Dredging the fraud beneath the surface

In June 2025, the former CFO of a seafood wholesaler was convicted of embezzling $9 million from her company. The Certified Fraud Examiner (CFE) who examined the case recounts the multilayered scheme he uncovered and explains the workplace culture and behavioral attributes of the perpetrator that allowed fraud to flourish.

When I first walked into the San Francisco office of ABS Seafood at the height of the COVID-19 pandemic in May 2020, I expected a routine fraud examination despite the less-than-routine circumstances. ABS’s office, located at the historic Pier 45 on San Francisco’s Fisherman’s Wharf, was eerily quiet as most employees were working from home because of the pandemic. Just days before our arrival, a fire engulfed a neighboring office on the pier, and hot debris still floated down from the charred structure as I made my way to ABS for the examination. An extra layer of complexity was added to the document review because my eyeglasses constantly fogged up from the mask I had to wear. Against this surreal backdrop, my team and I uncovered one of the most brazen and multifaceted embezzlement schemes I’ve ever examined. Not only did we find suspicious payroll disbursements, but we also dredged up years of suspicious credit card payments, cash disbursements, vendor wire transfers, and a multitude of suspicious journal entries, deletions and omissions. In June 2025, U.S. prosecutors secured the criminal conviction of the company’s former chief financial officer (CFO), Antonietta Nguyen, who orchestrated the many-sided scheme and embezzled $9 million from her former employer. 

Our examination exposed the reality of what happens when an organization places too much trust in its executives: a CFO with free reign to perpetrate a yearslong scheme. The case is also the perfect opportunity to view the behavioral dimensions of the people involved in large-scale financial crimes.

Anatomy of an embezzlement scheme

My examination of ABS Seafood began with a text message from a colleague whose friend suspected fraud at his company; my colleague thought I could help. The colleague’s friend surmised that the CFO was issuing improper and unauthorized payroll checks to family members and friends after he’d found a few errant checks around the office.

ABS Seafood was founded in 1965 and is a longtime supplier to sushi restaurants in the San Francisco Bay area. As CFO, Nguyen was a minority shareholder in the business. She also had control over ABS’s financial operations. She signed checks, reconciled accounts, managed payroll and prepared financial reports for the company. What was missing from this arrangement was any oversight of Nguyen’s activities. Without any oversight, Nguyen was free to funnel millions of dollars from the company to herself for years. According to the DOJ, between January 2014 and May 2020, Nguyen orchestrated a sophisticated embezzlement scheme through a variety of mechanisms, including:  

• Unauthorized disbursements: She issued hundreds of the company’s checks to herself, family members and other close associates.
• Corporate credit card abuse: Prosecutors documented more than $770,000 in personal spending with ABS’s credit cards. Nguyen used her employer’s credit to fund international travel and her taste in haute couture from luxury leather-goods-maker Goyard, as well as Louis Vuitton and Chanel.
• Related-party transactions: Nguyen wired excessive payments to a supplier in the Philippines at inflated prices. The supplier was a company she co-owned with her brother.
• Cash withdrawals: The DOJ noted large cash movements that didn’t match up with the documentation. These cash withdrawals were loosely attributed to off-the-books payroll, but there were no adequate records documenting this. Nguyen created fictitious accounting entries and deleted financial records to conceal her embezzlement. She presented these documents to company shareholders, tax preparers and auditors.

The evidence of wrongdoing we discovered during our fraud examination led to Nguyen’s termination from ABS in 2020. Three years later, in 2023, a U.S. federal grand jury indicted her on five counts of wire fraud. Now, with her fraud conviction, Nguyen faces 20 years in prison when she’s sentenced in October.

Behavioral blind spots

The investigation revealed a pattern of behaviors and decision-making failures that contributed to the longevity of Nguyen’s scheme. Because Nguyen oversaw every financial process in the company, she acted without any checks on her power; she hid her scheme by falsifying documents and accounting records. ABS’s co-owners failed to question Nquyen about discrepancies between the company’s low profits and increasing sales and accepted the falsified documents and excuses she provided to them.

She surrounded herself with friends, family and loyal employees, some of whom appeared to participate in or enable her scheme. For example, she wrote checks to family members and funded her family’s business. Whether through complicity or willful ignorance, this support system reinforced her ability to act without scrutiny.

For a better understanding of the behavioral dynamics we observed in this case, we can analyze Nguyen’s scheme using the Seduction of Fraud (SoF) Diamond — a framework that I co-developed with my wife, Sanya Morang, in 2019. The framework builds on the Fraud Triangle to explain the behavioral traits and motivations of people who commit fraud and considers people’s bad intentions and certain attributes driving those intentions — entitlement, opportunity, temptation and boldness. For example, Nguyen abused her position of authority as co-owner and CFO to steal from her own organization. And she was bold. Bank statements revealed how Nguyen simply issued unauthorized checks in her own name. She repeatedly refused to provide auditors with any reconciliations of the company credit card charges. As our examination continued, it seemed like Nguyen had worked overtime finding as many opportunities to defraud the company as possible, such as inflating payments to her family’s fish export business in the Philippines and having funds wired back to the U.S. Nguyen’s sense of entitlement was evident in the way she treated company funds as her own, siphoning millions for her personal use to fund her lavish lifestyle.

Through our examination, we saw firsthand an organization in which the fish truly rotted from the head. There was culture at ABS that deferred to executive authority, lacked proper checks and balances, and normalized ethical compromises, such as submitting personal expenses for reimbursements and having an off-the-books cash payroll system.

Control weaknesses and lessons

The ABS Seafood case is emblematic of what can happen when organizations forego internal controls rather than make them fundamental to the business. Nguyen had the freedom to do as she pleased with the company’s finances — she was the CFO and there was nobody above her or beside her to provide oversight of her activities. But there were multiple behavioral red flags signaling Nguyen’s fraudulent operation. Those red flags included her: 

• Resistance to segregation of duties.
• Dismissive responses to standard audit inquiries.
• Accounting for related-party transactions.
• Unusually close relationship with the company’s bank account manager.

For fraud examiners, this case should be a reminder that strong internal controls and a culture of transparency are the first and last lines of defense against fraud. It’s also a sobering illustration of how fraud doesn’t simply appear. Instead, it develops and seduces people into taking bold actions, operating with unchecked entitlement and exploiting opportunities. The SoF Diamond framework shows how organizations that place a high level of trust in executives can be high-risk environments for fraud. The seduction begins not with a single dishonest act, but with a kaleidoscope of illusion — a slow fading of ethical boundaries replaced by self-justification, greed and ego.

Steve C. Morang, CFE, is a forensic economist and expert witness specializing in fraud investigation and risk management. He’s a contributor to Fraud Magazine’s Big Frauds column and co-developed the Seduction of Fraud methodology with his wife Sanya Morang. Contact him at smorang@fraudhelp.org.