3:12-cr-00271-JFA Date Filed 03/29/12 Entry Number 2 , Page 1 of 3

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF SOUTH CAROLINA
COLUMBIA DIVISION
UNITED STATES OF AMERICA
v.
RACHEL DUNCAN
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CRIM. NO. 3: 12-271
26 U.S,.C. 7206(1)
18 U.S.C. 1343
INFORMATION
THE UNITED STATES ATTORNEY CHARGES:
COUNT 1
1. RACHEL DUNCAN was employed by the South Carolina Hospitality Association
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(The Association) from May 2001 until February 2012, working as the Director of
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Accounting and Membership services.
2. From 2006 to 2012, RACHEL DUNCAN embezzled funds from The Association and its
affiliate organizations by writing checks to herself, which she deposited into her personal bank
account. RACHEL DUNCAN also embezzled funds by using The Association's point of sale credit
card terminal to refund the money to her own debit card after association members paid dues or fees.
In total, RACHEL DUNCAN embezzled approximately $480,944, which she used primarily for
online gambling in offshore entities.
3. Additionally, RACHEL DUNCAN acquired a NetSpend prepaid Visa card. RACHEL
DUNCAN transferred stolen funds from her own account to her NetSpend Visa card by using
Western Union and MoneyGram. RACHEL the NetSpend card to deposit funds
into her online gambling account, which she previously did by using her own bank account.
4. RACHEL DUNCAN electronically transferred funds from her own bank account at South
Carolina State Credit Union to various shell companies around the world which served as payment
processors for an Austrqlian online casino.
3:12-cr-00271-JFA Date Filed 03/29/12 Entry Number 2 Page 2 of 3
5. For tax: years 2006 to 2011, RACHEL DUN CAN electronically filed her own federal income
tax return from her computer located in South Carolina. RACHEL DUNCAN filed each tax: return
by fraudulently failing to report all of her illegal income to the IRS, namely the funds she stole from
The Association. Each federal tax: return was filed under. penalty of perjury.
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6. In the tax year of2010, in the District of South Carolina, RACHEL DUNCAN did willfully
make and subscribe a Tax: Return Form 1040, which was verified by a written declaration that it was
made under the penaities of perjury and filed with the Internal Revenue Service, which Tax: Return
Form 1040 she did not believe to be true and correct as to every material matter in that the Tax
Return Form 1040 reported her taxable income as $41,339, whereas she then and there well knew
and believed, her taxable income was substantially more than $41,339;
All in violation of Title 26, United States Code, Section 7206(1) .
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3:12-cr-00271-JFA Date Filed 03/29/12 Entry Number 2 Page 3 of 3
COUNT 2
THE UNITED STATES ATTORNEY FURTHER CHARGES:
1. Paragraphs 1 through 5 of Count 1 are incorporated herein by ,
2. On or about January 28,2011, in the DistriCt of South Carolina and, elsewhere, the
defendant, RACHEL DUNCAN, for the purpose of executing the scheme
and artifice to defraud, and to obtain money and 'property by means of false and fraudulent
pretenses, representations and promises, did cause to be transmitted in interstate commerce,
by means of a wire communication from a South Carolina State Credit-Union Account, in
South Carolina, to .. www.icpcard.com .. in Stockholm, Sweden, a company used to process
international wire transfers, in order to buy credit at an online casino located in Australia;
In violation of TitIe 18, United States Code, Sections 1343.
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