• Photograph from Nelson’s daughter’s Instagram page

• Depicts Littlest Pet Shop toy and a comment indicating that she was returning home that day

• Based on a review of the credit card statements for Credit Card 1, as well as the records from the Sagamore Resort and other records, this post is consistent with her and her father, Nelson, being present at the Sagamore resort at a time consistent with the illegal charges reflected on the statements for Credit Card 1

Total Expenditures: $3,523.55

• Photograph from Nelson’s daughter’s Instagram page

• Depicts a black purse with contents, includes a comment indicating that she is going to Hersey and Gettysburg

• Based on a review of credit card statements for Credit Card 1, as well as records obtained from Hershey Lodge and other records, this post is consistent with Nelson and his family being in Hershey Park during the time when Credit Card 1 was used to illegally charge hotel and other expenses

Total Expenditures: $4,313.12

• Photograph from Nelson’s daughter’s Instagram page

• Depicts Nelson’s children standing in front of a Hershey Park sign, including a comment indicating she was at Hershey Park and heading to Gettysburg

• Based on a review of credit card statements for Credit Card 1, as well as records obtained from Hershey Lodge and other records, this post is consistent with Nelson and his family being in Hershey Park during the time when Credit Card 1 was used to illegally charge hotel and other expenses

Total Expenditures: $4,313.12

• Photograph from Nelson’s public Instagram page

• Depicts a knife, including a comment that the knife was one of the entries at the Blade Show convention

• Based on a review of the credit cards statements, this post is consistent with Nelson’s presence at the blade show in 2015, as well as his purchase of knives that he illegally charged to Credit Card 1

Total Expenditures: $2,814.35

• Photograph from Nelson’s public Instagram page

• Depicts two knives that Nelson apparently purchased, including a comment indicating that he purchased them at the Blade Show

• Based on a review of the credit cards statements, this post is consistent with Nelson’s presence at the blade show in 2015, as well as his purchase of knives that he illegally charged to Credit Card 1

Total Expenditures: $2,814.35

• Photograph from Nelson’s Public Instagram page

• Depicts a knife Nelson apparently purchased at the 2016 Blade Show, including a comment indicating he purchased it there

• Based on a review of the credit cards statements, this post is consistent with Nelson’s presence at the blade show in 2016, as well as his purchase of knives that he illegally charged to Credit Card 1

Total Expenditures: $4,045.28

• Photograph from Nelson’s Facebook account

• Depicts Nelson, his wife, and others at Heinz Stadium on December 28, 2014

• A review of the credit card statements for Credit Card 1 and records obtained from Tickets now reveals that in November 2014, Nelson ordered the tickets and charged the costs to Credit Card 1

Total Expenditures: $3,292.32

DOI determined based on financial analysis that Nelson misappropriated RCDA funds using two agency AMEXcards for personal expenditures:

Based on vendor records, social media activity and Nelson’s agency computer, DOI identified corroborating information linking Nelson to the majority of these charges:

All Deemed Suspicious Transactions

Amex 41004 $ 423,766

5/29/2005 - 12/28/2016

Amex 41005 17,496

1/29/2010 - 12/28/2016

Total $ 441,262

All Corroborated Suspicious Transactions

Amex 41004 $ 327,645

2/1/2009 - 12/28/2016

Amex 41005 16,306

2/1/2009 - 12/28/2016

Total $343,951

• Personal expenditures reflected on the AMEX credit card statements included domestic andinternational trips for Nelson and his family, jewelry, handbags, clothing, premium whiskey,collectible knives, and survival equipment.

Total by Category of All Deemed Suspicious Transactions TOTALS

COLLECTOR KNIVES $ 113,239.26

AMAZON VARIOUS (jewelry, clothing, camping, video games, knives, comics) 99,089.44

TRAVEL (lodging, airfare, restaurants, excursions, souvenirs) 72,259.68

OTHER (household, grocery, toys, sundries, restaurants, facebook, unknown PayPal) 49,967.45

PAYPAL PAYMENTS TO WILLIAM NELSON 24,702.60

COMICS/COLLECTIBLES 15,094.72

SPORTING EVENTS/MEMORABILIA 15,051.41

CLOTHING 12,118.93

SURVIVAL/CAMPING 11,864.47

ELECTRONICS 10,109.93

VIDEO GAMES/MOVIES/RADIO 8,286.69

JEWELRY 5,603.89

ALCOHOL 3,873.83

Grand Total $ 441,262.30

Total by Category of All Corroborated Suspicious Transactions TOTAL

COLLECTOR KNIVES $ 103,004.26

AMAZON VARIOUS (jewelry, clothing, camping, video games, knives, comics) 99,089.44

