Investment promoter and attorney charged with laundering Ponzi money through lawyer trust accounts
Federal prosecutors in Georgia allege an attorney passed investor money through his client trust accounts to keep two Ponzi schemes going. Both men are presumed innocent.
A federal grand jury indicted Roosevelt Tobias "Toby" Bailey, 70, of Duluth, Georgia, and Alvin Jones, 58, of Tampa, Florida, on 22 September 2026, the US Attorney's Office for the Northern District of Georgia announced on 20 October 2026. The office describes Jones as a former prosecutor and current practicing attorney. The charges are allegations, and both men are presumed innocent unless proven guilty.
Prosecutors allege that from about October 2018 through October 2022, Bailey ran two Ponzi schemes through his company, Borg Global. A Ponzi scheme pays earlier investors with money from newer investors. One program claimed it would pool investor money to buy precious stones and metals outside the US and resell them in the US at a higher price. The other, a standby letter of credit (SBLC) program, promised returns of up to 16 times the principal within 30 to 90 days.
Prosecutors allege Bailey directed investors to send money to Jones's interest on lawyer trust accounts (IOLTA), which are meant to hold client funds in trust. Jones allegedly sent the money, at Bailey's direction, to Bailey's personal and business accounts and to earlier investors to keep the schemes going, and kept a portion for himself. Bailey allegedly received nearly $2 million in investor funds and stopped communicating with investors in October 2022.
Bailey is charged with seven counts of wire fraud, one count of money laundering conspiracy and three counts of money laundering. Jones is charged with one count of money laundering conspiracy and three counts of money laundering. Bailey was arrested and arraigned on 16 October 2026 and Jones on 20 October 2026. The FBI investigated the case with help from the SEC.
Why it matters to AML professionals
Lawyers' client trust accounts can make investment money look legitimate and hide who it really belongs to. AML professionals at banks that hold these accounts need to understand the expected activity and question flows that look like investment collections rather than legal work.
Red flags in this case
- Investor payments sent to a lawyer's client trust account with no clear legal matter behind them
- Promised returns far above normal, such as several times the principal within weeks
- Trust account outflows to a promoter and to other investors soon after new deposits arrive
- Investment offers built on leasing, trading or monetizing bank instruments such as standby letters of credit
If this landed in your queue
- Ask the account holder to explain the clients and legal matters behind large trust account inflows
- Map deposits from many individuals against payments out to one promoter and to earlier depositors
- Check the promoter, the company and the lawyer for adverse media, regulatory actions and complaints
- Escalate and file a SAR that describes the trust account flows and the investment claims made to depositors
Key terms
- IOLTA
- Interest on lawyer trust account: a bank account a lawyer uses to hold client money in trust.
- Ponzi scheme
- A fraud that pays earlier investors with money from newer investors instead of real profits.
- Standby letter of credit (SBLC)
- A bank's promise to pay if its customer fails to meet an obligation; it is a guarantee, not an investment product.
Interview angle
Why are professional gatekeepers such as lawyers a money laundering risk?
Explain that client trust accounts and professional status can give illicit funds a look of legitimacy and hide the real owners. Describe how you would test whether trust account activity matches real legal work.
Sources
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