SAN FRANCISCO (NewsNation Now) — Federal prosecutors charged Texas billionaire Robert Brockman on Thursday with a $2 billion tax fraud scheme. The DOJ says it is the largest tax evasion case against an American.

Department of Justice officials said at a news conference that Brockman, 79, hid capital gains income over 20 years through a web of offshore entities in Bermuda and Nevis and secret bank accounts in Bermuda and Switzerland. Prosecutors announced that the CEO of a private equity firm that aided in the schemes would cooperate with the investigation.

The 39-count indictment unsealed Thursday charges Brockman, the chief executive officer of Ohio-based software company Reynolds and Reynolds Co., with tax evasion, wire fraud, money laundering, and other offenses.

Reynolds & Reynolds issued a statement saying the allegations were outside Brockman’s work with the company and that the company is not alleged to have participated in any wrongdoing.

Brockman appeared in federal court from Houston via Zoom Thursday. He entered a plea of not guilty to all counts and was released on $1 million bond, said Abraham Simmons, spokesman for the Northern District of California.

“Complexity will not hide crime from law enforcement. Sophistication is not a defense to federal criminal charges,” said David L. Anderson, U.S. attorney for the Northern District of California. “We will not hesitate to prosecute the smartest guys in the room.”

According to the U.S. Department of Justice, Brockman is charged with:

• Conspiracy
• Seven counts of tax evasion
• Six counts of failing to file foreign bank account reports
• 20 counts of wire fraud affecting a financial institution
• Two counts of concealment money laundering
• Tax evasion money laundering
• One count of international concealment money laundering
• One count of evidence tampering
• One count of destruction of evidence