Jeffery K. Armstrong, 52, of South Riding, Va., was sentenced today to 18 months in prison for obtaining more than $100,000 in salary payments by fraudulently holding concurrent jobs at the United Nations (U.N.) and the National Labor Relations Board (NLRB). He was ordered to serve a three-year term of supervised release following his sentence and to pay $128,153 in restitution.

Armstrong was convicted by a federal jury on October 21, 2011, on nine counts of wire fraud. He was indicted on June 28, 2011, by a federal grand jury in the Eastern District of Virginia for his scheme to defraud the U.N., an international organization committed to humanitarian and peace-keeping efforts, and the NLRB, an independent agency of the U.S. government.

According to evidence presented in the trial, in March 2008, Armstrong took a leave of absence from his position as a supervisory security specialist with the Department of the Army to accept a full-time position at the U.N. As an assistant chief of the Security and Safety Service at the U.N., Armstrong was responsible for all physical security of U.N. facilities in New York City, among other functions. According to evidence at trial, Armstrong received an annual salary from the U.N. of approximately $160,000. In February 2009, after working at the U.N. for almost a year, Armstrong applied for a position as chief of the security branch within the Division of the Administration at the NLRB in Washington, D.C. In April of 2009, Armstrong became a full-time employee at the NLRB, with an annual salary of approximately $121,000.

From approximately April to September 2009, Armstrong was an employee of both the U.N. and the NLRB. Armstrong concealed his dual employment from both employers by, among other things, dissuading NLRB personnel from contacting his supervisor at the U.N., submitting incomplete or inaccurate employment forms to the NLRB, and causing to be mailed to the NLRB false correspondence suggesting that he no longer worked at the U.N. In addition, Armstrong submitted medical leave documentation to the U.N., indicating that he was unable to work and was undergoing medical treatment, despite his full-time employment at the NLRB. According to the evidence presented at trial, Armstrong failed to notify his superiors at both entities of his concurrent employment and received more than $100,000 in concurrent salary.

One underlying issue that seems to be overlooked is the fact that the employers in this case, the U.N. and the NLRB, may have been somewhat negligent in failing to follow up on the information Armstrong was providing to them. As a chief of the security branch at the NLRB, one would think that past employers, including the U.N., would have been contacted rather than relying on paperwork provided by the potential employee. Further, the U.N. also appears to be negligent in failing to confirm whether Armstrong’s medical leave was valid. If both employers had acted diligently, Armstrong would not have been able to hold concurrent employment. If this was a civil case, these issues would be a larger factor in the case. However, in a criminal trial, negligence by others is hardly relevant as to whether a crime was committed.

The author of this blog is Erich Ferrari, an attorney specializing in Federal Criminal Defense matters. If you have any questions please contact him at 202-280-6370 or

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