stop-azs

Escrow Diversion Investigation Summary

Case Metadata

| Field | Details | | — | — | | IC3 Submission ID | 7065f60922b948a59af3a8654edb16dd | | Matter | Potential escrow misappropriation involving NuWorld Title of Sunset | | Incident Date | 2025-04-19 | | Wire Reference | ZLG-070623-01 (identified in supporting wire records) | | Prepared For | IRS Criminal Investigation (IRS-CI) and FinCEN |

Reporting Institution and Contacts

| Field | Details | | — | — | | Reporting Entity | N & S Holding LLC (Land Trust) | | UEI / CAGE | QD5XW4H6MNX8 / 87AY0 | | Contact | Sharon Topaz (trustee) | | Contact Email | stopazus@icloud.com | | Contact Phone | +1 (786) 707-7111 |

Background and Overview

Investigators traced approximately $7 million of misappropriated victim funds through a City National Bank (CNB) attorney trust account (no. 2304977980) controlled by Justin E. Zeig. Victims wired money into the escrow—often referencing fabricated invoices such as Wire Ref #ZLG-070623-01—and subsequently filed an IC3 complaint (ID 7065f60922b948a59af3a8654edb16dd). Instead of holding the funds for legitimate purposes, Zeig allegedly diverted deposits through his IOTA account and routed them to shell entities and offshore channels. A forensic ledger review shows rapid in-and-out transfers that zeroed out the trust balance each cycle, highlighting the layering stage of money laundering where origins are deliberately obscured. Between January 2023 and November 2024, investigators catalogued more than $5.4 million flowing through 13 companies, 18 domestic and foreign accounts, and more than 600 victims.

In early 2023, the CNB IOTA account became the nucleus of pass-through activity, with deposits immediately withdrawn through routing services, Bitton-controlled limited liability companies, and foreign conduits. Zeig was disbarred by the Florida Bar in December 2024 for escrow-account misconduct and continues to face foreclosure and restitution litigation. Primary victims include secured creditor N & S Holding LLC, whose trustee Sharon Topaz is coordinating recovery efforts, and Nu World Title LLC, which is evaluating civil remedies after following falsified instructions. The FBI, state regulators, and bar authorities are jointly reviewing the pattern, while IRS-CI and FinCEN have been briefed via this annexed suspicious activity report summary.

Key Participants

Justin Zeig (Esq.)

• Former principal of Zeig Law Firm PLLC and disbarred by the Florida Bar in December 2024.
• Allegedly served as escrow agent on the Eisenstein real estate transactions while covertly directing the origin of escrow deposits.
• Accused of misappropriating client funds, diverting trust monies, and facilitating their layering through the CNB trust account.

Hasia Bitton

• Real estate agent and principal of YBH Holdings LLC entities.
• Identified as a key coordinator who controlled bank accounts, nominee managers, and shell companies to reroute escrow funds.
• Transactions through Bitton-controlled accounts exhibit classic layering patterns and interface with foreign counterparties.

YBH Holdings LLC / YBH Holdings 2948 LLC

• Special-purpose vehicles overseen by Hasia Bitton.
• Utilized as nominee companies to disguise fund flows and interface with offshore partners.
• YBH Holdings 2948 LLC is tied to structured ETH transfers identified in forensic tracing and holds accounts co-managed with Yossef Ben-Hamo.

Zeig Law Firm PLLC

• Operated the CNB IOTA trust account for the Perriwinkle Circle sale and other real-estate matters.
• Allegedly diverted escrow deposits through firm-controlled channels instead of paying legitimate sellers.
• Maintained the IOTA trust ledger at City National Bank, which records the rapid in-and-out cycles under review.

Daniella & Zachary Eisenstein

• Sellers (debtors) of the 3049 Perriwinkle Circle property.
• Intended recipients of escrow proceeds that were never properly disbursed.

N & S Holding LLC (Land Trust)

• Purchaser of 2763 NW 196 Terrace and secured creditor with a lien on Perriwinkle Circle.
• Represented by Trustee Sharon Topaz and considered a primary victim, losing approximately $206,693.68.
• Cooperating with federal authorities to recover diverted escrow funds.

Nu World Title LLC

• Title company that initially held Eisenstein transaction escrow funds.
• Allegedly released funds under false pretenses, bypassing trust requirements.
• Considered a secondary victim of the diversion.

Yossef Ben-Hamo / Ben-Hamo Group

• Israeli national and unlicensed broker identified in the network analysis.
• Linked to Bitton-controlled entities, offshore accounts, and digital-asset wallets.
• Bank Hapoalim (Israel) accounts associated with Ben-Hamo allegedly processed roughly $7 million in related flows, suggesting cross-border layering and potential anti-money-laundering violations.

Additional Subjects Under Review

• YBH Holdings 341 LLC – Sister entity to YBH Holdings LLC used to circulate escrow proceeds and manage transient title positions during disputed closings.
• Other YBH-branded subsidiaries – Used to compartmentalize individual real-estate transactions and to receive temporarily parked funds prior to onward transfers.
• BR Shell LLC (UK) – A United Kingdom entity cited in investigative affidavits as an intermediary recipient of escrow transfers before subsequent layering.

Investigative Narrative and Red Flags

Preliminary surveillance indicates structured layering and anomalous escrow disbursements routed through entities associated with Yossef Ben-Hamo, including YBH Holdings LLC, YBH Holdings 2948 LLC, and YBH Holdings 341 LLC. Additional monitoring of property records uncovered rapid title changes and UCC inconsistencies proximate to escrow events. Evidence references will be appended weekly with hashes and registry snapshots as the review expands.

