(S3) Superseding Indictment Filed as to Apocalypse Bella — USA v. Bella (Dkt. 86, S.D.N.Y.)

Record facts

U.S. District Court for the Southern District of New York · No. 1:21-cr-00247-PAE · Doc. 86 · 2021-12-07 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
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UNITED STATES OF AMERICA 
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APOCALYPSE BELLA, 
a/k/a " Dias Yumba ," 
MACKENZY TOUSSAINT , 
a/k/a "Mack , " 
AMOS MUNDENDI , 
a/k/a "Mos ," 
a/k/a " El Ashile Mundi , " 
ALVIN MAXWELL , and 
BRANDON JACKSON , 
Defendants . 
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COUNT ONE 
SEALED SUPERSEDING 
INDICTMENT 
S3 21 Cr . 247 (PAE) 
(Conspiracy to Commit Major Fraud Against and 
Defraud the United States) 
The Grand Jury charges : 
OVERVIEW OF PAYCHECK PROTECTION PROGRAM FRAUD SCHEME 
1 . 
From at least in or about March 2020 to May 2021 , 
APOCALYPSE BELLA, a/k/a " Dias Yumba ," MACKENZY TOUSSAINT , a/k/a 
"Mack," AMOS MUNDENDI, a/k/a "Mos , " a/k/a " El Ashile Mundi ," and 
ALVIN MAXWELL, the defendants , were invol ved in an extensive 
scheme to prepare and submit fraudulent appl i cations to the 
Small Business Administration (" SBA") and to at least one 
company which processes certain SBA loan applications (" Loan 
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Company-1" ) , in order to obtain at least approximately $30 
million in government-guaranteed loans for various companies 
through the SBA' s Paycheck Protection Program ("PPP" ) , designed 
to provide financial relief to qualifying companies during the 
novel coronavirus/COVID-19 pandemic . 
This scheme resulted in 
the approval of fraudulent 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 to bank accounts controlled by TOUSSAINT and BELLA. 
2 . 
APOCALYPSE BELLA, a/k/a " Dias Yumba ," MACKENZY 
TOUSSAINT , a/k/a "Mack," AMOS MUNDENDI , a/k/a "Mos ," a/k/a "El 
Ashile Mundi ," and ALVIN MAXWELL , the defendants , devised and 
executed this fraudulent scheme by conspiring with individuals 
(the " Straw Appl icants " ) , who owned, operated or otherwise were 
affiliated with businesses (the " Straw Companies " ) , such as 
Company- 1 and Company- 2 . 
BELLA, TOUSSAINT , MUNDENDI , MAXWELL , 
and other co- conspirators supervised and coordinated the 
submission of fraudulent PPP loan applications for the Straw 
Companies , and in some cases , completed and/or submitted the 
fraudulent applications themselves . 
3 . 
The PPP l oan applications for Company- 1 and Company- 2 
(" Company- 1 PPP Loan Application" and " Company- 2 PPP Loan 
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Application" ) were false , designed to maximize fraud proceeds to 
scheme participants . 
Specifically, applications for Company-1 
and Cornpany- 2 contained material differences from loan 
applications submitted for both companies under the Economic 
Injury Disaster Loan ("E IDL" ) 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 . 
The 
Company- 2 PPP Loan Application was substantially similar to that 
of Company-1, in terms of the listed 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 have been 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 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 
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disbursement of a total of nearly $4 million in fraudulently 
procured loans to TOUSSAINT , BELLA, and other members of the 
conspiracy . 
5 . 
Between July and August 2020 , there were significant 
disbursements from a bank account belonging to Company- 1 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 was 
controlled by APOCALYPSE BELLA, a/k/a " Dias Yumba ," the 
defendant , and approximately $138 , 000 to a bank account which 
was 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 Applicat i on being 
prepared and submitted in the name of Company- 1 , requesting an 
additional $2 million in PPP funds . 
That l oan was never funded . 
7 . 
In or about June 2020 , ALVIN MAXWELL , the defendant , 
worked together with MACKENZY TOUSSAINT, the defendant , to 
submit a fraudulent PPP loan application for a third company 
(" Company-3" ) as part of the scheme , and facilitated the 
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transmission of a fraudulent PPP loan application for Company- 3 , 
which resulted in the disbursement of over $1 . 6 million in PPP 
loan funds . 
