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Federal prosecutors are seeking to recoup roughly $17 million meant for Native Hawaiian charitable causes that they allege was embezzled to pay for polo, homes in Hawaii and Florida, and other personal expenses of the late founder of Hawaiian Native Corp., according to federal court records.
Christopher Mailani Hookaamomi Dawson killed himself Dec. 19 at 12:46 p.m., 18 months after federal agents raided Hawaiian Native Corp.’s Fort Street Mall offices in June 2023.
His death did not end a federal criminal investigation into the alleged conspiracy to embezzle millions from the company he founded in 2004.
Between 2008 and 2023, Dawson’s companies received $892,386,181 in federal contracts to do U.S. Department of Defense and other federal work, including facility design, construction, maintenance, renovation and demolition; engineering and environmental services; and information technology and cybersecurity.
In a Nov.6, 2023, federal court filing unsealed last week and an amended complaint filed Nov. 10, the U.S.Department of Justice detailed how Dawson and his enablers at his companies allegedly stole money from federal contracts to buy homes in Hawaii and Florida and pay for Dawson’s personal expenses.
According to the filing, records from Dawson company accounts at American Savings Bank for January 2015 through November 2021 show that the total amount of money credited to Christopher Dawson from Dawson subsidiaries and HNC was over $17 million, nearly “double what the companies credited to HNC, the parent NHO.”
“There is no indication that Dawson Group provided any goods or services to HNC or Dawson in exchange for that money,” according to federal court records.
The forfeiture filing focuses on four properties, three in Hawaii and one in a Wellington, Fla., equestrian community allegedly bought with money pulled directly from Dawson companies’ and NHC’s profits.
Between 2017 and 2021, records show Dawson bought property on Equine Lane in Florida for $1,455,055; spent $1,333,450 on a Lokoea Place property in Haleiwa; shelled out $3,598,543 for a beachfront estate on Papailoa Road; and paid $1,425,000 for a property at 1118 Ala Moana Boulevard.
Federal prosecutors argue that the properties and money pulled from the Dawson companies’ profits were the result of “wire fraud” and “theft concerning a federally funded program.”
Dawson, who played polo for more than 30 years, was president and founded the Hawaii International Polo Association in 2013. He traveled the world playing, investing in and promoting polo through his company Hawaii Polo Life, which hosted the Hawaii Spring Invitational of Polo in Mokuleia.
Dawson, according to his former company website, was dedicated to supporting the Native Hawaiian community through “philanthropy, his business enterprises, and his work to teach Hawaiian history and culture through the lens of polo.”
The seven Dawson companies operated under the HNC umbrella were part of the U.S. Small Business Administration’s 8(a) Business Development Program, which was created to provide support to small, disadvantaged businesses, “particularly with gaining access to the federal marketplace,” according to the Native Hawaiian Organizations Association, a trade association “established to provide a unified voice for Native Hawaiian Organizations (NHOs).”
In a joint statement to the Honolulu Star-Advertiser, Allen K. Hoe, an attorney and board chair of HNC; and Dave Johnson, CEO and President of Dawson; said the company “took swift action to suspend and later terminate” Christopher Dawson.
Dawson, his family members and accused enablers were removed from the company in 2023 and the board and executive leadership were reconstituted in a manner approved by the SBA.
“In relation to certain polo and other assets Mr. Dawson owned, HNC has attempted to recover and liquidate all such assets so that the proceeds can be properly directed in accordance with SBA 8(a) regulations. HNC is working to resolve this matter with representatives of the Chris Dawson estate,” said Hoe and Johnson. “HNC understood that DOJ had taken certain actions against properties owned by Mr. Dawson, one of which HNC repossessed in 2023. Now that those actions appear to be proceeding, HNC expects to coordinate with DOJ on the eventual sale of those properties so that the proceeds can be properly directed.”
An NHO company can have an “unlimited number of for-profit subsidiaries that may receive an unlimited number” of direct-award government contracts of infinite value.
Dawson Technical, Dawson Federal, Dawson Solutions, Dawson Enterprises, Dawson Global, D7, B&H Contracting, Five Three Two Three Concepts, and Aktarius were “required to transfer 100% of the profits they generated” to HNC for use on Native Hawaiian charitable causes, according to federal prosecutors.
“The government’s investigation, including interviews with multiple former Dawson employees, has revealed that the Dawson companies obtain (government) contracts via the SBA 8(a) program, bill the contracts, and then spend the money on activities unrelated to giveback to Native Hawaiians or to Dawson or HNC’s business activities,” Assistant U.S.Attorney Sydney Spector wrote in November 2023.
Authorities accuse Dawson, with assistance from Bryan Hara, the Chief Financial Officer, of using “money from the Dawson companies to cover Mr. Dawson’s personal spending, which included purchasing various real properties (as well as other luxury items), in violation of SBA guidelines,” and Dawson and Hara’s fiduciary duties.
Dawson, “through Mr. Hara and others,” fraudulently accounted for non-allowable personal expenses as general and administrative expenses, which prosecutors say were at times passed on to the federal government via his federal contracts.
According to federal court records, HNC and Dawson executives used shell companies and hollow invoices to “circumvent compensation limitations imposed by the SBA 8(a) program” and to divert Dawson and HNC funds to themselves.
The shell companies were allegedly controlled by Dawson, and ex-executives including Hara, and Billy Cress, the former president and chief operating officer of Dawson.
The federal investigation showed that Dawson “intercepted significant portions of the proceeds generated by DAWSON’s participation in the 8(a) program” rather than pass them on to HNC and Native Hawaiian charitable causes.
“He did so through direct transfers to his personal accounts, purchase of real property in his own name, payment of business and personal credit card charges for personal expenditures, and use of shell companies, such as Dawson Group, Inc.,” wrote Spector.
These transfers were in addition to the salaries he collected from HNC, the Dawson operating companies, and his 100% ownership of Dawson Group, according to federal prosecutors.
“The investigation revealed also that Mr. Dawson failed to report as income on his tax returns large amounts of revenues diverted from HNC and Dawson,” according to federal court records.
Hara served as Dawson’s “financial manager, having authorized and executed many of the transfers” from HNC and Dawson to Christopher Dawson and his shell companies,” and for Mr. Dawson’s real property purchases, according to federal court records.
“Mr. Hara often instructed the CFOs of Dawson (subsidiaries) when and where to send funds for Mr. Dawson’s benefit,” wrote Spector. “In short, the investigation revealed Mr. Dawson and his associates abused the SBA 8(a) program to perpetuate a fraud scheme and embezzlement that victimized HNC and Native Hawaiians — the intended beneficiaries of the HNC and its participation in the SBA 8(a) program.”
Small businesses owned by Native entities such as NHOs, tribes and Alaska Native corporations are authorized to participate in the SBA 8(a) program under special rules and have access to no-bid federal contracts.
While the rules differ depending on the entity, the intent of the SBA 8(a) program is to provide native communities with the ability to develop self-sufficient economic ventures by using profits to improve the plight of their communities.
“HNC did not commit any fraud, waste or abuse against the federal government and its agencies,” said Hoe and Johnson.” In fact, HNC’s workforce of more than 1,500 employees across all 50 states continues to perform a wide array of construction, environmental, operations and maintenance, and professional services contracts nationwide for federal agencies that consistently rate their performance highly.”
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