Indictment (unsealed 9/20/2022) assigned to Judge Michael J. — United States v. Bock (Dkt. 1, D. Minn. No. 0:22-cr-00223)

Summary

An indictment in United States v. Aimee Marie Bock et al., Case 0:22-cr-00223-NEB-TNL, U.S. District Court for the District of Minnesota, filed September 13, 2022 as Doc. 1. It names 14 defendants, first among them Bock, the founder and executive director of Feeding Our Future, an approved sponsor of the Federal Child Nutrition Program, and alleges that from in or about April 2020 through in or about 2022 they obtained, misappropriated and laundered millions of dollars in reimbursements meant for free meals to children. Count 1 charges conspiracy to commit wire fraud and Count 15 conspiracy to commit federal programs bribery; the charging statutes are 18 U.S.C. §§ 371, 666, 1343, 1956 and 1957. The indictment closes with forfeiture allegations reaching substitute property.

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CASE 0:22-cr-00223-NEB-TNL Doc.1 Filed 09/13/22 Page 1 of 58

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA

UNITED STATES OF AMERICA,
Plaintiff,

Vv.

1. AIMEE MARIE BOCK,
2. ABDIKERM ABDELAHI EIDLEH,
3. SALIM AHMED SAID,
4. ABDULKADIR NUR SALAH,
5. AHMED SHARIF OMAR-HASHIM,
also known as “Salah Donyale,”
ABDI NUR SALAH,
ABDIHAKIM ALI AHMED,
AHMED MOHAMED ARTAN,
ABDIKADIR AINANSHE MOHAMUD,
also known as “AK,”
10. ABDINASIR MAHAMED ABSHIR,
11. ASAD MOHAMED ABSHIR,
12. HAMDI HUSSEIN OMAR,
13. AHMED ABDULLAHI GHEDI, and
14. ABDIRAHMAN MOHAMUD AHMED,
also known as “Chef Abcos,”

Defendants.

Ca, 22-223 W30/DTS
INDICTMENT

18 U.S.C. § 371
18 U.S.C. § 666
18 U.S.C. § 1343
18 U.S.C. § 1956
18 U.S.C. § 1957

THE UNITED STATES GRAND JURY CHARGES THAT: 9

At times relevant to the indictment:

1. The defendants devised and carried out a massive scheme to defraud the

federal child nutrition program, a program designed to provide free meals to children

in need. The defendants obtained, misappropriated, and laundered millions of dollars

in program funds that were intended as reimbursements for the cost of serving meals

to children. The defendants exploited changes in the program intended to ensure
CASE 0:22-cr-00223-NEB-TNL Doc.1 Filed 09/13/22 Page 2 of 58

underserved children received adequate nutrition during the Covid-19 pandemic.
Rather than feed children, the defendants took advantage of the Covid-19 pandemic—
and the resulting program changes—to enrich themselves by fraudulently
misappropriating millions of dollars in federal child nutrition program funds.

A, Background on the Federal Child Nutrition Program

2. The Food and Nutrition Service is an agency of the United States
Department of Agriculture (USDA) that administers various federal child nutrition
programs, including the Summer Food Service Program and Child and Adult Care
Food Program (together “the Federal Child Nutrition Program’).

3. The Summer Food Service Program (SFSP) is a federal program
established to ensure that children continue to receive nutritious meals when school
is not in session. The Summer Food Service Program reimburses non-profit
organizations and other participating entities that serve free healthy meals and
snacks to children and teens in low-income areas.

4. The Child and Adult Care Food Program (CACFP) is a federal program
that reimburses non-profit organizations and other participating entities that serve
healthy meals and snacks to children and adults at participating childcare centers,

daycares, and after-school programs.

