pooled funds to buy tax liens, manage the portfolio, and repay them with attractive interest once delinquent property owners paid up.

    Property tax lien investing is, in fact, a real and heavily procedural niche. When a property owner fails to pay local taxes, a county or other taxing authority can sell the lien to private investors, who then earn statutory interest or penalties when the taxes are ultimately paid.

    Texas law contains detailed provisions for so-called transferred tax liens, specifying how liens may be assigned, recorded, and enforced. Done properly, the business can be steady, if unspectacular, for specialists who understand the statutes and local practices.

    According to investigators, that veneer of legitimacy was central to the pitch. The complaint alleges that bank records do not support Gilchrist’s representations about buying liens. Instead, he allegedly commingled investor funds with other accounts, used money for personal expenditures, and diverted new deposits to repay earlier participants. Prosecutors characterize the pattern as a classic Ponzi structure: newer funds shoring up older promises, with no real underlying investment engine.

    In total, the affidavit alleges, Gilchrist collected approximately $1.45 million from investors over the nearly three-year period and returned only about $789,000. The remainder is alleged to have been absorbed into a mix of personal spending and circular payments that kept the program running just long enough to secure additional deposits.

    What kept this program out of view for so long is not hard to discern. Private partnerships centered on a niche state-law instrument like Texas tax liens tend to operate far from the retail securities markets that draw the SEC’s routine attention.

    Only when the alleged conduct implicated the federal wire fraud and securities fraud statutes did the full weight of federal oversight come into play. A similar operation, structured to avoid securities status and interstate transfers, might have remained a strictly local problem.

    Forged deeds and borrowed identities

    The alleged misconduct, as described in court filings, did not stop at misrepresentations to investors. Once the SEC opened a formal investigation and requested documentation of the supposed tax lien purchases, Gilchrist allegedly escalated.

    According to the complaint, he provided the SEC with a series of quitclaim deeds purporting to show transfers of lien-related interests. On closer review, investigators concluded the deeds were forgeries.

    The documents, prosecutors allege, contained notary stamps and signatures belonging to real Texas notaries who had never met Gilchrist and had not notarized the transactions in question. By attaching genuine credentials to fabricated instruments, the filings suggest, Gilchrist allegedly attempted to backfill a paper trail of tax lien activity that did not exist.

    Those acts underpin the aggravated identity theft charge, which requires that a defendant knowingly use another person’s identification without lawful authority in connection with certain predicate crimes.

    The invented intermediary

    The woman whose home Gilchrist allegedly visited in Bexar County plays a different role in the narrative. According to the criminal complaint, she became a central figure not because she helped run a tax lien business, but because Gilchrist allegedly tried to cast her as the face of a fictitious one.

    During sworn SEC testimony in April and May 2026, Gilchrist allegedly told investigators he used an undocumented woman in Bexar County as an intermediary to identify delinquent homeowners and deliver cash to them as part of a lien acquisition strategy.

    He allegedly claimed he had redacted homeowner names from documents because, in his telling, the homeowners were in the country without legal status. The implication was that the SEC could not safely contact them, and that their identities were too sensitive to share.

    The complaint paints a different picture. According to prosecutors, the woman exists but was barely acquainted with Gilchrist and had no role in any tax lien transactions. She was, the filings allege, placed at the center of an invented operation that did not occur as described.

    The driveway visit, framed around warnings about the FBI and a suggested multi-year “vacation,” is alleged to have come just days before Gilchrist was due back before the SEC, turning a peripheral acquaintance into an unwitting character in a story he had already told under oath.

    Delay, distraction, and the Mansfield gym

    While regulators were working through bank records and deeds, investors were asking for their money. The complaint alleges that Gilchrist responded with an evolving series of explanations for why redemptions were delayed or payments had to be rolled over.

    Among the reasons prosecutors say he offered: the federal government was shut down, stalling necessary approvals; local authorities were tied up in an arson investigation affecting properties connected to the liens; he had been deployed to assist with hurricane relief. Each explanation, if taken at face value, suggested that external forces, like Washington politics, criminal probes, and natural disasters, were temporarily blocking distribution of otherwise sound investment proceeds.

