Houston tech mogul Robert Brockman has been indicted with the biggest individual tax charge in U.S. history.

The charges against the CEO of Reynolds & Reynolds, unsealed in federal court on Thursday, accused him of hiding $2 billion in income using a wide array of offshore accounts.

“The allegation of a $2 billion tax fraud is the largest ever tax charge against an individual in the United States,” U.S. Attorney for the Northern District of California David Anderson said at a Thursday news conference.

In total, Brockman has been brought up on 39 charges, among them counts of money laundering, conspiracy, wire fraud, and tax evasion.

Billionaire Robert Smith agreed to cooperate with the investigation of Brockman, giving authorities crucial information for his indictment. In return, Smith, who was also being investigated for evading taxes on a massive scale, was not given any criminal charges.

Smith is the CEO of Vista Equity Partners and has a net worth of $7 billion, making him the wealthiest black man in America. He will be asked to pay $139 million for his offenses.

“Complexity will not hide crime from law enforcement,” Anderson added. “We will not hesitate to prosecute the smartest guys in the room.”

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