5. The Federal Child Nutrition Program operates throughout the United
States. The USDA’s Food and Nutrition Service administers the program at the
national and regional levels by distributing federal funds to state governments, which

provide oversight over the Federal Child Nutrition Program.
CASE 0:22-cr-00223-NEB-TNL Doc.1 Filed 09/13/22 Page 3 of 58

6. The Minnesota Department of Education (MDE) administers the
Federal Child Nutrition Program in Minnesota.

7. Meals funded by the Federal Child Nutrition Program are served by
“sites.” Each site participating in the Federal Child Nutrition Program must be
sponsored by a sponsoring organization that is authorized to participate in the
Federal Child Nutrition Program. Sponsors are required to submit an application to
MDE for each site. Sponsors are responsible for monitoring each of their sites and
preparing reimbursement claims for their sites.

8. Sponsors submit reimbursement claims to MDE on behalf of sites under
their sponsorship. The USDA then provides federal reimbursement funds on a per-
meal basis. MDE provides the federal funds to the sponsoring agency, which in turn
pays the reimbursements to the sites under its sponsorship. The sponsoring agency
retains 10 to 15 percent of the funds as an administrative fee in exchange for
sponsoring the sites, submitting reimbursement claims, and disbursing the federal
funds.

9. Historically, the Federal Child Nutrition Program has generally
functioned by providing meals to children involved in educational-based programs or
activities. During the Covid-19 pandemic, however, the USDA waived some of the
standard requirements for participation in the Federal Child Nutrition Program.
Among other things, USDA allowed for-profit restaurants to participate in the
program. It also allowed for off-site food distribution to children outside of educational

programs. At the same time, the state government’s stay-at-home order and telework
CASE 0:22-cr-00223-NEB-TNL Doc.1 Filed 09/13/22 Page 4 of 58

policies made it more difficult to oversee the program. These changes left the program

vulnerable to fraud and abuse.

B. The Defendants and Their Roles

10. Defendant AIMEE MARIE BOCK was the founder and. executive
director of Feeding Our Future, a non-profit organization in the business of helping
community partners participate in the Federal Child Nutrition Program and related
federal programs. Feeding Our Future was an approved sponsor of the Federal Child
Nutrition Program. As a sponsor, Feeding Our Future was responsible for submitting
site applications to MDE for approval, monitoring active sites, submitting claims for
reimbursement from MDE, and disbursing federal funds to sites under its
sponsorship. Feeding Our Future received payment from MDE and kept an
administrative fee—typically 10 to 15 percent. Feeding Our Future provided the
remaining funds directly to sites.

11. Defendant ABDIKERM ABDELAHI EIDLEH was an employee of
Feeding Our Future who was responsible for recruiting and supporting Federal Child
Nutrition Program sites under Feeding Our Future’s sponsorship.

12. Defendants SALIM AHMED SAID, ABDULKADIR NUR SALAH, and
ABDIRAHMAN MOHAMUD AHMED, also known as “Chef Abcos,” owned
Cosmopolitan Business Solutions LLC, the entity that ran Safari Restaurant in
Minneapolis. Safari Restaurant had approximately $600,000 in annual revenue in
each of the three years (2017-2019) prior to the onset of the Covid-19 pandemic. Safari
Restaurant enrolled in the Federal Child Nutrition Program in April 2020 under the

sponsorship of Feeding Our Future. Safari Restaurant also operated as a vendor
CASE 0:22-cr-00223-NEB-TNL Doc.1 Filed 09/13/22 Page 5 of 58

purporting to deliver food and meals to be served at other Federal Child Nutrition
Program sites.

13. Defendants ABDIHAKIM ALI AHMED, SALIM SAID, and AHMED
ABDULLAHI GHEDI created ASA Limited LLC in September 2020. ABDIHAKIM
AHMED, SALIM SAID, and AHMED GHEDI were equal 33% partners in the
company. ASA Limited opened federal child nutrition program sites in St. Paul,
Minnesota, including a site on McKnight Road (the “ASA Limited site”).

14. Defendant AHMED SHARIF OMAR-HASHIM, also known as “Salah
Donyale,” created a company called Olive Management Inc. in or about September
2020. Olive Management opened a federal child nutrition program site in St. Cloud,
Minnesota (the “Olive Management site”).

