Complaint as to Herode Chancy (1), Michael Albarella (2), Adedayo Ilori — USA v. Chancy et al. (Dkt. 1, S.D.N.Y.)

Record facts

U.S. District Court for the Southern District of New York · No. 1:20-cr-00378-LJL · Doc. 1 · 2020-03-03 · Docket on CourtListener

Full text

! 
Approved: 
Before: 
482 
CECILIA E. VOGL/TARA M. LAMORTE 
Assistant United States Attorneys 
THE HONORABLE KEVIN NATHANIEL FOX 
United States Magistrate Judge 
Southern District of New York 
ORIGINAL 
SEALED COMPLAINT 
UNITED STATES OF AMERICA 
-
V. 
-
HERODE CHANCY, 
MICHAEL ALBARELLA, and 
ADEDAYO ILORI, 
Defendants . 
Violations of 
18 u.s.c. §§ 215, 1343, 1349, 
1028A, 1956 
COUNTY OF OFFENSE : NEW YORK 
SOUTHERN DISTRICT OF NEW YORK, ss. : 
TERRY B. KIM, being duly sworn, deposes and says that he is 
a Special Agent with the Federal Bureau of Investigation 
("FBI"), and charges as follows: 
COUNT ONE 
(Conspiracy to Commit Wire Fraud) 
1. From at least in or about March 2019 up to and 
including in or about March 2020 , in the Southern District of 
New York and elsewhere, HERODE CHANCY and ADEDAYO ILORI, the 
defendants, and others known and unknown, willfully and 
knowingly, did combine, conspire, confederate, and agree 
together and with each other to commit wire fraud, in violation 
of Title 18, United States Code, Section 1343. 
2. It was a part and object of the conspiracy that 
HERODE CHANCY and ADEDAYO ILORI, the defendants, and others 
known and unknown, willfully and knowingly, having devised and 
intending to devise a scheme and artifice to defraud, and for 
obtaining money and property by means of false and fraudulent 
pretenses, representations and promises, would and did transmit 
and cause to be transmitted by means of wire, radio, and 
television communication in interstate and foreign commerce, 
writings, signs, signals, pictures, and sounds for the purpose 
of executing such scheme and artifice, in violation of Title 18, 
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United States Code, Section 1343, to wit, CHANCY and ILORI 
agreed together and with others to engage in a scheme in which 
they would submit fraudulent business loan applications with the 
intent not to repay the loans (the "Loan Scheme"), and in 
connection therewith and in furtherance thereof, would transmit 
and cause to be transmitted interstate electronic mail. 
(Title 18, United States Code, Section 1349.) 
COUNT TWO 
(Wire Fraud) 
3. From at least in or about March 2019 up to and 
including in or about March 2020, in the Southern District of New 
York 
and 
elsewhere, 
HERODE 
CHANCY 
and 
ADEDAYO 
ILORI, 
the 
defendants, willfully and knowingly, having devised and intending 
to devise a scheme and artifice to defraud, and for obtaining money 
and 
property 
by 
means 
of 
false 
and 
fraudulent 
pretenses, 
representations, 
and promises, 
did transmit and cause to be 
transmitted by means of wire, radio, and television communication 
in interstate and foreign commerce, 
writings, signs, signals, 
pictures, and sounds, for the purpose of executing such scheme and 
artifice, to wit, CHANCY and ILORI engaged in a scheme in which 
they submitted fraudulent business loan applications with the 
intent not to repay the loans, and in connection therewith and in 
furtherance thereof, transmitted and caused to be transmitted 
interstate electronic mail. 
(Title 18, United States Code, Section 1343 and 2.) 
