United States v. Frank Citro

Visa International, Mastercard International, and Bank of America’s Office of Corporate Security discovered an inordinate amount of counterfeit credit card use in the Las Vegas area and worked out an agreement with the Las Vegas Metropolitan Police Department to investigate local merchants for possible collusion in a counterfeit credit card scheme. The police department hired Michael Milano to act as a liaison in introducing undercover officers to merchants willing to accept counterfeit cards. Milano had a prior conviction for operating a counterfeit credit card scheme, but was working as a police informant.

Milano began frequenting a particular lounge where he met the defendant, Frank Citro, and the two became good friends. Milano eventually raised the idea of a scheme involving counterfeit credit cards and collusive merchants and explained to Citro how the credit card scheme might operate. There was evidence at trial that Citro suggested he might know of some merchants who would be willing to accept counterfeit credit cards. Milano told Citro that he had a partner, “Troy Hill” (who was in reality undercover police officer Edward Schaub), who actually possessed the counterfeit…