15. Defendants ABDULKADIR NUR SALAH and AHMED OMAR-
HASHIM operated Total Financial Solutions, a company that provided payroll and
bookkeeping services to many of the companies involved in the fraud scheme.

16. Defendants ABDULKADIR NUR SALAH, ABDI NUR SALAH, and
AHMED MOHAMED ARTAN, registered Stigma-Free International, a non-profit
entity used to carry out the scheme. Stigma-Free International opened up several
Federal Child Nutrition Program sites around the state of Minnesota, including in
Willmar, Mankato, St. Cloud, Waite Park, and St. Paul.

17. Defendant ABDIKADIR AINANSHE MOHAMUD, also known as “AK,”
ran the Stigma-Free site in Willmar, a small town in west-central Minnesota with a

total population of approximately 21,000 (the “Stigma-Free Willmar site”).
CASE 0:22-cr-00223-NEB-TNL Doc. 1 Filed 09/13/22 Page 6 of 58

18. Defendants ABDINASIR MAHAMED ABSHIR and ASAD MOHAMED
ABSHIR ran the Stigma-Free site in Mankato, a mid-sized city in southwestern
Minnesota (the “Stigma-Free Mankato site”).

19. Defendant HAMDI HUSSEIN OMAR ran the Stigma-Free site in Waite
Park, a suburb of St. Cloud, Minnesota (the “Stigma-Free Waite Park site”).

20. Bet on Better Future was a non-profit organization created by
ABDULKADIR SALAH in or about June 2021. Bet on Better Future opened several
Federal Child Nutrition Program sites throughout Minnesota, including sites in

Rochester, Minneapolis, Burnsville, and Faribault.

Count 1
(Conspiracy to Commit Wire Fraud)

21. From in or about April 2020 through in or about 2022, the defendants,

AIMEE MARIE BOCK,
ABDIKERM ABDELAHI EIDLEH,
SALIM AHMED SAID,
ABDULKADIR NUR SALAH,
AHMED SHARIF OMAR-HASHIM,
also known as “Salah Donyale,”
ABDI NUR SALAH,
ABDIHAKIM ALI AHMED,
AHMED MOHAMED ARTAN,
ABDIKADIR AINANSHE MOHAMUD,
also known as “AK,”
ABDINASIR MAHAMED ABSHIR,
ASAD MOHAMED ABSHIR,
HAMDI HUSSEIN OMAR, and
AHMED ABDULLAHI GHEDI,

conspired with each other, and others known and unknown to the grand jury, to
devise a scheme and artifice to defraud and to obtain money by materially false and
fraudulent pretenses, representations, and promises, and for the purpose of executing

such scheme and artifice, transmitted and caused to be transmitted writings, signs,
CASE 0:22-cr-00223-NEB-TNL Doc.1 Filed 09/13/22 Page 7 of 58

signals, pictures, and sounds by means of wire, radio or television communication in
interstate or foreign commerce, in violation of Title 18, United States Code, Sections
371 and 1343.

Object and Purpose of the Conspiracy

22. The object and purpose of the conspiracy was to carry out a fraudulent
scheme to obtain tens of millions of dollars in Federal Child Nutrition Program funds
by submitting fraudulent claims that they were serving meals to thousands of
children a day.

Manner and Means of the Conspiracy

23. The conspirators used the following manner and means, among others,
to accomplish the objects and purpose of the conspiracy.

Feeding Our Future

24. As Executive Director of Feeding Our Future, AIMEE BOCK oversaw a
massive scheme to defraud carried out by sites under its sponsorship. BOCK and her
company recruited individuals and entities to open up more than 200 Federal Child
Nutrition Program sites throughout the state of Minnesota. The sites fraudulently
claimed to be serving meals to thousands of children a day within just days or weeks
of being formed and despite having few, if any, staff and little to no experience serving
this volume of meals.