COUNT THREE 
(Aggravated Identity Theft) 
4. Between in or about January 2020 and March 2020, in 
the Southern District of New York and elsewhere, HERODE CHANCY 
and ADEDAYO ILORI, the defendants, knowingly did transfer, 
possess, and use, without lawful authority, a means of 
identification of another person, during and in relation to a 
felony violation enumerated in Title 18, United States Code, 
Section 1028A(c), to wit, CHANCY and ILORI 
used the names and 
dates of birth of other persons when submitting, and causing the 
submission of, fraudulent loan applications 
made in furtherance 
of the fraudulent conspiracy and scheme charged in Counts One 
and Two, respectively. 
(Title 18, United States Code, Sections 1028A(a) (1), 1028A(b), 
and 2.) 
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COUNT FOUR 
(Conspiracy to Commit Money Laundering) 
5. From at least in or about February 2020, through in 
or about March 2020, in the Southern District of New York and 
elsewhere, HERODE CHANCY, MICHAEL ALBARELLA, and ADEDAYO ILORI, 
the defendants, and others known and unknown, willfully and 
knowingly did combine, conspire, confederate, and agree together 
and with each other to violate the money laundering laws of the 
United States. 
6. It was a part and an object of the conspiracy that 
HERODE CHANCY, MICHAEL ALBARELLA, and ADEDAYO ILORI, the 
defendants, and others known and unknown, with the intent to 
conceal and disguise the nature, location, source, ownership, 
and control of property believed to be the proceeds of specified 
unlawful activity, to wit, the purported proceeds of business 
loans obtained in violation of Title 18, United States Code, 
Section 1343, as charged in Count Two of this Complaint, would 
and did conduct and attempt to conduct a financial transaction 
involving property represented to be the proceeds of specified 
unlawful activity, to wit, the defendants agreed to launder, 
through 
a bank account opened using a stolen identity, the 
purported proceeds of business loans obtained in violation of 
Title 18, United States Code, Section 1343, as charged in Count 
Two of this Complaint, by submitting business loan applications 
that contained fraudulent information, in violation of Title 18, 
United States Code, Section 1956 (a) (3) (B). 
(Title 18, United States Code, Sections 1956(h) .) 
COUNT FIVE 
(Bank Bribery - Solicitation and Acceptance) 
7. In or about February 2020, in the Southern District 
of New York and elsewhere, MICHAEL ALBARELLA, the defendant, being 
an 
officer, 
director, 
employee, 
and 
agent 
of 
a 
financial 
institution, would and did knowingly and corruptly solicit and 
demand for the benefit of a person, and corruptly accept and agree 
to accept things of value exceeding $1,000 from a person, intending 
to be influenced and rewarded in connection with any business and 
transaction of such institution, to wit, ALBARELLA, while acting 
as a manager of a financial institution located in New York, New 
York 
( "Bank-1"), and insured by the Federal Deposit Insurance 
Corporation ("FDIC"), solicited and accepted a bribe payment in 
connection with opening a fraudulent bank account at Bank-1 using 
.3 
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a stolen identity in furtherance of laundering the proceeds of the 
Loan Scheme . 
(Title 18, United States Code, Sections 215(a) (2) and 
2.) 
The bases for my knowledge and for the foregoing charges 
are, in part, as follows: 
8. I am a Special Agent for the FBI and I have been 
personally involved in the investigation of this matter. 
I base 
this affidavit on that personal experience, as well as on my 
conversations with other law enforcement agents, and my 
examination of various reports and records. 
Because this 
affidavit is being submitted for the limited purpose of 
demonstrating probable cause, it does not include all the facts 
that I have learned during the course of my investigation. 
Where the contents of documents and the actions, statements, and 
conversations of others are reported herein, they are reported 
in substance and in part, except where otherwise indicated. 
Overview 
9. As set forth more fully below, from at least in or 
about March 2019 up to and including in or about March 2020, 
HERODE CHANCY, who at all times relevant to this Complaint 
served as a bank manager at Bank-1, and ADEDAYO ILORI, the 
defendants, engaged in a scheme to submit fraudulent business 
loan applications, i.e., the Loan Scheme, to an individual they 
believed was employed as an underwriter by a third-party 
commercial lender but who was in reality an undercover law 
enforcement agent ("UC-1"). CHANCY and ILORI arranged to submit 
approximately eight fraudulent business loan applications by 
email and mail to UC-1 for a total of approximately $1,020,000 
in loans. 
