Don't they mean, "Hershey Highway"?
L/E might consider:
(a) conspiracy to defraud the IRS (stolen money is taxable),
(b) international money laundering,
(c) conspiracy to commit money laundering, and,
(d) aiding and abetting the preparation of false federal/state income tax returns,
(e) evading US banking laws.
Authorities might examine federal documents to verify falsifications (a felony); bogus allocations to gay groups (kickbacks); multiple conspiracies and transfers of funds as part of a money-laundering conspiracy.
Government audits might show off-the-books bank accounts that were accessed solely by insiders, and that government-funds were used in various illegal schemes that might have integrated:
(1) money laundering,
(2) tax evasion (stolen money is taxable),
(3) violations of US banking and currency laws,
(4) conspiracy to commit wire fraud,
(5) commercial bribery in various financial schemes,
(6) establishing secret offshore bank accounts outside the purview of the IRS and US banking laws,
(7) fraudulent and casual accounting practices,
(8) non-existent financial oversight,
(9) Having a hidden financial interest in companies faking business with Jennings,
(10) Putting phantom employees on the payroll (money laundering).
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Other crimes might include forgery, extortion, healthcare fraud, govt fraud and electronic/postal fraud, falsifying documents, making false statements to government officials, and concealment of facts on government documents.
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Was the Safe Schools Office using the Madoff MO: establishing a super-secret labyrinth of interrelated international funds, institutions and financial entities of almost unparalleled complexity and breadth......with assets and businesses in multiple places overseas that hid thievery, money laundering and tax evasion.
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Jennings might have been running simultaneous scams using govt funds:
(1) a tax evasion scheme for his gay buddies;
(2) a money-laundering scam;
(3) a protection racket for gay groups,
(4) aiding and abetting tax-exempt Gay foundations to evade US banking laws and the IRS.
(5) hiding govt money offshore, some of which was used for campaign donations (FEC fraud).
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REPORT SUSPECTED GOVT FRAUD HERE
FBI TIP PAGE http://tips.fbi.gov/ (you may remain anonymous)
Report US Postal Fraud:
EMAIL PAGE https://postalinspectors.USPIS.gov
REPORT GOVT FRAUD AND ILLEGAL CONVERSIONS OF GOVT FUNDS
Enforcement@SEC.gov
REPORT SUSPECTED TAX FRAUD HERE
IRS TOLL-FREE 1-800-829-0433----you may remain anonymous.