    In one episode highlighted by investigators, Gilchrist allegedly told an investor he was hospitalized in Tennessee recovering from a colectomy. Hospitalization, especially out of state, is a powerful signal that repayment delays are unavoidable and, at least temporarily, excusable.

    Yet according to the complaint, during the period he claimed to be recovering in Tennessee, access records showed him checking into a gym in Mansfield, Texas, close to his home base in the Dallas-Fort Worth area. The alleged disconnect between his claimed incapacitation and his actual whereabouts became one more data point in a pattern of shifting stories and eroding credibility.

    The Novinger link and a repeat appearance

    Gilchrist is not the only name in the government’s paperwork. In a parallel civil action, the SEC’s Chicago Regional Office has filed a complaint charging Gilchrist with securities fraud. That civil case also references Christopher Novinger, a figure already familiar to regulators.

    In 2015, the SEC filed a civil complaint, summarized in Litigation Release No. 23256, alleging that Novinger and related parties sold approximately $4.3 million in interests in life-settlement contracts to 26 investors while making material misrepresentations.

    The program was promoted on what was billed as a financial radio show, the “Retirement Experts Radio Show,” which the SEC alleged functioned less as neutral advice and more as a marketing platform for the offerings. In 2016, through Release No. 34-78213, the Commission imposed a bar order prohibiting Novinger from associating with broker-dealers or investment advisers.

    That bar remained in place when the SEC filed its new civil complaint involving Gilchrist. According to coverage by InvestmentNews on September 1, 2026, the SEC now alleges that Novinger, despite the prior sanction, was steering clients into Gilchrist’s tax lien program. The details of that alleged pipeline are still emerging, but the mere fact that a previously barred financial promoter appears again in a fresh enforcement action underscores longstanding concerns about how effectively sanctions are monitored and enforced in fragmented markets.

    The SEC Office of Inspector General is investigating the criminal matter alongside federal prosecutors, with substantial assistance from the U.S. Marshals Service, according to government statements. Assistant U.S. Attorneys Alexander Schwab and Douglas Brasher of the Fraud Section are leading the prosecution, signaling that the case is being treated as more than a routine regional fraud referral.

    The gap around the edges

    The Gilchrist case, as laid out in the criminal and civil complaints, is not the largest alleged Ponzi operation in recent memory, nor the most complex. What makes it notable is where it sat: at the intersection of a lightly supervised state-law investment niche, informal referral networks, and federal enforcement regimes that tend to activate only after enough red flags accumulate in one place.

    The alleged scheme ran from at least April 2023 to January 2026, a span of nearly three years in which paperwork, bank wires, and individual complaints were all, in theory, available to someone with the authority to scrutinize them.

    Federal involvement here required wire fraud charges and the invocation of securities laws that treat certain pooled investments as securities even when they are nominally tied to local tax instruments. The question, for regulators and lawmakers, is less why the SEC and Department of Justice eventually acted, and more what kinds of signals could have triggered earlier, narrower interventions.

    When barred promoters allegedly reappear as referral sources, when private tax lien partnerships scale into the millions, or when a solo practitioner suddenly claims to be running a multi-county lien portfolio, those data points can be captured long before a driveway conversation turns into an obstruction allegation.

    For now, the case moves through the courts. A criminal complaint is only an allegation; it is not evidence, and it is not a conviction. All defendants, including Gilchrist and any individuals named in related filings, are presumed innocent unless and until the government proves its accusations beyond a reasonable doubt in a court of law.

    The filings in United States v. Gilchrist and the related SEC actions nonetheless outline a familiar pattern around the edges of the regulatory state, where niche products, personal trust, and delayed scrutiny can combine to give alleged schemes a long runway before anyone in authority is prepared, or positioned, to pull them back to earth.

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  • Thirty-Eight Fakes: How Fraudsters Turned the SEC’s Own Filing System Into a Trust Machine

    When a Disclosure Looks Like a License

    On the Securities and Exchange Commission’s own public database, the profile page looks reassuringly official. There is an SEC file number. A Form ADV reference. An austere masthead that reads “Exempt Reporting Adviser.” To a retail investor searching the Investment Adviser Public Disclosure system, that badge can look like a license to trust.