CHANCY and ILORI intended to "bust out" the loans, 
i.e., they intended not to repay the loans, and they then 
intended to close the business accounts that received the loans 
in order to prevent the commercial lender from recouping the 
loan payments. 
10. 
To apply for the business loans, HERODE CHANCY 
and ADEDAYO ILORI, the defendants, submitted to UC-1 fabricated 
bank statements for purported business bank accounts. 
For some 
of the business loan applications, CHANCY and ILORI also used 
the identities of other persons as the purported loan recipients 
on the fraudulent loan applications, and opened bank accounts 
using the identification information of those other persons in 
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order to receive the loan proceeds. 
11. 
MICHAEL ALBARELLA, the defendant, who as 
described above, served as a manager at Bank-1 at all times 
relevant to this Complaint, opened a bank account using a stolen 
identity in order for HERODE CHANCY and ADEDAYO ILORI, the 
defendants, to launder proceeds of the Loan Scheme through the 
account, and ALBARELLA accepted an approximately $10,000 bribe 
in exchange for opening the account. 
Initial Meetings in Furtherance of the Loan Scheme 
12. 
Based on my review of documents, my conversations 
with 
law 
enforcement 
officers, 
my 
conversations 
with 
a 
confidential source ( the "CS") 1 and UC-1, my review of recorded 
conversations, as well as my own personal involvement in this 
investigation, I have learned, in part and in substance, that: 
a. On or about April 10, 2019, the CS met with 
HERODE CHANCY and ADEDAYO ILORI, the defendants, in Brooklyn, New 
York. 
The meeting was audio recorded. 
During the meeting, CHANCY 
and ILORI discussed fraudulently obtaining business loans from 
third parties through the CS. 
ILORI, in sum and substance, stated 
that he could make fake documents and obtain the identifications 
of other persons for use in this fraudulent loan scheme. 
CHANCY, 
ILORI, and the CS discussed, in sum and substance, that CHANCY and 
ILORI would obtain identification information for individuals in 
order to create fake identification documents, which CHANCY and 
ILORI 
would then use, 
along with fraudulently altered bank 
statements, to apply for the business loans. 
CHANCY explained, in 
sum and substance, that he had a contact who could alter bank 
statements. 
CHANCY, ILORI, and the CS also discussed, in substance 
and in part, that CHANCY and ILORI would open bank accounts using 
the identities of other persons in order to receive the loan 
payments. 
with CHANCY in 
the meeting, 
initially for 
b. On or about July 2, 2019, the cs and UC-1 met 
Manhattan. 
The meeting was audio recorded. 
During 
CHANCY, 
in sum and substance, 
agreed to apply 
approximately two business loans of approximately 
1 The CS has been a paid informed for the FBI since approximately 
February 2019. 
The CS has previously been convicted of narcotics 
and firearms offenses and racketeering charges, including murder 
and kidnapping in aid of racketeering. 
The information provided 
by the CS has been deemed reliable and corroborated by other 
information. 
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$10,000 each through the CS and UC-1 by submitting false bank 
statements and false identification documents to UC-1. 
CHANCY, in 
substance and in part, informed the CS and UC-1, that ILORI had 
previously opened business bank accounts at approximately three 
different banks using stolen identities, namely driver's licenses 
with real identifying information but an altered photograph, and 
that those business bank accounts were available to be used to 
receive the loan proceeds to conduct the Loan Scheme . 
c. Between in on or about July and October 2019, 
the CS and CHANCY continued to discuss, in sum and substance, 
the Loan Scheme, in audio recorded in person meetings and over 
the phone. 
d. On or about November 12, 2019, the CS met with 
CHANCY and ILORI in Manhattan. The meeting was audio recorded. 