25. Feeding Our Future also opened its own Federal Child Nutrition
Program sites, including several sites in Minneapolis and a site in Burnsville.
Feeding Our Future contracted with vendors who would, in theory, provide meals to

be served to children by Feeding Our Future staff. In reality, the Feeding Our Future
CASE 0:22-cr-00223-NEB-TNL Doc.1 Filed 09/13/22 Page 8 of 58

sites were fraudulent and their claims to be serving meals to thousands of children a
day, seven days a week, were false.

26. In support of these fraudulent claims, the conspirators created and
submitted fake documentation to cover up their fraud. Sites submitted fraudulent
meal count sheets purporting to document the number of children and meals served
at each site. They also submitted fake invoices purporting to document their purchase
of food to be served at the sites. Although some sites did purchase and serve some
small amount of food, they obtained fraudulent invoices for inflated quantities of food
purchased or meals served to make it appear as though they were serving meals to
thousands of children each day. The conspirators also created fake invoices from
legitimate food distribution companies in order to cover up their scheme to defraud.

27. The sites submitted fake attendance rosters. The rosters purported to
list the name and age of each child that received a meal each day. But the rosters
were fake and did not actually track the service of meals to children. Instead, the
conspirators created the lists using fake names. Because the program only
reimbursed for meals served to children, the conspirators sometimes used an Excel
formula to insert a random age between 7 and 17 into the rosters.

28. Despite knowing the claims were fraudulent, BOCK and Feeding Our
Future submitted her co-conspirators’ fraudulent claims to MDE and then disbursed
the fraudulently obtained Federal Child Nutrition Program funds to the individuals
and entities involved in the scheme.

29. Beginning in approximately April 2020, Feeding Our Future

dramatically increased both the number of sites under its sponsorship as well as the
CASE 0:22-cr-00223-NEB-TNL Doc.1 Filed 09/13/22 Page 9 of 58

amount of Federal Child Nutrition Program funds received by those sites. The
company went from receiving and disbursing approximately $3.4 million in federal
funds to sites under its sponsorship in 2019 to nearly $200 million in 2021. In all,
Feeding Our Future fraudulently obtained and disbursed more than $240 million in
Federal Child Nutrition Program funds during the Covid-19 pandemic.

30. In exchange for sponsoring these sites’ fraudulent participation in the
program, Feeding Our Future received nearly $18 million in Federal Child Nutrition
Program funds as administrative fees in 2021. Because its administrative fees were
tied to the amount of federal funds received by sites under its sponsorship, Feeding
Our Future received tens of millions of dollars in administrative fees to which it was
not entitled due to its sponsorship and facilitation of sites’ fraudulent participation
in the program.

31. In addition to the administrative fees, BOCK, ABDIKERM EIDLEH,
and other Feeding Our Future employees also solicited and received bribes and
kickbacks from individuals and companies sponsored by Feeding Our Future. In
effect, Feeding Our Future operated a pay-to-play scheme, where individuals seeking
to operate fraudulent sites under the sponsorship of Feeding Our Future had to
kickback a portion of their fraudulent proceeds to Feeding Our Future employees.
Many of these kickbacks were paid in cash or disguised as “consulting fees” paid to
shell companies created by Feeding Our Future employees to conceal the true nature
of the payments and to make them appear legitimate.

32. As part of the scheme, EIDLEH also created his own Federal Child

Nutrition Program sites in the name of nominee owners. EIDLEH, through his
CASE 0:22-cr-00223-NEB-TNL- Doc. 1 Filed 09/13/22 Page 10 of 58

nominee owners, fraudulently claimed that the sites were serving meals to thousands
of children per day. EIDLEH created shell companies purporting to be meal vendors
providing food and meals to be served at these sites. EIDLEH also created and
submitted fraudulent invoices purporting to document the sale of meals to the sites.
In reality, these invoices were fake and designed to obtain, misappropriate, and
launder Federal Child Nutrition Program funds.

