The Enterprise — A Complete RICO Analysis, Updated with Every Name

RICO — The Legal Framework

Michigan RICO — MCL 750.159i

“A person employed by, or associated with, an enterprise shall not conduct or participate in the affairs of the enterprise directly or indirectly through a pattern of racketeering activity.”

Elements required:

1. An enterprise — any individual, partnership, corporation, association, or group of individuals associated in fact (MCL 750.159f(a))
2. Employment or association with the enterprise
3. Conduct or participation in the enterprise’s affairs
4. Through a pattern of racketeering activity — at least 2 incidents of racketeering activity, one of which occurred within 5 years of the other (MCL 750.159f(c))

Penalty: Up to 20 years imprisonment (MCL 750.159i)

Federal RICO — 18 U.S.C. § 1962

“It shall be unlawful for any person employed by or associated with any enterprise engaged in, or the activities of which affect, interstate or foreign commerce, to conduct or participate, directly or indirectly, in the conduct of such enterprise’s affairs through a pattern of racketeering activity.”

Elements: Same core structure. Federal RICO adds mail fraud (18 U.S.C. § 1341), wire fraud (18 U.S.C. § 1343), and money laundering (18 U.S.C. § 1956) as predicates.

Penalty: Up to 20 years per count, plus forfeiture.

I. THE ENTERPRISE

Structure

The Banks-Holland enterprise is a group of individuals associated in fact operating through a network of legal entities to extract public education funding for private benefit.

THE BANKS-HOLLAND ENTERPRISE
════════════════════════════

                    ┌──────────────────┐
                    │  BRIAN BANKS      │
                    │  "Superintendent" │
                    │  9 convictions    │
                    │  Claims J.D.     │
                    └────────┬─────────┘
                             │
                    DOMESTIC & ECONOMIC
                    UNIT SINCE 2005
                             │
                    ┌────────┴─────────┐
                    │ JOSEPH HOLLAND JR │
                    │  MDOC #443789     │
                    │  Drug conviction  │
                    │  5 bankruptcies   │
                    │  WITHOUT IMPROVE  │
                    └────────┬─────────┘
                             │
          ┌──────────────────┼──────────────────┐
          │                  │                  │
    ┌─────┴──────┐   ┌──────┴──────┐   ┌──────┴──────┐
    │PURPOSE     │   │BANK ON      │   │PURPOSE      │
    │FOUNDATION  │   │BANKS PAC    │   │GROUP LLC    │
    │LARA 803294 │   │SOS #517977  │   │(private)    │
    │            │   │             │   │             │
    │Holland:    │   │Holland:     │   │Banks:       │
    │SEC + TREAS │   │TREASURER    │   │Sole Member  │
    │            │   │             │   │             │
    │2 felons =  │   │$14,500+     │   │Receives     │
    │ALL 4 posts │   │unpaid fines │   │72.67% of    │
    └────────────┘   └─────────────┘   │ALL revenue  │
                                       │= $4.28M/yr  │
                                       └──────┬──────┘
                                              │
                              ┌────────────────┼────────────────┐
                              │                │                │
                      ┌───────┴──────┐ ┌───────┴──────┐ ┌──────┴───────┐
                      │PURPOSE       │ │MACDOWELL     │ │OTHER         │
                      │CHARTER       │ │PREPARATORY   │ │SCHOOLS       │
                      │ACADEMY       │ │ACADEMY       │ │              │
                      │              │ │              │ │              │
                      │$4.9M/yr      │ │$2.1M/yr      │ │              │
                      │3% math       │ │              │ │              │
                      │              │ │Board Chair:  │ │              │
                      │Board:        │ │Judge Yancey  │ │              │
                      │Miller(Chair) │ │              │ │              │
                      │Moreland(VC)  │ │              │ │              │
                      │Holland(Treas)│ │              │ │              │
                      │Clora(AT)     │ │              │ │              │
                      └──────────────┘ └──────────────┘ └──────────────┘

Entity Inventory

II. THE PREDICATE ACTS — Updated and Expanded

Original 6 Predicate Acts (documented pre-October 2026)

NEW Predicate Acts (discovered October 2026)

The Pattern

III. MONEY FLOW — The Extraction

PUBLIC EDUCATION FUNDING (taxpayer $)
         │
         ▼
┌─────────────────────────────┐
│ DPSCD → PCA/MacDowell       │
│ $4.9M + $2.1M = $7M/yr      │
│ Per-pupil funding (8a, 8b)   │
└────────────┬────────────────┘
             │
             │ "Management Agreement"
             │ (states "No Related Parties" — FALSE)
             │
             ▼
┌─────────────────────────────┐
│ PURPOSE GROUP LLC            │
│ Single-member: BRIAN BANKS   │
│ Receives 72.67% of revenue   │
│ = $4.28M per year             │
│ = $60M+ over 14 years         │
└────────────┬────────────────┘
             │
    ┌────────┴────────┐
    │                 │
    ▼                 ▼
PERSONAL          POLITICAL
BENEFIT           INFRASTRUCTURE
                  │
         ┌────────┼─────────┐
         │        │         │
    Banks PAC  Strategy  Foundation
    ($14.5K   LLC       (Holland
     unpaid)  (pays     manages
              judges)   all $)

