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Press Release

Former Bank Employee And Two Others Arrested For Involvement In Procurement Kickback Scheme

For Immediate Release
U.S. Attorney's Office, Southern District of New York
Bank Employee Accepted Nearly $900,000 in Kickbacks for Helping Vendor Secure Approximately $8.4 Million in Contracts with Bank

Geoffrey S. Berman, the United States Attorney for the Southern District of New York, and William F. Sweeney Jr., Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of Investigation (“FBI”), announced today the unsealing of a criminal complaint charging RICHARD WONG, GABRIELA BRATKOVICS, and EVAN BROWN with honest services wire fraud, bank fraud, bribery of a financial institution employee, and conspiracy, for their role in a kickback scheme designed to compensate WONG, an employee of a large financial institution, for ensuring that his employer continued to utilize the services of the information technology staffing company controlled by BRATKOVICS and BROWN.  WONG was arrested yesterday and presented before United States Magistrate Judge Katharine H. Parker.  BRATKOVICS and BROWN were arrested today and are expected to be presented before Magistrate Judge Parker this afternoon.

According to the allegations in the Complaint[1] unsealed yesterday in Manhattan federal court:

From 2011 through July 2018, WONG worked for a large financial institution (“Bank-1”) in procurement and was responsible for, among other things, managing relationships with certain vendors, negotiating contracts, reviewing requests for proposals, and requesting quotes for services.  Beginning in 2013, WONG was responsible for supervising Bank-1’s relationship with a company that provides temporary information technology staffing to corporate clients (“Company-1”).  BRATKOVICS and BROWN are the co-founders of Company-1; BRATKOVICS is the chief executive officer of Company-1, and BROWN is the chief financial officer of Company-1. 

Between in or about July 2013 and in or about December 2018, Bank-1 paid Company-1 in excess of $8.4 million for IT staffing services.  Between in or about January 2014 and in or about December 2018, BRATKOVICS and BROWN, acting on behalf of Company-1, caused approximately $891,000 to be transferred to WONG, in the form of cash, checks, and wire transfers; these payments were kickbacks, designed to compensate WONG for assisting Company-1 in securing Bank-1’s business and providing Company-1 with information about Bank-1’s procurement process.  Indeed, the total amount of each kickback payment was tied to the number of hours of Company-1’s services Bank-1 utilized during a particular time period, typically each month.

WONG, BRATKOVICS, and BROWN began discussing possible kickbacks approximately three months after Company-1 began providing services to Bank-1.  On or about October 8, 2013, WONG sent an email to BROWN, writing, in substance and in part, “Send me your spreadsheet on the 5 resources I gotten for you. . . .  And your proposal. . . .  Let’s get on the same page[.]”  Approximately two months later, on or about December 9, 2013, WONG emailed BROWN, copying BRATKOVICS, writing, in substance and in part, “Can you guys send me what you have so I can see the data . . . not saying I will want the money now . . . but want to see how it looks likes [sic][.]”

On multiple occasions, beginning in or about January 2014, BRATKOVICS, BROWN, and WONG exchanged emails discussing spreadsheets that appear to detail the names and hours worked by Company-1 staffers at Bank 1 for specified time periods.  At the bottom of the spreadsheets was a calculation that appears to determine how much Company-1 is to pay WONG in kickbacks for that period.  Throughout the period in which WONG was receiving kickbacks from Bank-1, Company-1 not only continued to provide services to Bank-1, but WONG also repeatedly provided BRATKOVICS and BROWN with information about Bank-1’s internal discussions regarding use of Company-1’s services by blind carbon copying them on emails. 

On or about April 30, 2018, WONG was notified by Bank-1 that his position had been eliminated.  Bank-1 continued to employ the services of Company-1 until in or about December 2018.  WONG continued to receive payments from accounts controlled by BRATKOVICS and Company-1 even after his employment was terminated, until in or about December 2018.

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A chart containing the names, charges, and maximum and minimum penalties for the defendants is set forth below.  The maximum potential sentences in this case are prescribed by Congress and are provided here for informational purposes only, as any sentencing of the defendants will be determined by the judge.

Mr. Berman praised the outstanding investigative work of the FBI in this case.

The case is being prosecuted by the Office’s Complex Frauds and Cybercrime Unit.  Assistant U.S. Attorneys Katherine Reilly and Dina McLeod are in charge of the prosecution.

The charges contained in the Complaint are merely accusations, and the defendants are presumed innocent unless and until proven guilty.


[1] As the introductory phase signifies, the entirety of the text of the Complaint, and the description of the Complaint set forth herein, constitute only allegations, and every fact described should be treated as an allegation.


Jim Margolin, Nicholas Biase
(212) 637-2600

Updated January 17, 2020

Financial Fraud
Press Release Number: 20-024