33. In order to cover up and continue the fraud, BOCK and Feeding Our
Future sought to divert attention away from their fraudulent scheme by blaming
MDE when it attempted to perform legitimate and necessary oversight. MDE
regularly raised questions about the number of sites and amount of claims being
submitted by Feeding Our Future on behalf of sites under its sponsorship. BOCK and
Feeding Our Future knew that MDE’s concerns were valid, and that little of the
Federal Child Nutrition Program funds disbursed by Feeding Our Future were used
to feed children. BOCK further knew that if MDE discovered the true nature of the
fraud, the flow of federal funds to Feeding Our Future and sites under its sponsorship
would stop.

34. Toallay MDE’s concerns and suspicions, BOCK and Feeding Our Future
gave false assurances that they were monitoring the sites under its sponsorship and
that the sites were serving the meals as claimed. When MDE employees pressed
BOCK for further clarification and answers, BOCK accused MDE of discrimination
and unfairly scrutinizing Feeding Our Future’s sites. When MDE denied Feeding Our

Future site applications, BOCK and Feeding Our Future filed a lawsuit accusing

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MDE of denying the site applications due to racial animus in violation of the
Minnesota Human Rights Act.

Safari Restaurant

35. As part of the conspiracy, in April 2020, during the early days of the
Covid-19 pandemic, the Safari Restaurant opened a Federal Child Nutrition Program
site under the sponsorship of Feeding Our Future. By July 2020, Safari Restaurant
claimed to be serving meals to 5,000 children a day, seven days a week. In all, the
defendants claimed to have served more than 3.9 million meals to children at the
Safari Restaurant site between April 2020 and November 2021.

36. In support of their fraudulent claims, the conspirators submitted fake
attendance rosters purporting to list the names and ages of children who attended
and received meals at the Safari Restaurant site’s “after-school program.” For
example, in October 2021, SALIM SAID submitted a roster listing the names and
ages of approximately 2,036 children who received the Safari Restaurant site. The
roster was fraudulent. Of the more than 2,000 names on the list, only approximately
100 matched those of children attending school in the Minneapolis Public School
District.

37. Safari Restaurant also operated as a vendor purporting to deliver food
and meals to Federal Child Nutrition Program sites created by co-conspirators
throughout the state of Minnesota. In all, the defendants claimed that Safari
Restaurant provided more than 2.2 million meals to other Federal Child Nutrition
Program sites involved in the scheme. In all, as part of the scheme to defraud, Safari

Restaurant received more than $16 million in Federal Child Nutrition Program funds

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in 2020 and 2021. SALIM SAID and ABDULKADIR SALAH sent much of this money
to their co-conspirators via shell companies created and used to receive and launder
the proceeds of the fraudulent scheme.

38. Feeding Our Future received more than $1.4 million in administrative
fees for sponsoring Safari Restaurant’s fraudulent participation in the program
during this period. In addition, Safari Restaurant paid more than $350,000 in bribes
and kickbacks to BOCK and EIDLEH in exchange for Feeding Our Future’s
sponsorship of Safari Restaurant’s fraudulent participation in the Federal Child
Nutrition Program.

The ASA Limited and Olive Management Sites

39. In September and October 2020, SALIM SAID, ABDULKADIR SALAH,
and other co-conspirators associated with Safari Restaurant applied to open new
Federal Child Nutrition Program sites. They applied to open these sites under the
names of newly created shell companies—ASA Limited and Olive Management.

40. As part of the scheme, ABDIHAKIM AHMED, SALIM SAID, and
AHMED GHEDI opened up a Federal Child Nutrition Program site in St. Paul (the
“ASA Limited site”) in September 2020. The ASA Limited site claimed to have served
meals to 2,000 or 3,000 children each day, seven days a week at the Gurey Deli, a
small market located in a strip mall in St. Paul. During the one-year period from
September 2020 to September 2021, the conspirators claimed to have served more
than 1.6 million meals at the ASA Limited site. In support of these claims,
ABDIHAKIM AHMED and his co-conspirators prepared and submitted fraudulent

meal counts and invoices.

