Sealed Indictment as to Apocalypse Bella (1) count(s) 1, 2, 3, 4, Sealed — USA v. Bella (Dkt. 3, S.D.N.Y.)

Summary

The Sealed Indictment of Apocalypse Bella, also known as Dias Yumba, Mackenzy Toussaint, also known as Mack, and Amos Mundendi, also known as Mos and El Ashile Mundi, in the U.S. District Court for the Southern District of New York, filed 04/14/21 as Document 3 in Case 1:21-cr-00247-PAE. It charges that from about March 2020 the defendants used straw applicants and companies to submit false PPP applications seeking at least approximately $14 million, and that loans of nearly $4 million were approved in early July 2020 for Company-1 and Company-2. It alleges the applications claimed over 100 employees for Company-1 although an earlier EIDL application listed four, and that proceeds went abroad and to accounts controlled by Bella and Toussaint. Counts include conspiracy, major fraud against the United States and wire fraud conspiracy.

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UNITED STATES DISTRICT COURT 
SOUTHE RN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA 
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v . -
APOCALYPSE BELLA, 
a/k/a " Dias Yumba ," 
MACKENZY TOUSSAINT , 
a/k/a "Mack," and 
AMOS MUNDENDI , 
a/k/a "Mos ," 
a/k/a "El Ashile Mundi ," 
Defendants. 
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COUNT ONE 
SEALED INDICTMENT 
21 Cr . 
(Conspiracy to Commit Major Fraud Against and 
Defraud the United States) 
The Grand Jury charges : 
OVERVIEW OF FRAUDULENT SCHEME 
1. 
From at least in or about March 2020 to the present , 
APOCALYPSE BELLA, a/k/a " Dias Yumba ," MACKENZY TOUSSAINT, a/k/a 
"Mack," and AMOS MUNDENDI, a/k/a "Mos," a/k/a "El Ashile Mundi ," 
the defendants , were involved in an extensive scheme to prepare 
and submit fraudulent applications to the Small Business 
Administration (" SBA" ) and to at least one company which 
processes PPP loan applications ("PPP Loan Company- 1" ) , in order 
to obtain at least approximately $14 million in government-
guaranteed loans for various companies through the SBA' s 
Case 1:21-cr-00247-PAE   Document 3   Filed 04/14/21   Page 1 of 13