    According to a sweeping set of civil complaints the SEC filed in late August, it has also become something else: a cheap, reusable prop for fraud.

    The mechanism is deceptively simple. The Exempt Reporting Adviser, or ERA, category was created so that certain private fund advisers could file limited disclosures without undergoing the intensive scrutiny of full SEC registration. Yet on the Investment Adviser Public Disclosure (IAPD) database, those filings sit in the same public directory as fully registered advisers.

    The SEC itself alleges that dozens of purported firms exploited that proximity, pointing potential victims to their ERA pages as if they were evidence of government approval that the system was never designed to provide.

    The Exemption That Wasn’t Designed for This

    In regulatory terms, an ERA is a light-touch registrant. Under rules implementing the Dodd-Frank Act of 2010, advisers that manage only private funds and qualify for certain exemptions may file as Exempt Reporting Advisers instead of registering fully.

    The filing is mainly a disclosure exercise: basic ownership information, certain disciplinary histories, high-level data about the funds advised. It is transmitted through the same electronic system as full Form ADV filings, but it does not trigger the same examination regime or substantive vetting by the SEC.

    What it does not confer is any seal of approval. An ERA is not a registered investment adviser. The SEC does not review or endorse individual ERA business models before they appear on the IAPD database. According to the SEC’s own investor education materials, the category exists to reduce compliance burdens for advisers that serve sophisticated investors, not to create another credential for mass-market consumption.

    Thirty-Eight Complaints, One Playbook

    Yet the line between “disclosure” and “endorsement” can blur on a government-branded web portal. On August 27, 2026, the SEC announced that it had filed 38 simultaneous civil complaints in the U.S. District Court for the District of Colorado alleging that purported advisers and trading platforms around the world used ERA filings and related SEC references as marketing tools for unregistered, and in many instances fictitious, investment schemes.

    The actions, summarized in SEC Release No. 2026-78 and Litigation Release No. 26622, represent one of the most concentrated attempts yet to police the boundary between disclosure regime and perceived imprimatur.

    According to the complaints, the pattern recurs with minor variations. Entities would obtain or reference an ERA filing, claim a Colorado business address, and publish contact information that led nowhere. Phone numbers allegedly rang to disconnected lines. Suite numbers mapped to virtual offices or co-working spaces that had never heard of the firms using their addresses. From there, the SEC alleges, the purported advisers pointed investors to SEC file numbers, ERA pages, or fabricated “approval” documents to vouch for their legitimacy.

    Across the 38 cases, the SEC describes a common playbook. Allegedly false Colorado mailing addresses. Websites restyled from one template to another, but reusing the same fund descriptions and performance statistics across entities that were not otherwise connected. Nearly identical language, according to the complaints, touting high-yield crypto, foreign exchange, or “AI-driven” strategies.

    Phantom Auditors and Forged Seals

    Several of the complaints note that internal SEC analytics flagged statistically implausible overlaps in fund data entered into the IARD filing system, prompting closer review by enforcement staff.

    In place of real oversight, the firms allegedly invented it. The complaints cite, among other examples, references to outside auditors with no verifiable existence. One oft-repeated name in the filings, “Indicator Global,” appears in the SEC’s narrative as a kind of phantom gatekeeper, invoked to reassure investors that an independent third party had vetted returns and custody practices. According to the SEC, no such audit firm could be located.

    In other instances, the defendants allegedly displayed ornate “certificates of approval” featuring the SEC’s name or seal, despite the fact that the Commission issues no such certificates for ERAs or for investment advisers more generally.

    The SEC’s complaints also point to the digital exhaust left by the filings themselves. Although the purported firms claimed Colorado addresses, many of the IARD submissions and related account logins allegedly originated from foreign IP addresses scattered across multiple jurisdictions.

    The Commission does not allege that foreign origin is itself improper, but argues that the mismatch between claimed domestic locations and observed access patterns reinforced the picture of a coordinated effort to manufacture a U.S. regulatory footprint from afar.