The CS, CHANCY, and ILORI discussed, in substance and in part, 
that CHANCY and ILORI would initially submit fraudulent business 
loan applications for two loans of $10,000 each and later 
fraudulently apply for a larger loan, and they discussed that 
CHANCY would provide doctored bank statements and false 
identification documents to apply for the business loans and 
that ILORI would create the false identification documents. 
In 
addition, the CS, CHANCY, and ILORI discussed, in substance and 
in part, how to divide the loan proceeds amongst themselves and 
UC-1. 
e. On or about November 19, 2019, the CS and UC-1 
met with CHANCY and ILORI in Manhattan. 
The meeting was audio 
recorded. 
During the meeting, the CS, UC-1, 
CHANCY, 
and ILORI 
discussed, in sum and substance, the Loan Scheme, including the 
fraudulent documents they would submit to apply for the loans, the 
number of loans they would obtain, and the timing of the scheme. 
During the conversation, ILORI explained, in sum and substance, 
that the identification documents to be used in furtherance of the 
scheme 
were out-of-state issued driver's licenses that were 
fraudulently obtained using stolen identities. 
The Initial Fraudulent Loan Applications Submitted for $20,000 
in Loans in Furtherance of the Loan Scheme 
13 . 
databases, 
my 
conversations 
conversations, 
investigation, 
Based on my review of documents and law enforcement 
conversations with law enforcement officers, my 
with the 
CS 
and 
UC-1, 
my 
review of 
recorded 
as well as my own personal involvement in this 
I have learned , in part and in substance, that: 
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a. On or about December 13, 2019, 
HERODE CHANCY, 
the defendant, emailed a loan application ("Loan Application-1") 
in the name of another person and fraudulently doctored bank 
statements (the "Loan Application-1 Bank Statements") to UC-1 with 
the expectation that UC-1 would submit Loan Application-1 and the 
Loan Application-1 Bank Statements to the third-party lender. 
A 
review of law enforcement databases shows that the identity listed 
on Loan Application-1 is a real identity of an individual. 
The 
Loan Application-1 Bank Statements were real bank statements, but 
the account number ("Account Number-1") and the business account 
holder ("Business Account Holder-1") had been changed. 
Several of 
the pages of the Loan Application-1 Bank Statements included a 
different account number ("Account Number-2") that appears to have 
been unintentionally left on the otherwise falsified statement 
sent by CHANCY to UC-1. 
Based on grand jury subpoena returns for 
Bank Account Number-2, I have learned that the Loan Application-1 
Bank 
Statements 
were 
the actual 
statements 
for 
a 
business 
("Business Account Holder-2") that used Account Number-2, and that 
the account number and account holder on the Loan Application-1 
Bank Statements had been changed to Account Number-1 and Business 
Account Holder-1 in order to disguise the source of the Loan 
Application-1 Bank Statements. 
b. Between on or about January 13 and 15, 2020, 
the CS and ADEDAYO ILORI, the defendant, had phone calls, which 
were consensually recorded, 
in which they discussed the Loan 
Scheme, including, in sum and substance, the fraudulent driver's 
licenses and fraudulent bank statements that ILORI was preparing, 
and that ILORI was preparing them with the assistance of another 
unidentified individual. 
c. On or about January 16, 2020, law enforcement 
officers recovered from an undercover mailbox located in New York, 
New York, four fraudulent loan applications that CHANCY had mailed 
to 
UC-1. 
Loan Application-1 
was 
one 
of 
those 
four 
loan 
applications. 
A review of law enforcement databases shows that 
the three identities listed on each of the three other loan 
applications ("Loan Applications-2, -3, and -4," respectively) are 
real identities of other persons. 
In addition, a review of bank 
records obtained pursuant to grand jury subpoenas shows that the 
bank statements submitted with Loan Applications-2, -3, and -4 
were altered prior to CHANCY mailing those statements. 