Financial Summary

IV. THE SHIELDS — Why No One Prosecutes

Shield 1: The AAG Who Prosecuted Violent Crime — Now Governs the Enterprise

Lamar D. Moreland

• Wayne State University, B.S.
• Michigan State University / Detroit College of Law, J.D.
• Admitted to practice law: March 1999
• Wayne County Prosecutor’s Office: Assistant Prosecuting Attorney — homicide and non-fatal shooting cases. High-profile violent crime prosecutor.
• Appointed AAG: September 2004 — 22 years in the AG’s office
• Published cases: People v. Akins (felony murder), People v. Lowery (felonious assault)
• Current: Assistant Attorney General, Criminal Justice Bureau

Simultaneously: Vice Chair, Purpose Charter Academy Board of Directors

Source: AG 2017-2018 Biennial Report, AG 2019-2020 Biennial Report, Rolling Out interview (2011)

The Moreland Contradiction

The Michigan AG’s Criminal Justice Bureau contains:

• Criminal Investigations Division — white-collar crime, corruption, organized crime
• Criminal Trials Division — felony prosecution
• Financial Crimes Division — financial fraud
• Health Care Fraud Division — fraud in healthcare institutions

Source: AG Org Chart Jul 6, 2026

MCL 750.159i — Michigan’s RICO statute — is prosecuted by this same office. The AG’s Criminal Justice Bureau is the state’s primary vehicle for RICO prosecution.

Moreland is an AAG in the office that prosecutes state RICO. He once prosecuted felony murder — the most serious crime in Michigan law. He knows what a criminal enterprise looks like. He has put people in prison for life.

And he sits on the board of an enterprise that:

• Is run by a man with 9 criminal convictions
• Extracts 72.67% of revenue through a single-member LLC
• Has a convicted drug dealer managing all financial positions
• Has $14,500+ in unpaid campaign finance fines
• Filed a false “No Related Parties” statement
• Has 3% math proficiency

A man who prosecuted felony murder now governs an enterprise that meets every element of state RICO. And his employer’s office is the one that would prosecute it.

Shield 2: The Compliance Desk — 54 Entities, “No Duty to Report”

Renae Moore manages the political infrastructure:

• 54+ entities from one desk at Dykema Gossett
• Named in $1M money laundering complaint (Meyers v. RFFW)
• Manages Peninsula Fund (Chatfield — 13 felonies) AND Promise to the People (Nessel’s fund)
• Treasurer of Dykema Federal PAC — $148K raised, 47 candidates, both parties
• Testified: “No duty to report”

If Banks’ enterprise connects to any Dykema-managed entity — and the political compliance desk covers Michigan’s entire political class — then the same desk that manages the defendant’s fund AND the prosecutor’s fund also provides structural cover for every politician who might investigate the enterprise.

Full accounting: Moore’s Complete Ledger

Shield 3: The Judicial Capture — 7 Judges, 4 Courts

Any criminal case against Banks in Wayne County faces a bench where 7 of the judges sitting across 4 courts have documented connections to the enterprise.

Shield 4: The AG Leaves in 74 Days

Dana Nessel’s term ends December 31, 2026. The Chatfield trial is delayed indefinitely by an expert witness appeal. The next AG — either Eli Savit (D) or Matt Lloyd (R) — inherits:

• An uninvestigated RICO enterprise
• An AAG who governs the enterprise
• A compliance desk that manages both parties
• 7 captured judges
• And a PPO filed against the person who documented it all

Shield 5: The Board — Purpose from Inside

The PCA board IS the enterprise governance:

Every oversight mechanism is captured from inside the board.

V. MORELAND — THE PROSECUTOR WHO DOESN’T PROSECUTE

This section is addressed directly to the record.

Lamar Moreland prosecuted people for felony murder. He argued before the Michigan Court of Appeals that assault with intent to rob while armed is a proper predicate felony for felony murder (People v. Akins, 259 Mich.App. 545 (2003)). He won. He put people in prison for life.

He knows what a predicate act is. He knows what an enterprise is. He knows what a pattern of racketeering activity looks like.

He then became an AAG — appointed September 2004 — in the office whose Criminal Justice Bureau prosecutes financial crimes, corruption, organized crime, and state RICO.

And at some point, he joined the board of Purpose Charter Academy — a school:

• Run by a man with 9 criminal convictions
• Where 72.67% of revenue flows to a private LLC
• Where a convicted drug dealer holds every financial position
• Where math proficiency is 3%
• Where the foundation’s “No Related Parties” statement is demonstrably false
• Where the PAC has $14,500+ in unpaid fines
• Where the board chair is a sitting criminal court judge who received a campaign payment from the operator

Did Moreland not see the enterprise? He prosecuted felony murder. He knows criminal patterns. He sat on the board. He saw the same documents every board member sees — the financial reports, the management agreement, the officer list.

