as they typically come from a generation that was more trusting, and are often too proud to report the fraud. They also may be concerned that relatives might see it as a sign of declining mental capacity, and they are afraid to lose their independence. Victims can be enticed to borrow or embezzle money to pay the advance fees, believing that they will shortly be paid a much larger sum and be able to refund what they misappropriated. Crimes committed by victims include credit-card fraud, check kiting, and embezzlement. San Diego-based businessman James Adler lost over $5 million in a Nigeria-based advance-fee scam. While a court affirmed that various Nigerian government officials (including a governor of the Central Bank of Nigeria) were directly or indirectly involved, and that Nigerian government officials could be sued in U.S. courts under the "commercial activity" exception to the Foreign Sovereign Immunities Act, Adler was unable to get his money back due to the doctrine of unclean hands because he had knowingly entered into a contract that was illegal. Some 419 scams involve even more serious crimes, such as kidnapping or murder. One such case, in 2008, involves Osamai Hitomi, a Japanese businessman who was lured to Johannesburg, South Africa and kidnapped on September 26, 2008. The kidnappers took him to Alberton, south of Johannesburg, and demanded a $5 million ransom from his family. Seven people were ultimately arrested. In July 2001, Joseph Raca, a former mayor of Northampton, UK, was kidnapped by scammers in Johannesburg, South Africa, who demanded a ransom of £20,000. The captors released Raca after they became nervous. One 419 scam that ended in murder occurred in February 2003, when Jiří Pasovský, a 72-year-old scam victim from the Czech Republic, shot and killed 50-year-old Michael Lekara Wayid, an official at the Nigerian embassy in Prague, and injured another person, after the Nigerian Consul General explained he could not return the $600,000 that Pasovský had lost to a Nigerian scammer. The international nature of the crime, combined with the fact that many victims do not want to admit that they bought into an illegal activity, has made tracking down and apprehending these criminals difficult. Furthermore, the government of Nigeria has been slow to take action, leading some investigators to believe that some Nigerian government officials are involved in some of these scams. The Nigeria government's establishment of the Economic and Financial Crimes