Paycheck Protection Program (" PPP" ) , designed to provide 
financial relief to qualifying companies during the novel 
coronavi rus/COVID- 19 pandemic. 
This scheme resulted in the 
approval of fraudulently procured loans for two companies 
(" Company- 1" and " Company- 2" ) , both located in the Southern 
District of New York , totaling approximately $4 million , and the 
distribution of the proceeds of these fraudulently obtained 
funds to a series of bank accounts located in the United States 
and elsewhere , including bank accounts controlled by TOUSSAINT 
and BELLA . 
2. 
APOCALYPSE BELLA, a/k/a "Dias Yumba ," MACKENZY 
TOUSSAI NT , a/k/a " Mack," and AMOS MUNDENDI , a/k/a "Mos ," a/k/a 
"El Ashile Mundi ," the defendants , devised and executed this 
fraudulent scheme by conspiring wi th indivi dua l s (the " Straw 
Applicants " ) , who own , operate or otherwise are affi liated with 
businesses (the " Straw Companies " ) , such as Company- 1 and 
Company- 2 . 
BELLA, TOUSSAINT , MUNDENDI , and other co-
conspirators supervised and coordinated the submission of 
fraudulent PPP l oan applications for the Straw Compani es , and in 
some cases , completed and/or submitted the fraudulent 
applications themselves . 
3. 
The PPP loan applications for Company- 1 and Company- 2 
(" Company-1 PPP Loan Application" and " Company-2 PPP Loan 
Application" ) were false , designed to maximize proceeds to the 
2 
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fraud scheme . 
Specifically, applications for both Company-1 and 
Company- 2 contained material differences from loan applications 
submitted f or both companies for the Economic Injury Disaster 
Loan ("EIDL" ) program just months earlier. 
For instance, the 
Company-1 PPP Loan Application represented that Company-1 had 
over 100 employees. 
However , an earlier EIDL loan application 
for Company-1 dated on or about March 30 , 2020 , represented that 
Company-1 had only four employees. 
And the Company-2 PPP Loan 
Application was strikingly similar to that of Company- 1, in 
terms of the number of employees and the size of its payroll , 
although a previously submitted EIDL loan application for 
Company- 2 also claimed that Company- 2 had many fewer employees. 
Moreover , the Company-1 and Company- 2 PPP Loan Applications both 
contained false information about the number of employees, size 
of payroll , and other financial information relating to Company-
1 and Company-2. 
These false representations appear to be 
designed to result in the procurement of PPP loans just shy of 
$2 million for each company , the largest PPP loan that was 
allowed by PPP Loan Company- 1 at the time that the Company- 1 and 
Company-2 PPP Loan Applications were submitted . 
4 . 
In early July 2020, the PPP loan applications for both 
Company- 1 and Company- 2 were approved, resulting in the 
disbursement of nearly $4 million total in fraudulently procured 
loans to the defendants. 
3 
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5 . 
Between July and August 2020 , there were significant 
disbursements from the Company- 1 Bank Account that did not 
appear to meet the requirements for the use of PPP funds , 
including large transfers of funds abroad, the movement of funds 
to an investment management company , and the payment of 
approximately $729 , 550 in funds to a bank account which is 
controlled by APOCALYPSE BELLA, a/k/a " Dias Yumba ," the 
defendant , and approximately $138 , 000 to a bank account which is 
controlled by MACKENZY TOUSSAINT , a/k/a "Mack," the defendant. 
6 . 
Starting in or about February 2021 , AMOS MUNDENDI , 
a/k/a "Mos ," a/k/a " El Ashile Mundi , " the defendant , began to 
facilitate the process of fraudulently applying for a second 
round of PPP loans , including for Company- 1 and Company- 2 . 
This 
resulted in a second fraudulent PPP Loan Application being 
prepared and submitted in the name of Company- 1 requesting an 
additional $2 million in PPP funds. 
Those funds have not yet 
been disbursed . 
Statutory Allegations 
7 . 
From at l east in or about March 2020 to the present , 
in the Southern District of New York and elsewhere , APOCALYPSE 
BELLA, a/k/a " Dias Yumba ," MACKENZY TOUSSAINT , a/k/a "Mack," and 
AMOS MUNDENDI , a/k/a "Mos , " a/k/a "El Ashile Mundi ," the 
defendants , together with others known and unknown , willfully 
and knowingly combined , conspired , confederated , and agreed 
4 
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together and with each other to commit an offense against the 
United States and to defraud the United States and an agency 
thereof , to wit , the SBA, in violation of Title 18 , United 
States Code , Sect i ons 1031 and 2 . 
8 . 
It was a part and an object of the conspiracy that 
APOCALYPSE BELLA, a/k/a " Dias Yumba ," MACKENZY TOUSSAINT , a/k/a 
"Mack," and AMOS MUNDENDI , a/k/a "Mos ," a/k/a " El Ashile Mundi," 
the defendants , together with others known and unknown , 
willful l y and knowingly would and did execute and attempt to 
execute , a scheme and artifice with t he intent to defraud the 
United States, and to obtain money and property by means of 
false and fraudulent pretenses , representations , and promises , 
in a grant , contract , subcontract , subsidy, loan, guarantee , 
insurance , and other form of Federal assistance , including 
through an economic stimulus, recovery and rescue plan provided 
by the Government , the value of which was $1,000 , 000 and more , 
to wit, BELLA, TOUSSAINT , and MUNDENDI engaged in a scheme to 
obtain at least approximately $14 million in Government -
guaranteed loans for various companies , including Company-1 and 
Company-2, by means of false and fraudulent pretenses , 
representations , and documents , through the PPP of the SBA, 
designed to provide relief to small businesses during the novel 
coronavirus/COVID-1 9 pandemic . 
5 
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9 . 
It was a further part and an object of the conspiracy 
that APOCALYPSE BELLA, a/k/a " Dias Yumba ," MACKENZY TOUSSAINT , 
a/k/a " Mack," and AMOS MUNDENDI , a/k/a "Mos ," a/k/a "El Ashi le 
Mundi ," the defendants , together with others known and unknown , 
willfully and knowingly would and did defraud the United States , 
and an agency thereof , to wit , BELLA, TOUSSAINT , and MUNDENDI 
engaged in a scheme to obtain at least approximately $14 million 
in Government - guaranteed loans for various companies , including 
Company- 1 and Company- 2 , by means of false and fraudulent 
pretenses , representations , and documents , through the SBA' s 
Payment Protection Program . 
Overt Acts 
10 . 
In furtherance of the conspiracy and to effect the 
illegal objects thereof , APOCALYPSE BELLA, a/k/a " Dias Yumba," 
MACKENZY TOUSSAINT , a/k/a "Mack," and AMOS MUNDENDI , a/k/a 
"Mos ," a/k/a " El Ashile Mundi ," the defendants , and others known 
and unknown , committed the following overt acts , among others , 
in the Southern District of New York and elsewhere : 
a . 
In or about July 2020 , a co- conspirator not named 
herein (" CC- 1" ) , who was located in the Southern District of New 
York and acts as an agent of both Company-1 and Company- 2 , 
caused a total of approximately $729 , 550 in proceeds from 
fraudulently procured PPP loans to be transferred to a bank 
6 
Case 1:21-cr-00247-PAE   Document 3   Filed 04/14/21   Page 6 of 13