Statutory Allegations 
8 . 
From at least in or about March 2020 to May 2021 , in 
the Southern District of New York and elsewhere , APOCALYPSE 
BELLA, a/k/a "Dias Yumba ," MACKENZY TOUSSAINT , a/k/a "Mack," 
AMOS MUNDENDI , a/k/a "Mos ," a/k/a "El Ashile Mundi ," and ALVIN 
MAXWELL , the defendants , together with others known and unknown , 
willfully and knowingly combined , conspired , confederated , and 
agreed 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 , Section 1031 . 
9 . 
It was a part and an object of the conspiracy that 
APOCALYPSE BELLA, a/k/a " Dias Yumba ," MACKENZY TOUSSAINT , a/k/a 
"Mack," AMOS MUNDENDI , a/k/a "Mos ," a/k/a " El Ashile Mundi ," and 
ALVIN MAXWELL , the defendants , together with others known and 
unknown , willfully and knowingly would and did execute and 
attempt to execute , a scheme and artifice with the 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 , 
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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 , MUNDENDI , and MAXWELL 
engaged in a scheme to obtain at least approximately $30 million 
in Government-guaranteed PPP loans for various companies , 
including Company-1 , Company- 2 , Company-3 by means of false and 
fraudulent pretenses , representations , and documents . 
10 . 
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," AMOS MUNDENDI , a/k/a "Mos ," a/k/a " El Ashile 
Mundi ," and ALVIN MAXWELL , 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, 
TOUSSAI NT , MUNDENDI , and MAXWELL engaged in a scheme to obtain 
at least approximately $30 million in Government - guaranteed PPP 
loans for various companies , including Company-1 , Company- 2 , and 
Company- 3 , by means of false and fraudulent pretenses , 
representations , and documents . 
Overt Acts 
11 . 
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," AMOS MUNDENDI , a/k/a "Mos ," 
a/k/a " El Ashile Mundi ," and ALVIN MAXWELL , the defendants , and 
others known and unknown , committed the following overt acts , 
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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 was acting 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 from a bank 
account located in the Southern District of New York to a bank 
account controlled by BELLA. 
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 from a bank account l ocated in the 
Southern District of New York to an account controlled by 
TOUSSAINT . 
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 . 
d . 
In or about June 2020 , MAXWELL aided and abetted 
the submission of a fraudulent PPP loan application for 
Company- 3 , which resulted in the disbursement of over $1 . 6 
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million in PPP loan funds . 
(Title 18 , United States Code , Section 371) . 
COUNT TWO 
(Major Fraud Against the United States) 
The Grand Jury further charges : 
12 . 
The allegations set forth in paragraphs 1 to 7 are 
repeated and realleged , and incorporated by reference as if 
fully set forth herein. 
13 . 
From at least in or about March 2020 to May 2021 , in 
the Southern District of New York and e l sewhere , APOCALYPSE 
BELLA, a/k/a " Dias Yumba ," MACKENZY TOUSSAINT , a/k/a "Mack," AMOS 
MUNDENDI , a/k/a "Mos ," a/k/a " El Ashile Mundi ," and ALVIN 
MAXWELL , the defendants , willfully and knowingly executed , and 
attempted to execute , a scheme and artifice with the 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 , MUNDENDI , and MAXWELL in a 
scheme to obtain at least approximately $30 million in 
Government- guaranteed PPP loans by means of false and fraudulent 
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pretenses , representations , and documents , incl uding for 
Company-1 a nd Company-2 , and Company-3 . 
(Title 18 , United States Code , Sections 1031 and 2 . ) 
COUNT THREE 
(Wire Fraud Conspiracy) 
The Grand Jury further charges : 
14 . The allegations set forth in paragraphs 1 to 7 are 
repeated and realleged , and incorporated by reference as if 
fully set forth herein . 
15 . From at least in or about March 2020 through at least 
in or about May 2021 , in the Southern District of New York and 
elsewhere , APOCALYPSE BELLA , a/k/a " Dias Yumba ," MACKENZY 
TOUSSAINT , a/k/a "Mack," AMOS MUNDENDI , a/k/a "Mos ," a/k/a " El 
Ashile Mundi ," and ALVIN MAXWELL , the defendants , and others 
known and unknown, wi l lfully 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 . 