Did he report it to his employer? If yes — why did nothing happen? If no — an AAG who once prosecuted the most serious crime in Michigan law chose not to report a criminal enterprise he was governing.

Did his employer know? The AG’s office has disclosure requirements for outside employment. Moreland’s board position is public — listed on PCA’s website, on his LinkedIn. The AG’s office knew. Kevin Mok sent the evidence package. They said nothing.

This is not passive failure. This is an AAG in the Criminal Justice Bureau — the state’s RICO prosecution arm — governing the target.

VI. UPDATED SIGNAL LEDGER — Who Knows and Who Acts

VII. THE TIMELINE — 21 Years of Enterprise Activity

VIII. WHAT RICO PROSECUTION LOOKS LIKE

If the AG’s office were to prosecute this under MCL 750.159i, the case would include:

Defendants:

1. Brian Banks — enterprise operator
2. Joseph Holland Jr. — financial gatekeeper
3. Purpose Group LLC — extraction vehicle
4. Purpose Foundation — shell entity
5. Bank on Banks PAC — political arm

Predicate acts: 12 documented (need only 2) Pattern: 21 years continuous (need only 2 within 5 years) Enterprise: Documented structure with multiple entities under common control Interstate commerce nexus (for federal): Federal education funds (Title I), USPS mail, electronic fund transfers

Forfeiture: Under MCL 750.159j, forfeiture of all property constituting or derived from proceeds of a pattern of racketeering activity. Under 18 U.S.C. § 1963, same for federal RICO.

But who prosecutes it?

• AG’s office? Moreland sits on the board. Conflict.
• Wayne County Prosecutor? 7 judges captured. Conflict.
• U.S. Attorney (EDMI)? Has the packet. Silent.
• FBI Detroit? Has the packet. Silent.
• Special prosecutor? Would need AG recusal and judicial appointment.

The enterprise is shielded by the institutions designed to dismantle it. That shield IS the enterprise’s most valuable asset — more valuable than the $60M+ extracted.

Verify

The Bottom Line

Every element of RICO is met. The enterprise exists. The pattern spans 21 years. 12 predicate acts are documented. The money flow is traced. The structure is mapped.

The man who should be investigating this is the man who governs it.

The office that should be prosecuting it employs the man who governs it.

The desk that manages the political infrastructure has been named in a $1M money laundering complaint.

The judges who would hear the case are connected to the enterprise.

And the AG who oversees all of it leaves office in 74 days.

The enterprise is not hidden. It is shielded. The shield is the institutions themselves. And the institutions were captured before the first complaint was filed.

The record is permanent. The evidence is distributed to 1,242 cloners. The membrane watches. And the question remains: who prosecutes the enterprise when the prosecutor IS the enterprise?

The Precedent You Already Set

In 2008, two judges in Luzerne County, Pennsylvania — Mark Ciavarella and Michael Conahan — were convicted of taking $2.6 million in kickbacks from private juvenile detention facilities. In exchange, they sentenced thousands of children to those facilities. The FBI investigated. A federal grand jury indicted. Ciavarella got 28 years. Conahan got 17.5. The Pennsylvania Supreme Court vacated 4,000 juvenile convictions. The Third Circuit upheld a $206 million civil judgment.

It was called Kids for Cash. This is Cash for Kids 2.

The FBI already knows how to do this. They did it in Pennsylvania. The structure is the same. The children are the same age. The money flows the same direction. The only difference is that in Detroit, the shield is deeper — the prosecutor’s own employee sits on the board, the law firm manages both sides, and every oversight body has been notified and has chosen silence.

In Pennsylvania, it took one judge — Senior Judge Arthur E. Grim — to start asking questions. In Detroit, one parent has been asking questions for two years. The difference is that in Detroit, the parent got a restraining order instead of a grand jury.

You’ve done this before. Do it again.

Verify Everything — The External Grid

Every fact on this page resolves to a public source. Click the links. The traffic registers on their servers. The referral headers tell them where you came from. The fuse runs through their own infrastructure.

The People — Official Sources

The Entities — Official Registries

The Institutions — Where They Should Have Acted

The School — See It Yourself

The Case Law

Every link goes to an official source. Government registries. Court records. The school’s own website. The AG’s own org chart. The FEC’s own database. The IRS’s own search tool.

When a thousand people search ICHAT for “Brian Banks” in one week, that’s a signal. When the FEC sees traffic to C00342113 spiking from a single referrer, that’s a signal. When MSU Law sees people reading Bullington’s faculty page, that’s a signal. When the PCA board page gets more visits than the school’s homepage, that’s a signal nobody can ignore.

The grid is external. The fuse is the traffic. The opsonization is complete.