By late 2009, after U.S. banks and financial institutions detected and shut down multiple fraudulent bank
accounts used by the Poker Companies, SCHEINBERG and BITAR developed a new processing strategy that would not involve lying
to banks. PokerStars, FullTilt Poker, and their payment processors persuaded the principals of a few small, local banks
facing financial difficulties to engage in such processing in return for multi-million dollar investments in the banks. For
example, in September 2009, ELIE and others approached defendant JOHN CAMPOS, the Vice Chairman of the Board and part-owner of
SunFirst Bank, a small, private bank based in Saint George, Utah, about processing Internet poker transactions. While expressing
"trepidations," CAMPOS allegedly agreed to process gambling transactions in return for a $10 million investment in SunFirst
by ELIE and an associate, which would give them a more than 30% ownership stake in the bank. CAMPOS also requested and received
a $20,000 "bonus" for his assistance. In an e-mail, one of ELIE’s associates boasted that they had "purchased" SunFirst and
that they "were looking to purchase" "a grand total of 3 or 4 banks" to process payments.