    The Defendants

    The set of charged entities is sprawling by design. In its Colorado filings, the SEC names Abrdn Canada Limited, Absolutaris Base Limited, Apexium Securities Ltd, Axivon Exchange Ltd, Calystron Capital Ltd, CryptoOrbit Ltd, Equal Chance Capital Ltd, Ftaexchange Ltd, Future Finance Academy Ltd, Gainstra Capital Inc., Glorious Dawn Capital Management Co. Ltd, Harbor Financial Institute Ltd, Helios Wealth Management Ltd, Ideal Finance Ltd, Ironclad Trading Institute LLC, Korzen Asset Management Ltd, LinkedIn Research Institute Ltd, LuxePoint Capital Ltd, Nautical Echo Capital Ltd, NewstarAsset Capital Inc., Nexera Technologies Ltd, Nova Academy of Finance Ltd and Nova Financial Academy Ltd.

    The list continues: Perkea Capital Securities Inc., Pinnacle Crypto Exchange Inc., Pinno Capital Inc., Quantum Financial Institute Ltd, RBH Infinity Exchange Inc., Robin Markets Inc., Rockford Partners, Sapphire Tide Capital Ltd, Stellar Path Institute Ltd, Summit Breeze Haven Exchange Ltd, THEVGPRO Ltd, ThreeM Holding Ltd, Veriton Investment Inc., Web3 University, Wingspan Advisors LLC, and Ichcoin Tech Corp., the company behind the “WealthTutor” platform previously scrutinized in this publication’s separate investigation.

    Each complaint lays out its own factual narrative and alleged misrepresentations, but all are built on the shared theme of regulatory sheen without regulatory substance.

    The Trust Signal as a Weapon

    Those names may or may not be familiar to investors who encountered them on social media, search ads, or cold outreach. What almost all of them shared, according to the SEC, was a reference back to Washington. Marketing materials allegedly steered targets toward ERA listings, Form ADV identifiers, or generic SEC web pages, encouraging them to infer that appearance in the federal database meant their money was entering a supervised environment, part of a broader pattern of frauds moving through referral networks and recycled personas.

    The SEC is now, in effect, arguing that its own public records became part of the fraud script.

    The agency has tried to separate signal from noise. Concurrent with the Colorado filings, the Office of Investor Education and Advocacy released an alert on investor.gov warning that Exempt Reporting Advisers are not subject to the same level of regulatory oversight as registered advisers and that the SEC does not issue “certificates of approval” for any advisory firm. The alert urges investors to read the details of any IAPD entry carefully and to treat ERA status as a disclosure starting point, not an endorsement. That distinction has always been present in the rule text.

    A Design Flaw the Rule Didn’t Account For

    Dodd-Frank directed the SEC to tailor reporting obligations for advisers to certain private funds, based on the premise that sophisticated investors need less regulatory hand-holding. The Commission responded by designing ERA filings as a way to capture systemic risk information without forcing every small or specialized fund adviser into the full registration regime. But while the filing requirements calibrated burden and benefit for industry participants, the effect on unsophisticated investors confronting the IAPD interface received less attention.

    On the front end, the IAPD does exactly what Congress asked: it makes advisory information public. Yet the way it presents that information matters. ERAs appear in the same search results as fully registered advisers, framed by the same SEC branding. The database does contain textual explanations of status differences, but they do not leap off the page. For a hurried user looking for a yes-or-no answer to whether a firm is “in the system,” the difference between “registered investment adviser” and “exempt reporting adviser” is easily lost.

    Regulators are quick to stress that this is a design vulnerability, not a confession that the architecture is broken. The ERA framework has enabled thousands of legitimate advisers to comply with federal law in a proportionate way. Most ERAs do not show up in enforcement releases.

    The 38 cases in Colorado, if the allegations are borne out in court, would instead illustrate how a small subset of actors can weaponize a disclosure mechanism when user-interface design assumes sophistication that the audience does not actually possess.

    This publication previously reported in depth on Ichcoin Tech Corp. and its “WealthTutor” platform, one of the entities now named among the 38. In that case, as in the broader set of complaints, the alleged pattern is familiar: a thin factual connection to U.S. jurisdiction, a heavy rhetorical reliance on SEC file numbers and logos, and a target audience for whom those references substituted for more traditional due diligence. The new filings extend that pattern from one platform to a network of ostensibly separate brands.

