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“Such operations, albeit not purposeful, may impugn the company’s reputation and potentially subject Evolution to heightened regulatory scrutiny and the imposition of sanctions,” the report continues.
In the dossier, Spectrum unpacks Evolution’s review and vetting processes for potential clients. At the time of the report, Evolution required clients to provide certification of the beneficial ownership of 25% or more of the company. But Spectrum says it was not using “a viable process” as some documents provided by companies could be inaccurate.
“If red flags become known to Evolution during this onboarding process, Evolution should either determine not to do business with the company or undertake enhanced due diligence to resolve the red flags before engaging in business with the company,” Spectrum advises.
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According to the arrest warrant affidavit, law enforcement began investigating Pietras after an employee with a third-party company that assists funeral homes in managing and administering funeral contracts notified police about possible discrepancies at Pietras Family Funeral Homes in Coventry. Such funeral trust administrators partner with funeral homes to provide various programs, including trust funds, insurance policies, and escrow account management.
Law enforcement investigators uncovered a mountain of alleged theft. As the news spread, clients began requesting escrow statements, only to find that their funds were never deposited.
Prosecutors alleged that Pietras was stealing the funeral money to fund his gambling addiction. Law enforcement found that Pietras made more than 800 casino trips over a 14-year period.