account controlled by BELLA from a bank account located in the 
Southern District of New York . 
b . 
In or about August 2020 , CC-1 , who was located in 
the Southern District of New York , caused a total of 
approximately $138 , 000 in proceeds from fraudulently procured 
PPP loans to be transferred to an account controlled by 
TOUSSAINT from a bank account located in the Southern District 
of New York . 
c. 
In or about February 2021 and March 2021 , 
MUNDENDI communicated with CC-1 , who was located in the Southern 
District of New York , and caused to be prepared a fraudulent PPP 
application for Company- 2 , which was transmitted to CC- 1 . 
(Title 18 , United States Code , Section 371) . 
COUNT TWO 
(Major Fraud Against the United States) 
The Grand Jury further charges: 
11 . 
The allegations set forth in paragraphs 1 to 6 are 
repeated and realleged , and incorporated by reference as if 
fully set forth herein . 
12 . 
From at least in or about March 2020 to the present , 
in the Southern District of New York and elsewhere , APOCALYPSE 
BELLA, a/k/a "Dias Yumba ," MACKENZY TOUSSAINT , a/k/a "Mack, " and 
AMOS MUNDENDI, a/k/a "Mos , " a/k/a "El Ashile Mundi ," the 
defendants , willfully and knowingly executed , and attempted to 
execute , a scheme and artifice with the intent to defraud the 
7 
Case 1:21-cr-00247-PAE   Document 3   Filed 04/14/21   Page 7 of 13