TRAVEL (lodging, airfare, restaurants, excursions, souvenirs) 59,020.16

PAYPAL PAYMENTS TO WILLIAM NELSON 24,702.60

OTHER (household, grocery, toys, sundries, restaurants, facebook, unknown PayPal) 16,902.11

SPORTING EVENTS/MEMORABILIA 13,970.43

COMICS/COLLECTIBLES 12,579.61

VIDEO GAMES/MOVIES/RADIO 4,909.98

JEWELRY 4,463.88

CLOTHING 2,917.01

SURVIVAL/CAMPING 2,327.19

ELECTRONICS 63.92

Grand Total $ 343,950.59

Total by Year of All Deemed Suspicious Transactions YEAR ANNUAL TOTALS

2006 $ 184.24

2007 195.08

2008 465.83

2009 13,987.09

2010 21,810.80

2011 19,455.18

2012 33,322.39

2013 62,407.80

2014 75,837.27

2015 116,486.31

2016 97,110.31

Grand Total $ 441,262.30

Total by Year of All Corroborated Suspicious Transactions

YEAR ANNUAL TOTAL

2009 $ 13,662.11

2010 20,533.19

2011 14,646.13

2012 22,665.01

2013 36,995.78

2014 58,263.89

2015 96,862.92

2016 80,321.56

Grand Total $ 343,950.59

Nelson used the RCDA AMEX account to transfer money to his personal PayPal account in excess of $159,000, which was used for the following charges: • Transfers to personal checking account - $12,000;• Payment made out to William Nelson - $24,703;• Personal purchases - $123,149 (mostly knives and collectible action figures).

Nelson’s charged personal travel expenses to the RCDA AMEX card inclusive of the following:• Two trips to the UK -$10,631;• Five trips to the Lansdowne golf course in Virginia -$ 20,308;• Three trips to Walt Disney World-$6,795;• Hershey Park-$2,294;• Sagamore Resort in New York -$3,524;• Monaco Hotel in Philadelphia-$2,019;• Jefferson Hotel in Richmond -$1,917;• Manor Club at Fords Colony Williamsburg-$1,476.

Nelson used the RCDA AMEX card to charge more than $13,836 in tickets to sporting events including:

• Coaches Club tickets for a Giants/Patriots game - $7,191;

• Steelers/Bengals games - $3,351.

Nelson purchased over $99,000 in personal items from Amazon which were shipped to his home address including:

• Stainless steel propane gas grille - $2,068;

• Vintage GI Joe action figures and Star War collectibles - $2,619;

• Ferragamo, Movado and Gucci watches - $8,552;

• Various sporting equipment, Luxury handbags, survival and camping gear, electronics, jewelry and comic books.

• Chief Fiscal Officer did not conduct monthly reviews of agency card usage

• Chief Fiscal Officer improperly delegated approval authority to subordinates

• Nelson had AMEX statements sent to his RCDA email address and concealed the statements to avoid any review

City Agency Budgets assign various billing object codes to track source of funds for expenditures

Object Code 460 used for confidential expenditures such as witness protection, paid informants and surveillance operations

• Donovan objected to Audit on grounds that investigations could be compromised

• Nelson spending spikes after Donovan letter to Comptroller

• RCDA failed to conduct its own audit

• Nelson’s credit card purchases exceeded the purchase thresholds as set forth by the Comptroller

• Failure to review spending by budget code, and to note significant increases or decreases in spending

• Failure to segregate duties

• Director of Procurement has authority to make purchases

• Director of Procurement has authority to approve purchases

• Purchases made via two RCDA American Express (“AMEX”)credit cards

• Nelson had sole access to the AMEX credit card account

• According to Nelson’s supervisor, Nelson’s wife liked nice things and could not handle money

• Nelson was close to Donovan and did not like DA McMahon

• Nelson was demoted in June 2016 after NY Post article published about McMahon spending

• When asked at time of arrest why he “did it” he responded

• “BECAUSE I COULD”

• Political Sensitivities

• Determining if there were coconspirators

• Ability to confirm hotel stays-video identification

• Time Constraints –potential move to Pennsylvania

• Volume of Vendor Subpoenas

• The fact that Subject remained on payroll

• Jurisdictional Venue

• Determining if Agency received Federal Funds

• Pled guilty to theft of government funds

• Awaiting sentencing

• Conviction carries a possible 30 year sentence