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

Summary

The sealed S3 Superseding Indictment against Apocalypse Bella, Mackenzy Toussaint, Amos Mundendi, Alvin Maxwell and Brandon Jackson, Case 1:21-cr-00247-PAE in the U.S. District Court for the Southern District of New York, filed 12/07/21 as Document 86. It alleges that from about March 2020 to May 2021 Bella, Toussaint, Mundendi and Maxwell ran a scheme using straw applicants and companies to seek at least approximately $30 million in PPP loans through the SBA and a loan processing company. It alleges fraudulent loans of nearly $4 million were approved in early July 2020 for two New York companies whose PPP applications claimed over 100 employees, while an earlier EIDL application for one listed only four. Count One charges conspiracy to commit major fraud against and defraud the United States. The charges are allegations.

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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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