United States , and to obtain money and property by means of 
false and fraudulent pretenses , representations , and promises , 
in a grant , contract , subcontract , subsidy , loan , guarantee , 
insurance , and other form of Federal assistance , including 
through an economic stimulus , recovery and rescue plan provi ded 
by the Government , the value of which was $1 , 000 , 000 and more , 
to wit , BELLA, TOUSSAINT , AND MUNDENDI engaged in a scheme to 
obtain at least approximately $14 million in Government-
guaranteed loans by means of false and fraudulent pretenses , 
representations , and documents , including for Company- 1 and 
Company- 2 , through the PPP . 
(Title 18 , United States Code , Sect i ons 1031 and 2 . ) 
COUNT THREE 
(Wire Fraud Conspiracy) 
The Grand Jury further charges : 
13 . 
The allegations set forth in paragraphs 1 to 6 are 
repeated and realleged , and incorporated by reference as if 
fully set forth herein. 
14 . 
From at least in or about March 2020 through at least 
in or about May 2020 , in the Southern District of New York and 
elsewhere , APOCALYPSE BELLA, a/k/a "Dias Yumba ," MACKENZY 
TOUSSAINT , a/k/a " Mack," and AMOS MUNDENDI, a/k/a "Mos ," a/k/a 
"El Ashile Mundi ," the defendants , and others known and unknown , 
willfully and knowingly did combine , conspire , confederate , and 
8 
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agree toget her and with each other to commit wire fraud , in 
violation of Title 18 , United States Code , Section 1343 . 
15 . 
I t was a part a nd an object of the conspiracy that 
APOCALYPSE BELLA, a/k/a " Dias Yumba ," MACKENZY TOUSSAINT , a/k/a 
"Mack," and AMOS MUNDENDI , a/k/a "Mos ," a/k/a " El Ashile Mundi ," 
the defendants , and others known and unknown , willfully and 
knowingly , having devised and intending to devise a scheme and 
artifice to defraud, and for obtai ning money and property by 
means of false and fraudulent pretenses , representations , and 
promises , transmi tted and caused 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 , BELLA , TOUSSAINT , AND MUNDENDI engaged in a scheme to 
obtain at least approximately $14 million in Government-
guaranteed loans by means of false and fraudulent pretenses , 
representations , and documents , including Company- 1 and Company-
2 , through the PPP , including the online submission of PPP loan 
applications transmitted from the Southern District of New York . 
(Title 18 , United States Code , Sections 1349 and 2 . ) 
9 
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COUNT FOUR 
(Wire Fraud) 
The Grand Jury further charges : 
16 . 
The allegations set forth in paragraphs 1 to 6 are 
repeated and realleged , and incorporated by reference as if 
fully set forth herein . 
17 . 
From at least in or about March 2020 to the present , 
in the Southern District of New York and elsewhere , APOCALYPSE 
BELLA, a/k/a "Dias Yumba ," MACKENZY TOUSSAINT , a/k/a "Mack," and 
AMOS MUNDENDI , a/k/a "Mos ," a/k/a "El Ashile Mundi ," 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 , transmitted and caused 
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, BELLA, TOUSSAINT , 
AND MUNDENDI engaged in a scheme to obtain at least 
approximately $14 million in Government - guaranteed loans by 
means of false and fraudulent pretenses , representations , and 
documents , including for Company- 1 and Company-2 , through the 
PPP , for which fraudulent PPP loan applications were accessed 
online from the Southern District of New York . 
10 
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(Title 18 , United States Code , Sections 1343 and 2.) 
FORFEITURE ALLEGATIONS 
18 . 
As the result of committing the offenses charged in 
Counts Three and Four of this Indictment , APOCALYPSE BELLA, 
a/k/a "Dias Yumba ," MACKENZY TOUSSAINT , a/k/a " Mack," and AMOS 
MUNDENDI , a/k/a "Mos ," a/k/a " El Ashile Mundi ," the defendants, 
shall forfeit to the United States , pursuant to Title 18 , United 
States Code , Section 981 (a) (1) (C) and Title 28 United States 
Code , Section 2461(c) , any and all property , real and personal , 
that constitutes , or is derived from , proceeds traceable to the 
commiss i on of said offenses , including but not limited to a sum 
of money in United States currency representing the amount of 
proceeds traceable to the commission of said offenses . 
Substitute Assets Provision 
19 . If any of the above - described forfeitable property , as 
a result of any act or omission of the defendants : 
a . 
cannot be located upon the exercise of due 
diligence ; 
b. 
has been transferred or sold to , or deposited 
with , a third person ; 
c. 
has been placed beyond the jurisdiction of the 
Court ; 
d. 
has been substantially diminished in value ; or 
e . 
has been commingled with other property which 
cannot be subdivided without difficulty ; 
11 
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it is the intent of the United States , pursuant to Title 21 , 
United States Code , Section 853(p) , and Title 28 , United States 
Code , Section 2461(c) , to seek forfeiture of any other property 
of the defendants up to the value of the forfeitable property 
described above . 
(Title 18 , United States Code , Section 981 ; 
Title 21 , United States Code , Section 853 ; and 
Title 28 , United States Code , Section 2461 . ) 
12 
RAUSS 
ffe 
l 
tates Attorney 
Case 1:21-cr-00247-PAE   Document 3   Filed 04/14/21   Page 12 of 13

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA 
v. 
APOCALYPSE BELLA, a/k/a "Dias Yumba," 
MACKENZY TOUSSAINT , a/k/a "Mack," and 
AMOS MUNDENDI, a/k/a "Mos , " a/k/a "El Ashile 
Mundi," 
Defendants . 
SEALED INDICTMENT 
21 Cr . 
( 18 U. S . C. §§ 3 71 , 10 31 , 13 4 3, 13 4 9 and 2 . ) 
AUDREY STRAUSS 
United States Attorney 
A TRUE BILL 
LA)o r (of\+ s 
)-w~cr"' Gflv i//1y/,z/ 
rJ(_ 
Case 1:21-cr-00247-PAE   Document 3   Filed 04/14/21   Page 13 of 13

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