The bank fraud charges were related to the unlawful withdrawals and transfer of money from the accounts of the victims.

The money was then withdrawn, the bulk of it sent to Benson and a small portion kept by the co-conspirators as payment for the services provided.

Hansen contacted Benson through Clark to offer him this personal information, claiming they were mortgage leads.

Officers arrested Benson and executed a consent search of his home where they found fraudulent ID documents, credit cards, and skimmers as well as photographs of Clark and the other co-defendants, Hansen and Thao.

In Blockburger v. United States, 284 U.S. 299 (1932), it was confirmed that multiple punishments for convictions that fall under separate statutes do not violate the double jeopardy clause.

The motion of judgment of acquittal was denied, citing Chase [2] applying the same standard of review to the district.

During the trial, the district court brought up a case from 2001 where Clark pleaded guilty for identity theft.

The court concluded that evidence of prior bad actions was in fact admissible under exceptions of rule 404(b)[3] of the Federal Rules of Evidence for limited purposes such as intent, knowledge or absence of mistake as long as it was relevant to a material issue.

Since Clark presented a defense that he acted in good faith when depositing these checks, his knowledge and intent were considered an issue.

Citing Ruiz-Estrada,[4] the court stated that they would only reverse the decision when such evidence had no bearing on the case and was primarily being used to prove that the defendant had the propensity to commit a criminal act.

Previously only credit granting agencies who suffered monetary losses were considered victims.

One of the largest most sophisticated identity theft cases in the US involved 111 people who used skimming devices to swipe and steal consumer credit card information at retail and food establishments.

Companies are taking advantage of security information and event management systems in conjunction with large data mining and pattern identification techniques to reduce the risk of financial fraud.

[11] Banks have employed real-time monitoring based on rule based engines however due to the dynamic nature of fraud, the bank's own fraud trends, the customer's patterns and the exchange of data between financial institutions has to be just as flexible.