For 
example, the transaction history listed on the bank statements 
accompanying Loan Applications-2, -3, and -4 does not match the 
transaction history reflected in the bank records obtained from 
the banks pursuant to grand jury subpoenas for the bank account 
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numbers listed on the bank statements for Loan Applications-2, 
-3, and -4. 
d. On or about January 16, 2020, 
UC- 1 spoke with 
CHANCY on a recorded call, and they discussed, in substance and in 
part, that the bank statements submitted with Loan Application-1, 
-2, -3, and -4, were doctored. 
e. On or about January 19 and January 23, 
2020, 
CHANCY emailed to UC-1 four term sheets that confirmed a loan 
amount of $5,000 for each of Loan Application-1, -2, -3, and -4. 
The term sheets were purportedly signed in the name of the loan 
applicants. 
f. On or about January 23, 2020, four $5,000 wire 
transfers were sent from an undercover bank account to the four 
bank accounts listed on Loan Applications-1, 
-2, 
-3, 
and -4 
submitted by CHANCY to UC-1. 
The bank accounts were opened in the 
name of the identities listed on Loan Applications-1, -2, -3, and 
-4. CHANCY informed the CS in later recorded conversations, in 
substance and in part, that CHANCY and ILORI had withdrawn the 
funds from the four accounts. 
g. On or about January 30, 2020, the CS met CHANCY 
at the Bank-1 branch office where CHANCY worked in Manhattan (the 
"Bank-1 Branch Office"). 
The meeting was audio recorded. 
During 
the meeting, CHANCY paid the CS $3,000 in U.S. Currency, which was 
part of the commission CHANCY and ILORI owed to the CS and UC-1 
for their role in the Loan Scheme in accordance with their prior 
agreement. 
The Later Fraudulent Loan Applications Submitted for $1,000,000 
in Loans in Furtherance of the Loan Scheme 
14. 
Based on my review of documents, my conversations 
with law enforcement officers, my conversations with the CS and 
UC-1, 
my review of recorded conversations, as well as my own 
personal involvement in this investigation, I have learned, in 
part and in substance, that: 
a. On or about February 18, 2020, the CS met HERODE 
CHANCY, the defendant, at the Bank-1 Branch Office. 
The meeting 
was audio recorded. 
During the meeting, CHANCY paid the CS an 
additional $2,000 in U.S. Currency as commission to the CS and UC-
1 for their role in securing the $20,000 in fraudulent loan 
proceeds distributed to date for the Loan Scheme . 
During this 
meeting, CHANCY and the CS discussed the next four larger loan 
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applications that CHANCY intended to submit to UC-1, for $250,000 
per loan. CHANCY told the CS, in substance and in part, that he 
had printed the fraudulent bank statements for the larger loan 
applications at a FedEx store because he had not wanted to print 
them at work. 
CHANCY showed the CS the fraudulent bank statements. 
During the meeting, MICHAEL ALBARELLA, the defendant, entered the 
room, 
and CHANCY did not attempt to hide the fraudulent bank 
statements. At that point, the CS met with ALBARELLA in a separate 
room at the Bank-1 Branch Office, and the meeting was audio 
recorded. 
ALBARELLA told the CS, in substance and in part, that 
he could open two to three personal bank accounts for the CS at 
Bank-1 using the identities of other persons so long as the race 
of the individual on the identification card used to open the bank 
account matched the race of the individual who entered Bank-1 to 
open the account. 
b. On or about February 19, 2020, 
CHANCY emailed 
four additional fraudulent loan applications to UC-1 and mailed 
the same to UC-1 at the same undercover mailbox in Manhattan. 
CHANCY had also 
previously discussed with the CS and UC-1 in 
recorded conversations that each of these loans would be for 
$250,000 and that CHANCY and his co-conspirators were not intending 
to repay the loans, i.e., they intended to "bust out" the loans. 
