Belize | Goal | Met

The scam was orchestrated by a group of individuals led by a repeat offender, Andris Pukke, along with Peter Baker and John Usher. Beginning around 2005, they marketed lots in a planned luxury development in Stann Creek, Belize, under various names including "Sanctuary Belize," "Sanctuary Bay," and "The Reserve."

Their sales pitch was highly deceptive and targeted retirees and small business owners. They used slick marketing materials, including television ads on channels like Fox News and Bloomberg, and telemarketing calls to lure in potential buyers. The key false promises included:

• Luxury Amenities: The development was advertised as a lavish resort community with amenities like a hospital staffed with American doctors, a golf course, an airport, a marina, and high-end boutiques and restaurants.
  
• "No-Debt" Business Model: They claimed to operate on a "no-debt" model, promising that every dollar from lot sales would be reinvested directly into the development. In reality, the money was funneled to the scammers to fund their extravagant lifestyles.
  
• Rapid Appreciation: Investors were told their lots would double or triple in value within a few years, and that reselling them would be easy. In fact, very little of the promised development was ever completed, and the lots were essentially worthless.
  

Pukke's involvement was particularly notable because he was already a known fraudster with a prior FTC case against him for a deceptive credit counseling service, AmeriDebt. He was even held in contempt and sentenced to prison for obstructing the AmeriDebt receivership. Despite a court order requiring him to turn over the Belize property, he maintained control of it and used it to launch the Sanctuary Belize scheme.

The Federal Trade Commission (FTC) began a year-long investigation and, in November 2018, took action by filing a complaint and obtaining a temporary court order to shut down the operation. The FTC's lawsuit was one of the largest overseas scams the agency had ever targeted.

A federal court in Maryland appointed a receiver to take control of the defendants' assets and the Belizean properties to freeze them and prevent further loss. The purpose of the receivership was to manage and liquidate the assets to provide restitution to the victims.

In the ensuing legal battle, the FTC charged the defendants with violating the FTC Act and the Telemarketing Sales Rule. A key aspect of the case was the FTC's ability to demonstrate a "common enterprise" among the defendants and their various companies, which allowed the court to hold them jointly and severally liable.

The case also had significant international dimensions. For the first time, the FTC sued a foreign bank, Atlantic International Bank Limited (AIBL), which had facilitated the scam. In a settlement, AIBL agreed to pay $23 million to the FTC and ceased operations.

In 2020, the court issued its verdict, finding in favor of the FTC and holding Pukke, Baker, Usher, and other corporate defendants liable. A $120.2 million judgment was issued against them

The Sanctuary Belize case is in the final stages of receivership, with ongoing efforts to provide restitution to the victims.

• Asset Sale and Restitution: After a lengthy process, the Sanctuary Belize and Kanantik properties were sold. A motion for approval of the sale to a company called First Belize Investment Market Ltd. (FBIM) for a total price of $20.5 million was granted by the court in May 2025. The sale was finalized in June 2025.
  
• Refunds to Victims: The first round of restitution payments was sent out to eligible consumers in August 2023. These initial payments were part of the funds recovered from various settlements. Following the completion of the asset sale in mid-2025, the receiver is working to satisfy remaining financial and legal obligations of the receivership and anticipates seeking court approval for the distribution of additional pro-rata redress payments to eligible victims.
  
• Legal Standing: The judgments against the defendants have been largely upheld on appeal. While a ruling in a separate case (AMG Capital Management, LLC v. FTC) limited the FTC's ability to seek monetary damages under one section of the law, the judgments in the Sanctuary Belize case were affirmed on other grounds, including contempt of a prior injunction, ensuring that the asset freeze and receivership could continue to pursue restitution for the victims.