    What Comes Next

    For now, the Colorado cases are at an early stage. The SEC is seeking permanent injunctions to bar future violations of the securities laws, conduct-based restrictions that would limit how the defendants could participate in the securities markets if they remain in them at all, and civil penalties intended to deter similar conduct by others. The complaints do not themselves determine liability, and all defendants are presumed innocent unless and until a court finds otherwise.

    The institutional question is what happens next to the machinery these firms allegedly misused. The SEC has now put in writing that Exempt Reporting Adviser filings and the IAPD interface can be co-opted as confidence devices.

    Having made that acknowledgement in court papers and investor alerts, the Commission owns the next move. It can redesign the architecture so that ERAs and registered advisers are visually and functionally distinct to unsophisticated users, or it can leave the interface largely as is and rely on case-by-case enforcement to police its perimeter.

    The 38 Colorado complaints draw a line in the sand. Whether that number stays exceptional, or becomes an early chapter in a larger series of exploitations, will depend in no small part on how the SEC treats the trust signals it has created.

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  • Drug Companies Told the VA What Their Best Customers Pay. Two-Thirds of Them Lied.

    When Veterans Become Test Cases For Drug Pricing Honesty

    The Department of Veterans Affairs runs the largest integrated health care system in the country. It buys enormous volumes of drugs through the VA Federal Supply Schedule, a program that was supposed to solve a simple problem: if manufacturers tell the government what they charge their best commercial customers, the government will not get fleeced.

    The contract paperwork calls this a Commercial Sales Practices disclosure. The theory is that the VA should get a price at least as good as the most favored commercial customer identified in that disclosure, consistent with the pricing rules in 38 U.S.C. § 8126.

    In practice, the VA Office of Inspector General keeps finding problems. In its latest summary of pre-award reviews of pharmaceutical proposals for fiscal year 2025, the OIG reports that 11 of 16 manufacturers submitted proposals with deficiencies in those required disclosures, covering contracts with an estimated value of about $21 billion and 1,043 offered items.1 That is just under 69 percent. You do not need a graduate seminar in procurement policy to understand what that ratio means. You just have to be able to count.

    How The VA Drug Pricing Gate Is Supposed To Work

    The VA National Acquisition Center in Hines, Illinois, runs the pharmaceutical side of the Federal Supply Schedule program under a delegation from the General Services Administration.2 Drug companies that want in on that steady government demand submit proposals that include a Commercial Sales Practices disclosure.

    On paper, it is straightforward. The manufacturer identifies its most favored commercial customer, lists the prices and discounts that customer receives, and explains any deviations from standard commercial pricing that might matter when the VA negotiates its own rates.

    The OIG does not rubber stamp those claims. For selected high value proposals, it conducts what the agency calls a pre-award review. Investigators compare the disclosure against underlying sales data, rebates, and price concessions to see whether the manufacturer described its commercial pricing accurately and completely before the contract is awarded.1

    The point is simple: the VA should not pay more than commercial customers pay for the same drug, especially when Congress has already told manufacturers in statute that prices for the VA and certain other agencies are capped at no more than a fixed percentage of the nonfederal average manufacturer price.

    For fiscal year 2025, the OIG summary covers 16 pharmaceutical proposals with a combined estimated value of about $21 billion, offering 1,043 line items into the Federal Supply Schedule.1 These are not discount contracts for aspirin at the corner store. These are large volume, multi year deals that set the baseline for what the government pays and what manufacturers earn on veterans health care.

    What Fiscal Year 2025 Actually Found

    The headline number is astounding: 11 out of 16 proposals had disclosure deficiencies, as the OIG defines them. That category includes errors, omissions, or inaccuracies in the commercial sales practices data that manufacturers are required by contract to provide truthfully and completely.1

    In seven of those 16 proposals, the OIG went further and made explicit pricing recommendations that helped contracting officers obtain about $24.7 million in savings before the contracts were awarded. That figure is not a theoretical projection, but one that reflects savings that VA contracting staff actually realized after the reviews.

    The names of the manufacturers do not appear in the public record. Individual pre-award reports are sealed because they contain commercially sensitive pricing information that federal law protects from public release.1 So the taxpayers who funded the drugs, and the veterans who will take them, see only the aggregate scorecard. They get the failure rate and the total savings, but not which company left what out of its disclosure, or how hard the government had to push to fix it.