Three of these four larger loan applications used the 
same 
identities 
as 
Loan 
Applications-1, 
-2, 
-3, 
and 
-4 
("Loan 
Applications-5, -6, and -7," respectively) . 
The fourth of the 
larger loan applications listed CHANCY as the loan applicant ( "Loan 
Application-8") . 
A review of bank records obtained pursuant to 
grand jury subpoenas shows that the bank statements submitted with 
Loan Applications-5, 
-6, 
and 
-7 are fraudulent 
because the 
transaction history on the bank statements for Loan Applications-
5, -6, and -7 does not match the actual transaction history of 
those bank accounts as reflected in records produced by the banks 
in response to grand jury subpoenas , i.e., the transaction history 
on the bank statements for Loan Applications-5, 
- 6, and - 7 is 
fabricated. 
c. On or about February 20, 2020, UC-1 and CHANCY 
spoke on a recorded call regarding the Loan Scheme. 
During the 
call, CHANCY asked UC-1, in substance and in part, whether the 
lender for which UC-1 worked and that was issuing the loans for 
Loan Application-5, -6, -7, and -8 would seek to impose a judgment 
on the loan applicants for failing to repay the loans. 
CHANCY 
explained, in substance and in part, that the bank accounts used 
to receive the loan payments would be closed after the loans are 
busted out in order to prevent the collection of any judgments by 
the lender. 
CHANCY expressed concern that the lender would seek 
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to impose a personal judgment against CHANCY because CHANCY was 
using his own identity to apply for one of the loans. 
CHANCY also 
explained, in substance and in part, that three of the four loan 
applicants for the larger loans were "legit," i.e., that three of 
the four loan applicants, including CHANCY, were using their own 
identities to participate in the Loan Scheme, 
and the fourth 
identity was a stolen identity. During the conversation, CHANCY 
asked UC-1 if UC-1 was speaking on a "burner phone," which UC-1 
confirmed. 
In addition, 
CHANCY admitted to UC-1 that he had 
previously thought UC-1 was a "cop," and CHANCY and UC-1 joked 
about CHANCY's prior concerns that UC-1 worked for law enforcement. 
d. On or about February 24, 2020, CHANCY emailed to 
UC-1 four term sheets that confirmed loan amounts of $250,000 for 
each of the four larger loan applications, 
for 
a 
total of 
$1,000,000 in loans for Loan Applications-5, -6, -7, and -8. 
The 
term sheets were signed in the name of the loan applicants. 
The Conspiracy to Launder the $1,000,000 in 
Fraudulent Loan Proceeds 
15. 
Based on my review of documents, my conversations 
with law enforcement officers, my conversations with the CS, uc-
1, and a second undercover officer ("UC-2"), my review of recorded 
conversations, as well as my own personal involvement in this 
investigation, I have learned, in part and in substance, that: 
a. On or about February 26, 2020, the CS met with 
HERODE CHANCY, the defendant, at the Bank-1 Branch Office. 
The 
meeting was audio recorded. 
The CS explained to CHANCY, in 
substance and in part, that they needed to open a "clean" bank 
account-i.e., an account not associated with anyone involved in 
the Loan Scheme-in order to launder the proceeds from the Loan 
Scheme obtained pursuant to Loan Applications-5, -6, -7, and -8. 
CHANCY called ADEDAYO ILORI, the defendant, in the CS's 
presence. 
During the call, CHANCY informed ILORI, in substance 
and in part, that the CS wanted to move the proceeds from the 
larger fraudulent loan applications using a bank account that 
was not associated with the CS. 
CHANCY asked ILORI, in 
substance and in part, if ILORI had a "random" identity they 
could use and whether they could open a bank account using the 
stolen identifications ILORI had previously given CHANCY. 
CHANCY asked ILORI, in substance and in part, to send him the 
identification on his other phone. 
After the call to ILORI, 
CHANCY told the CS, in substance and in part, that he had an 
identification that the CS could use to open the bank account. 