16. It was a part and an object of the conspiracy that 
APOCALYPSE BELLA, a/k/a " Dias Yumba," MACKENZY TOUSSAINT , a/k/a 
" Mack," AMOS MUNDENDI , a/k/a "Mos ," a/k/a "El Ashile Mundi ," and 
ALVIN MAXWELL , the defendants , and others known and unknown , 
willful l y and knowingly , having devised and intending to devise 
a scheme a nd artif i ce to defraud , and for obtaining money and 
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property by means of false and fraudulent pretenses , 
representat i ons , and promises , knowingly 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 , 
MUNDENDI , and MAXWELL engaged in a scheme to obtain at least 
approximately $30 million in Government - guaranteed PPP loans by 
means of false and fraudulent pretenses , representations , and 
documents , including Company-1 , Company- 2 , and Company- 3 , 
including through the onl ine submission of PPP loan applications 
transmitted from the Southern District of New York . 
(Title 18 , United States Code , Sections 1349 . ) 
COUNT FOUR 
(Wire Fraud) 
The Grand Jury further charges : 
17 . The allegations set forth in paragraphs 1 to 7 are 
repeated and realleged , and incorporated by reference as if 
fully set forth herein . 
18 . From at least in or about March 2020 to May 2021 , in 
the Southern District of New York and elsewhere , APOCALYPSE 
BELLA, a/k/a "Dias Yumba ," MACKENZY TOUSSAINT , a/k/a "Mack," 
AMOS MUNDENDI , a/k/a "Mos ," a/k/a "El Ashile Mundi ," and ALVIN 
MAXWELL , the defendants , having devised and intending to devise 
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a scheme and artifice to defraud , and for obtaining money and 
property by means of false and fraudulent pretenses , 
representations , and promises , knowingly 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 , 
MUNDENDI , and MAXWELL engaged in a scheme to obtain at least 
approximately $30 million in Government - guaranteed PPP loans by 
means of false and fraudulent pretenses , representations , and 
documents , including for Company- 1 , Company-2 , and Company- 3 , 
including through the online submiss i on of PPP loan applications 
transmitted from the Southern District of New York . 
(Title 18, United States Code , Sections 1343 and 2 .) 
COUNT FIVE 
(Wire Fraud Conspiracy) 
The Grand Jury further charges : 
OVERVIEW OF ECONOMIC INJURY DISASTER LOAN PROGRAM FRAUD SCHEME 
19 . From at least May 2020 to at least in or about April 
2021 , in the Southern District of New York and elsewhere , 
MACKENZY TOUSSAINT , a/k/a "Mack , " and BRANDON JACKSON , the 
defendants , were engaged in a scheme to submit to submit 
fraudulent Economic Injury Disaster Loan ("EIDL" ) applications , 
frequently through the use of synthetic identities (involving a 
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fake name with the real personal identifying information of 
another person) . 
JACKSON and TOUSSAINT frequently used Social 
Security numbers belonging to minors as part of the synthetic 
identities created for the fraud . 
20 . In addition , BRANDON JACKSON , the defendant , at the 
direction of MACKENZY TOUSSAINT , a/k/a " Mack," the defendant , 
created a number of falsified documents , including bank records , 
to submit in support of the fraudulent EIDL applications. 
At 
least approximately $1 . 7 million in EIDL l oans were funded as a 
resulted o f the fraudulent applications created by JACKSON and 
TOUSSAINT. 
21 . Once the fraud proceeds were deposited into bank 
accounts in the names of the synthetic identities , BRANDON 
JACKSON , the defendant , transferred the proceeds via check into 
a bank account that he controlled (the " JACKSON Account") . 
On 
numerous occasions , the check deposits into the JACKSON Account 
took place at a bank branch l ocated in New York , New York . 
STATUTORY ALLEGATIONS 
22 . From at least May 2020 to at least in or about April 
2021 , in the Southern District of New York and elsewhere , 
MACKENZY TOUSSAINT, a/k/a "Mack," and BRANDON JACKSON , the 
defendants , and others known and unknown , willfully and 
knowingly did combine , conspire , confederate , and agree together 
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and with each other to commit wire fraud , in violation of Title 
18 , United States Code , Section 1343 . 
