Employee Benefit Solutions LLC (EBS)
Outcome
Anthony Riccardi, co-owner and EVP of Employee Benefit Solutions LLC in New Canaan, Connecticut pleaded guilty in February 2023 and was sentenced to 10 years in federal prison and $14.87 million restitution for orchestrating a $40 million scheme from 2015–2019 that stole client healthcare funds from a self-funded employee benefits program and diverted them to personal expenses including mortgage payments, boating, luxury cars, and golf.
Details
Employee Benefit Solutions LLC / Anthony Riccardi — $40 Million Client Healthcare Fund Theft (2023)
Outcome: Anthony Riccardi, co-owner and Executive Vice President of Employee Benefit Solutions LLC in New Canaan, Connecticut, pleaded guilty in February 2023 and was sentenced to 10 years in federal prison plus $14,870,653.36 in restitution and $2 million in forfeiture, for leading a $40 million scheme from 2015 through 2019 that stole client healthcare funds entrusted to his firm as a third-party administrator for self-funded employee health plans.
Employee Benefit Solutions LLC (EBS) operated as a third-party healthcare claims administrator (TPA) in New Canaan, Connecticut, serving clients who elected to "self-fund" their employee healthcare benefit plans. Under this arrangement, employer clients deposited healthcare funds with EBS, which was supposed to administer, process, and pay healthcare claims to medical providers on behalf of the clients' employees in exchange for an administrative fee. Riccardi, as 50% co-owner and Executive Vice President, held a fiduciary position over these client funds.
From 2015 through 2019, Riccardi and his co-conspirators used EBS as a vehicle to steal the healthcare funds that employer clients had deposited in trust. In a documented example involving an automobile dealership chain headquartered in Westchester County, New York, EBS served as the TPA for the dealership's self-funded employee healthcare program. Instead of paying legitimate healthcare claims to medical providers, Riccardi and his co-conspirators used the dealership's healthcare funds to pay Riccardi's personal home mortgage, fund a personal credit card account, and cover personal expenses related to boating, luxury automobiles, and golf.
Former employees and managers of EBS were separately charged in a related $17 million fraud scheme involving the same conduct. Riccardi's 10-year sentence reflected the severity of the breach of fiduciary duty, the scale of the fraud, and the harm to employer clients and their employees who lost access to healthcare benefits they believed were funded.
Primary Source: DOJ SDNY — Owner of Insurance Firm Sentenced to 10 Years for $40 Million Scheme
How Crucible Prevents This
Crucible's instinct-observer hook would detect the pattern of client healthcare fund distributions that deviated from standard healthcare claims payment workflows. The pre-tool-check hook would enforce client fund segregation controls requiring documented healthcare provider payment verification before any disbursement. The quality-gate would flag disbursements from client healthcare escrow accounts that matched personal expense categories (mortgage, luxury purchases) rather than healthcare provider payees.
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