CHANCY showed the cs a Missouri state identification on his 
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personal cellphone (the "Stolen Missouri ID"). 
b. Later that same day, the CS met with MICHAEL 
ALBARELLA, the defendant, at the Bank-1 Branch Office. 
The 
meeting was audio recorded. 
During the meeting, ALBARELLA 
indicated, in substance and in part, that he was aware of the 
Loan Scheme, and the CS explained, in substance and in part, 
that the CS needed to open bank accounts to "clean" the 
fraudulent loan proceeds. 
The CS offered ALBARELLA $10,000 in 
U.S. Currency to open fraudulent bank accounts, with $5,000 to 
be paid up front to open the accounts and $5,000 to be paid 
after the accounts were funded with the fraudulent loan 
proceeds. 
ALBARELLA agreed to open the accounts in exchange for 
the $10,000 in U.S. Currency. 
In addition, ALBARELLA told the 
CS, in substance and in part, that he wanted to take part in the 
Loan Scheme in the future by submitting fraudulent loan 
applications and that he could have doctored bank statements 
prepared for the loan applications . 
ALBARELLA informed the CS, 
in substance and in part, that the CS could open the bank 
accounts any day that ALBARELLA was working and that the race of 
individual who opened the bank accounts should match the race of 
the individual on the identification card provided to Bank-1 to 
open the bank accounts. 
CHANCY subsequently joined the meeting 
with the CS and ALBARELLA. 
In response to questions from 
CHANCY, ALBARELLA informed CHANCY and the CS, in substance and 
in part, that a date of birth and social security number would 
be required to open the laundering bank account but that the 
person who came into the bank to open the bank account did not 
need to look like the person pictured on the identification used 
to open the bank account. 
CHANCY showed the Stolen Missouri ID 
on his cellphone to the CS and ALBARELLA and asked ALBARELLA, in 
substance, if the identification could be used to open a bank 
account. 
ALBARELLA responded yes. 
c. On or about February 27, 2020, the CS and UC-2 
met with CHANCY at the Bank-1 Branch Office. 
UC-2 was 
introduced to CHANCY as a friend of the CS who was willing to 
open a personal bank account using the Stolen Missouri ID. 
The 
meeting was audio and video recorded. 
CHANCY gave UC-2 a 
photocopy of the Stolen Missouri ID in order to open a bank 
account to launder the proceeds of the Loan Scheme. 
ALBARELLA 
introduced himself to UC-2 and went to a separate office with 
UC-2, where ALBARELLA opened a bank account for UC-2 using the 
Stolen Missouri Stolen ID. 
UC-2 was not the individual listed 
or pictured on the Missouri Stolen ID. 
ALBARELLA brought UC-2 
to a bank teller, who assisted UC-2 with making a deposit into 
the newly opened account. 
UC-2 subsequently told ALBARELLA, in 
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I 
' 
substance and in part, that he had the $5,000 payment for 
ALBARELLA for opening the bank account. 
ALBARELLA took UC-2 
into a bathroom at the Bank-1 Branch Office, where UC-2 paid 
ALBARELLA $5,000 in U.S. Currency. 
ALBARELLA explained, in 
substance, that they were conducting the transaction in a 
bathroom because there were no cameras in the bathroom. 
d. A review of law enforcement databases shows 
that the Stolen Missouri ID reflects the identity of a real 
person. 
WHEREFORE the deponent respectfully requests that warrants be 
issued for the arrest of HERODE CHANCY, 
MICHAEL ALBARELLA, 
and 
ADEDAYO ILORI, 
the defendants, and that they be arrested, and 
imprisoned or bailed, as the case may be. 
Sworn to before me this 
"3 
day of March, 2020 
Terry 
. 
1m 
Special Agent 
FBI 
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6053d698b904d3155e901e8a0688a5fc42e818b0ab6c4090b5549a9aadbb24e8

Our copy

gov.uscourts.nysd.540905.1.0.pdf

Original

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