being caught selling local timeshare units without work permits.

Mr. Alan Seif and Mr. Jack Naylon have been working illegally for the Hamiltonian Island Club, which is owned by property developer Mr. Harold Stavisky.

They went into hiding yesterday after their activities became known to The Royal Gazette .

They locked themselves into a timeshare apartment one of them occupies at the Pembroke site and refused to come out.

Earlier, Mr. Seif had looked shocked when he was confronted by The Royal Gazette outside an Italian restaurant in Hamilton.

He agreed to be interviewed later at the Hamiltonian but failed to show up.

One source said yesterday that the two Americans had been living the "life of Riley'' in Bermuda.

They each had a rent-free apartment at the club, which contains several tennis courts, a swimming pool and glorious ocean views.

Mr. Seif is believed to have been on the Island at least since May and was working up until a few days ago, when he was told to stop by Immigration.

Mr. Naylon, though, has only been on the Island a few weeks, and is understood to have flown in from the New Jersey gambling resort of Atlantic City.

Bermuda's Department of Immigration confirmed it had just completed an investigation into Mr. Seif, who was the head of timeshare sales at the Hamiltonian.

A report due to go shortly to Minister of Immigration, the Hon. John Irving Pearman, is believed to recommend that Mr. Seif be deported.

But the department reportedly was not aware that Mr. Naylon was also working on the Island without a permit.

For the past few weeks, Mr. Naylon has been trying to entice tourists and locals alike to have a look at the Hamiltonian apartments. He operated from a booth in The Emporium Building, off Front Street, in Hamilton.

In return for 90 minutes of their time, tourists were offered special gifts.

These included a dinner or snorkel cruise aboard the 65 foot Ovation glass bottom boat; $50 certificates for use at local restaurants; a five-day moped rental; and a free golf package at Ocean View golf club.

Hamiltonian owner Mr. Harold Stavisky said yesterday he had no idea that Mr.

Seif and Mr. Naylon had been breaking the law.

He said the two men worked for a company called Vacations Unlimited, which had a contract to sell timeshares at the Hamiltonian.

However, the phone lines to Vacations Unlimited in Rhode Island, have been disconnected.

"They came to me highly recommended,'' said Mr. Stavisky. "I'm appalled by this. I always thought they had work permits.'' However, Mr. Stavisky, a Jew, appeared to be more concerned that The Royal Gazette had interrupted him over Yom Kippur.

"I don't think it's such a big deal as to have been disturbed on the holiest Jewish holiday,'' he said. "You can quote me on that. I have never been annoyed so much in all my life.'' Mr. Stavisky, who operates from an office suite in Boston, said both men were due to leave Bermuda before the weekend.

Mr. Horst Finkbeiner, who runs the day-to-day operations of the Hamiltonian Island Club, said that timeshare sales were not part of his duties.

"I cannot deny that I didn't know Mr. Seif and Mr. Naylon did not have work permits,'' admitted Mr. Finkbeiner. "But it was not my responsibility. They didn't report to me.'' Mr. Alan Seif.