    What that aggregate view does show is a pattern over time. The 2025 summary does not appear in isolation. In fiscal year 2023, the OIG reviewed 17 proposals and recommended approximately $120.6 million in savings for VA contracting officers.3

    In fiscal year 2024, it reviewed 14 proposals and estimated about 54.9 million dollars in potential savings, of which the VA sustained $36.8 million after negotiations.4 The $24.7 million in 2025 is realized savings, not just a recommendation.

    Whether that lower figure reflects cleaner initial proposals, a shift in which proposals the OIG chose to review, or less aggressive follow through by contracting officers is a question the public summary raises by implication and then leaves on the table.

    Why Deficiencies Are The Point, Not A Glitch

    The federal pricing rules for covered drugs exist because of a basic information gap. Drug manufacturers know exactly what they charge their best customers and what quiet concessions they make to close big commercial deals. The government generally does not, unless manufacturers are required to disclose it as a condition of doing business. Under the Veterans Health Care Act and its implementing contracts, that disclosure is not optional etiquette. It is a binding promise.

    Getting it wrong can carry real penalties. If a manufacturer obscures or misstates its commercial pricing, the government can seek price adjustments, refunds, or more severe remedies. In some cases, that pattern of conduct turns into False Claims Act exposure. That is not a hypothetical risk. The Justice Department has used that statute against pharmaceutical companies that overcharged the VA by failing to live up to their pricing obligations.

    Sanofi Pasteur, for example, agreed to pay $19.8 million to resolve allegations that it overcharged the department for certain vaccines by misreporting its pricing under the relevant federal program.5

    The OIG pre-award review program exists to keep more of those problems from maturing into retroactive enforcement cases years later. Seen that way, 11 out of 16 proposals requiring correction is not proof that the process failed. It is proof that the process is catching something real every time it is used. It is also a reminder that without this gatekeeping, those same deficiencies could have gone straight into long term contracts with no one the wiser until a whistleblower or analyst stumbled over the gap.

    What The Screen Misses By Design

    The pre-award reviews have one unavoidable limitation, in that the OIG does not review every pharmaceutical proposal that comes through the Federal Supply Schedule door. For fiscal year 2025, it examined 16. The broader VA FSS pharmaceutical portfolio is bigger than that, and the OIG is candid that it selects high risk, high value targets rather than running a universal check.1

    The individual pre-award reports remain confidential. The public does not see which manufacturers needed corrections or which contracting officers accepted, modified, or ignored OIG pricing recommendations. The $24.7 million in savings for 2025 is a documented floor, the confirmed amount that VA obtained after the reviews. How much was recommended but not sustained, as in 2024 when $54.9 million in potential savings yielded $36.8 million in actual reductions, is not broken out for 2025 in the public record.4

    What the record does say is simple enough. The VA is the largest buyer of prescription drugs in the federal system. The OIG reviews only a fraction of the proposals, and roughly two thirds of those examined contain problems in mandatory pricing disclosures. The screen catches something. It does not catch everything.

    Why Veterans Should Care Who Gets The Best Price

    Veterans health care spending is not an abstraction on a chart. The VA pharmaceutical budget comes from public money and buys medicines for people who served in uniform. When a manufacturer submits an inaccurate Commercial Sales Practices disclosure on a contract worth hundreds of millions or billions of dollars, and the OIG flags it before award, that is oversight doing its job.

    When about 69 percent of the proposals the OIG reviews contain deficiencies, year after year, that is the oversight system sending a message. The pre-award review program itself is relatively small compared with the volume of contracts it could examine. The path to catching more overcharging before it happens is not complicated. It involves more reviews, more often, with the same unglamorous insistence on accurate data.

    The harder question is how to get accurate disclosures from the start. The summary reports, properly, stay out of that policy fight. They just present the numbers and leave the rest to the people who decide how much risk they are willing to run with other peoples medicine.

    For more on VA oversight and institutional accountability, see Paying for Nothing — on how the VA paid $11.2 million for Veterans Crisis Line backup services never delivered — and The VA Knows How to Help Pregnant Veterans. It Isn’t Doing It Consistently. — on where the maternity care coordination program holds up and where it frays.