Amanda Joy Quinn, a 42-year-old woman from Sisseton, South Dakota, was sentenced to 18 months in federal prison followed by three years of supervised release for embezzling over $107,000 from the Long Hollow District of the Sisseton-Wahpeton Oyate Sioux Tribe.
The sentencing took place on November 14, 2024, in Aberdeen, South Dakota, and was presided over by U.S. District Judge Charles B. Kornmann.
From June 2017 through July 2020, Quinn, who had been elected Treasurer of the Long Hollow District, processed checks from the district's bank account and authorized overpayments to herself and others. She then negotiated the checks in her name and kept the cash. Quinn admitted to the scheme during her change of plea hearing, acknowledging that she was not entitled to the money and that her actions were unlawful.
In addition to her prison sentence, Quinn was ordered to pay $100 as a statutorily required special assessment to the Federal Crime Victims Fund.
This case was part of the Guardians Project, a federal law enforcement initiative aimed at coordinating efforts between various agencies to combat public corruption, fraud, and embezzlement involving federal program funds, contracts, and grants. The investigation was conducted by the U.S. Attorney's Office and the FBI.
https://www.justice.gov/usao-sd/pr/sisseton-woman-sentenced-federal-prison-embezzlement-and-theft-violation and https://www.mykxlg.com/news/local/sisseton-woman-sentenced-to-18-months-for-embezzling-over-107-000-from-tribal-organization/article_c5bbf528-a6d2-11ef-a84e-87a1abd1228c.html and https://www.gowatertown.net/sisseton-woman-sentenced-on-federal-embezzlement-charge/
Commentary
Quinn had the authority to write and sign checks on behalf of the district. Her scheme was to authorize overpayments to herself or to vendors. For example, if a legitimate payment to an approved vendor was $500, she might write a check for $1,000.
Quinn would then negotiate the checks in her name. This means she deposited or cashed the checks at a bank, effectively converting the checks into cash.
After negotiating the checks, she kept the excess cash for herself and paid what was due to the vendor. This was the embezzlement part of the scheme, where she unlawfully took money that belonged to the district.
Preventing schemes like Quinns takes a concerted effort by organizations. Below is a checklist on how to prevent internal embezzlement:
- Develop, distribute, and enforce a policy promoting honesty and integrity and prohibiting embezzlement and employee theft. Have all employees acknowledge in writing the receipt of and understanding of the policy
- Develop and enforce standards of checks and balances regarding allocation of resources via checks including signature authority and when and for what amounts multiple signatures are required
- Avoid providing signature authority to one person without oversight and frequent review
- Limit access to blank checks
- Prohibit issuing checks with blank fields
- Prohibit and prevent the printing of checks without authorization
- Prohibit employees from writing checks to themselves or endorsing checks personally
- Prohibit employees from using checks to pay for personal expenses
- Prohibit employees from holding checks for customers/clients or vendors
- Prohibit employees from accepting post-dated checks from other employees for cash or goods without authorization
- Strictly limit the number of employees with the authority to write or sign checks
- Closely monitor and limit access to signature stamps
- Consider prohibiting the use of signature stamps on checks issued from the organization's accounts and/or over a certain amount
- Investigate any unauthorized and excessive use of signature stamps
- Prohibit employees from endorsing checks to themselves or using any organizational checks to pay personal bills
- Keep track of and account for all blank organizational checks
- Perform due diligence on all employees with check signature authority, including criminal background checks
- Do not provide signature authority or check management authority to employees with a history of embezzlement, fraud, or other fidelity crimes
- Create a system of oversight so multiple people can view and/or oversee how checks and other negotiable instruments are utilized
- Train employees on your organization's standards for accepting/rejecting checks and, if applicable, other negotiable instruments
- For tracking of access to online bill paying systems, do not permit sharing of identities. Require each person with access to have his/her own unique user ID and password
- Train employees to secure their online identities and organization bill paying systems, including auto-pays from checking accounts and not writing down, changing, sharing, and/or employing weak passwords
- If possible, use cameras to visually record all register transactions including accepting payments via check
- Review video footage when investigating reasonable suspicions of check fraud
- Disclose to employees that all transactions are visually recorded
- Use an up-to-date accounting software program
- Make certain that your accounting software or equivalent records all transactions including tracking all check transactions as well as checks printed, deleted, and/or altered
- Use an up-to-date and secure online bill paying system that allows your organization to easily and safely monitor all transactions, including online payments via check and wire transfer as well as all auto-pay transactions
- Make certain your online banking services allows your organization to monitor when checks are cashed, the amounts for the checks, and provides images of the front and back of every cashed check
- Require that receipts be offered for any purchase and/or transaction
- Promptly investigate all complaints from customers, employees, or others regarding not being offered a receipt or altered checks paid to your organization
- Ensure different employees are involved in different aspects of managing organization finances including tracking account receivables and payables
- Provide a means for employees and others to report suspicions of wrongdoing - including charges of forgery, employee embezzlement and/or theft - easily, safely, and without retaliation
- Consider a third-party mechanism for employees and other workplace participants to anonymously report suspicions of wrongdoing, including check fraud
- Investigate all suspicious or unusual check activity or suspicions of forgery or fraud in a timely and professional manner
- If an investigation is warranted, use a person trained in investigating employee crime, theft, or embezzlement and/or a person experienced in forensic accounting
- If embezzlement or fraud is detected or reasonably suspected, consult legal counsel immediately
- Do not terminate a person or make accusations of embezzlement, fraud, or other fidelity crimes without seeking information from law enforcement and advice from an attorney