The Office of the Comptroller of Puerto Rico (OCPR) requests your advice regarding the alleged fraud scheme committed by various persons against the Municipality of San Juan (the Municipality). The Municipality has recovered only $ 1.8 million of the $ 9 million invested in instruments that promised to guarantee the principal and generate an approximate annual return of 10%. OCPR is interested in your recommending the best alternative for the Municipality to recover the loss of $ 7.2 million of its municipal funds ($ 9 million - $ 1.8 million).

Required:

(a) What is the best alternative available for the Municipality to recover the loss caused by this fraud? Your response should include your reasons for the recommended alternative and identify what person or persons would the Municipality be taking these actions against?