23 . It was a part and an object of the conspiracy that 
MACKENZY TOUSSAINT , a/k/a " Mack," and BRANDON JACKSON , 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 , knowingly transmitted and caused to be transmitted by 
means of wire , radio , and television communication i n interstate 
and foreign commerce , writings , signs , signals , pictures , and 
sounds , for the purpose of executing such scheme and artifice , 
to wit , TOUSSAINT and JACKSON engaged in a scheme to obtain at 
least approximately $1 . 7 million in Government - guaranteed loans 
from the SBA' s EIDL Program, by submitting fraudulent loan 
applications , including applications using fake names and the 
true Social Security numbers of minors , and sent interstate 
wires in furtherance of that scheme. 
(Title 18 , United States Code , Sections 1349 and 2 . ) 
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COUNT SIX 
(Major Fraud Against the United States) 
The Grand Jury further charges : 
24 . The allegations set forth in paragraphs 19 to 21 are 
repeated and realleged , and incorporated by reference as if 
fully set forth herein . 
25 . From at least in or about May 2020 to at least in or 
about April 2021 , in the Southern District of New York and 
elsewhere , MACKENZY TOUSSAINT , a/k/a "Mack," and BRANDON 
JACKSON , the defendants , willfully and knowingly executed , and 
attempted to execute , a scheme and artifice with the 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 , TOUSSAINT and JACKSON engaged in a scheme to 
obtain at least approximately $1.7 million in Government -
guaranteed loans from the EIDL Program, by submitting fraudulent 
loan applications , includi ng applications using fake names and 
the true Social Security numbers of minors . 
(Title 18 , United States Code , Sections 1031 and 2 . ) 
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COUNT SEVEN 
(Aggravated Identity Theft) 
The Grand Jury further charges : 
26 . The allegations set forth in paragraphs 19 to 21 are 
repeated and rea l leged , and incorporated by reference as if 
fully set forth herein . 
27. From at least in or about May 2020 to at least in or 
about April 2021 , MACKENZY TOUSSAINT , a/k/a " Mack," and BRANDON 
JACKSON , the defendants , knowingly did transfer , possess , and 
use , without lawful authority , a means of identification of 
another person , during and in relation to a fe l ony violation 
enumerated in Tit l e 18 , United States Code , Section 1028A(c) , to 
wit , TOUSSAINT and JACKSON used the true Social Security numbers 
of multiple minor individuals , in connection with the submission 
of fraudulent EIDL applications to the SBA, during and in 
re l ation to the fraud offenses charged in Counts Five and Six of 
this Indictment . 
(Title 18 , United States Code , Secti on s 1028A(a) (1) , 
(b) 
& 
( c) ( 4 ) - ( 5) , and 2 . ) 
FORFEITURE ALLEGATIONS 
28 . 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," AMOS 
MUNDENDI , a/k/a " Mos ," a/k/a " El Ashile Mundi ," and ALVIN 
MAXWELL , the defendants , shall forfeit to the United States , 
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pursuant to Title 18 , United States Code , Section 981 (a) (1) (C) 
and Title 28 , United States Code , Section 246l(c) , any and all 
property constituting , or derived from , proceeds obtained 
directly or indirectly , as a result of the commission 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 . 
29 . As the result of committing the offense charged in 
Count Five of this Indictment , MACKENZY TOUSSAINT , a/k/a "Mack," 
and BRANDON JACKSON , 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 constituting, or derived from , proceeds 
obtained directly or indirectly , as a result of the commission 
of said offense , 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 
30. 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 ; 
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! 
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 ; 
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 . ) 
• 
DAMIAN WILLIAMS 
United States Attorney 
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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," 
AMOS MUNDENDI, a/k/a "Mos," 
a/k/a "El Ashile Mundi," 
ALVIN MAXWELL, and 
BRANDON JACKSON. 
Defendants. 
SEALED SUPERSEDING INDICTMENT 
S3 21 Cr . 247 (PAE) 
(18 U. S . C. §§ 371 , 1028A, 1031 , 1343 , 1349 , 
and 2 . ) 
DAMIAN WILLIAMS 
United States Attorney 
A TRUE BILL 
Foreperson 
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