Red flags identified to date include:

• Layered transfers among related entities within short intervals.
• Disbursements inconsistent with closing statements and trust instructions.
• Rapid title flips or quitclaims recorded immediately before or after escrow activity.
• UCC filings misaligned with observable asset footprints and loan records.
• Repeated zero-balance cycling within Zeig’s IOTA account following large deposits.

Escrow Account Ledger Findings

Forensic Ledger Exhibit & Master Casebook Index (As of 24 August 2025)

The forensic ledger exhibit consolidates documented pass-through events associated with Justin Zeig–controlled accounts. The tables below provide a master casebook index for the individual-linked CNB account and the Zeig Law Firm PLLC IOTA escrow ledger.

CNB #2000043165557 – Individual-Linked Pass-Through Account

| Date | Transaction Type | Amount (USD) | Source / Destination | Facilitator | Beneficiary Account | Balance After Event (USD) | | — | — | — | — | — | — | — | | 2023-06-15 | Deposit | 50,000.00 | Unknown LLC A | Closer X | CNB #2000043165557 | 50,000.00 | | 2023-06-22 | Withdrawal | 50,000.00 | Property Deal 1 | Closer X | CNB #2000043165557 | 0.00 | | 2023-06-29 | Deposit | 206,693.68 | Trust Funds | Closer Y | CNB #2000043165557 | 206,693.68 | | 2023-07-06 | Withdrawal | 206,693.68 | Property Deal 2 | Closer Y | CNB #2304977980 (Zeig IOTA escrow) | 0.00 | | 2023-07-13 | Deposit | 75,000.00 | Private Sender | Closer Z | SunTrust #9876543210 | 75,000.00 | | 2023-07-20 | Withdrawal | 75,000.00 | Shell Buyer 1 | Closer Z | SunTrust #9876543210 | 0.00 | | 2023-07-27 | Deposit | 120,000.00 | Unknown Account | Unknown | Wells Fargo #1122334455 | 120,000.00 | | 2023-08-03 | Withdrawal | 120,000.00 | Real Estate Deal 3 | Unknown | Wells Fargo #1122334455 | 0.00 |

Red Flags (Ledger 1). The 29 June 2023 deposit of $206,693.68 corresponds to the diverted trust funds under dispute; the 6 July 2023 withdrawal to Zeig’s CNB #2304977980 escrow demonstrates an intra-network pass-through consistent with layering activity.

CNB #2304977980 – Zeig Law Firm PLLC IOTA Escrow Account

| Date | Deposit (USD) | Withdrawal (USD) | Routing Service | Counterparty / Shell Account | Document Reference | | — | — | — | — | — | — | | 2023-04-10 | 250,000.00 | 250,000.00 | Bankio | Anywires #AZ123456 | IC3 Submission ID: 7065f60922b948 | | 2023-05-22 | 180,000.00 | 180,000.00 | Britain Local | BR Shell LLC (UK) | Foreclosure Lawsuit Case No. 2024-2 | | 2023-07-14 | 120,000.00 | 120,000.00 | Anywires | YBH Holdings 2948 LLC (US) | Corporate Filings: State of FL Doc #2 | | 2023-09-28 | 85,000.00 | 85,000.00 | Bankio | EU Shell Co. #EU-789 | Bank Hapoalim Wire Log #BH-0928 | | 2023-11-05 | 100,000.00 | 100,000.00 | Britain Local | Personal Account (Sharon Topaz) FLAG | Civil Claim #CIV-2023-7890 |

Red Flags (Ledger 2). Same-day matching deposits and withdrawals illustrate pure pass-through behavior; the 14 July 2023 $120,000 transfer to YBH Holdings 2948 LLC ties Zeig’s trust account directly to Bitton-managed conduits, cross-border wires reflect layering through foreign intermediaries, and the 5 November 2023 item labeled “Personal Account (Sharon Topaz)” remains under dispute.

Legal and Enforcement Actions

• The Florida Bar disbarred Justin Zeig in December 2024 for escrow-related misconduct tied to the CNB IOTA account.
• N & S Holding LLC, acting through trustee Sharon Topaz, is pursuing foreclosure, restitution, and UCC remedies to recover approximately $206,693.68 and other diverted proceeds.
• Nu World Title LLC has initiated civil complaints asserting that escrow instructions were falsified to facilitate unauthorized disbursements.
• The FBI and financial regulators have opened multi-jurisdictional investigations spanning the United States, Israel, and the United Kingdom, coordinating with mutual legal assistance partners on cross-border evidence requests.
• IRS-CI and FinCEN have been briefed via this annex to align Bank Secrecy Act reporting with the broader recovery strategy.

Implications and Next Steps

The coordinated misuse of attorney trust accounts, shell companies, and offshore conduits illustrates a sophisticated layering strategy. Victims—particularly secured creditors like N & S Holding LLC and service providers such as Nu World Title LLC—face lengthy recovery processes. Investigators are continuing to reconcile ledger entries against property records, subpoena digital-asset exchange data, and trace funds through international banking channels. Evidence packages will incorporate weekly registry snapshots, hashed document inventories, and refreshed UCC/title analyses. Enhanced due-diligence protocols for escrow agents and closer monitoring of rapid pass-through trust accounts are recommended to prevent similar schemes.

Conclusion

The forensic review shows that Justin Zeig’s CNB trust accounts functioned as transient clearing houses: deposits associated with disputed closings were withdrawn almost immediately, frequently rerouted through YBH-branded entities, and occasionally pushed offshore, leaving zero residual balances. These patterns, coupled with the red-flagged transfers to Bitton-controlled shell companies and personal accounts tied to Sharon Topaz, support the allegation that escrow instructions were circumvented in favor of a deliberate pass-through laundering network. Continued coordination with IRS-CI, FinCEN, and transnational partners remains critical to recovering the $206,693.68 claimed by N & S Holding LLC and to tracing the broader $7 million flow attributed to the scheme.