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41. Theconspirators also submitted a fake attendance roster that purported
to identify both the names and ages of approximately 2,000 children that attended
the ASA Limited site’s “after-school program” in September 2021. The list was fake.
Indeed, the spreadsheet contained a formula that inserted a random number between
7 and 17 in the age column for each “child” on the list.

42. Based on these false claims, ABDIHAKIM AHMED and his co-
conspirators received approximately $5 million in Federal Child Nutrition Program
reimbursements for meals purported served at the ASA Limited site. ABDIHAKIM
AHMED sent much of this money to his co-conspirators via shell companies created
and used to receive and launder the proceeds of the fraudulent scheme. For its part,
Feeding Our Future received more than $400,000 in administrative fees for
sponsoring the ASA Limited site’s fraudulent participation in the program.

43. ABDIHAKIM AHMED also paid approximately $49,000 in kickbacks
from ASA Limited LLC to ABDIKERM EIDLEH, the Feeding Our Future employee
who served as the site support manager for the ASA Limited site. These payments
were made to entities controlled by EIDLEH, in order to disguise the nature of the
kickback payments and to make them appear legitimate.

44. As part of the scheme, AHMED OMAR-HASHIM opened up the Olive
Management site in September 2020. The Olive Management site fraudulently
claimed to have served meals to 3,000 children a day, seven days a week, at the
Hormud Meat and Deli, a small storefront deli located in a strip mall in St. Cloud.
During the 12-month period from September 2020 to September 2021, OMAR-

HASHIM and his co-conspirators fraudulently claimed to have served more than 1.6

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million meals to children at the Olive Management site. In support of these claims,
OMAR-HASHIM prepared and submitted fraudulent meal count sheets and invoices.

45. Insupport of their fraudulent claims, the conspirators also submitted a
fake attendance roster purporting to list the names of 2,040 children who attended
the Olive Management site’s “after-school program.” The roster was fraudulent. Of
the approximately 2,040 names on the list, only approximately 20 matched the names
of children attending school in the St. Cloud Public School District.

46. Based on these fraudulent claims, from in or about September 2020 to
September 2021, OMAR-HASHIM and his co-conspirators received approximately $5
million in Federal Child Nutrition Programs reimbursements for meals purportedly
served to children at the Olive Management site.

47. OMAR-HASHIM sent much of this money to his co-conspirators via shell
companies created and used to receive and launder the proceeds of the fraud scheme.
OMAR-HASHIM also paid approximately $45,000 in kickbacks from Olive
Management to EIDLEH, the Feeding Our Future employee who served as the site
support manager for the Olive Management site. Feeding Our Future also received
approximately $400,000 in administrative fees for sponsoring Olive Management’s
fraudulent participation in the program.

The Stigma-Free Sites

48. In October 2020, MDE announced that USDA was no longer allowing
restaurants and other for-profit companies to enroll as Federal Child Nutrition
Program sites. MDE explained that restaurants would only be allowed to participate

as meal vendors providing food and not as distribution sites. MDE further announced

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that any restaurants enrolled as distribution sites would be closed as of October 31,
2020. In response to this new policy, and in an effort to facilitate the sites’ fraudulent
participation in the scheme, on or about October 20, 2020, BOCK emailed a letter to
MDE titled “Clarification — Restaurants.” In the letter, BOCK falsely claimed that
many of the sites opened at restaurants were actually being staffed and operated by
Feeding Our Future employees, including the Safari Restaurant, Olive Management,
and ASA Limited sites. With respect to each of these sites, BOCK claimed—falsely—
that the “site is being staff[ed] by Feeding Our Future. ... Only Feeding Our Future’s
trained staff and volunteers and sponsor trained site staff serving as volunteers are
permitted to distribute the meals.”

49. Shortly after MDE announced that it was no longer approving sites run
by restaurants and other for-profit companies, the owners of Safari Restaurant and
other associates, including ABDULKADIR SALAH, SALIM SAID, AHMED OMAR-
HASHIM, ABDI SALAH, and AHMED ARTAN, obtained a new non-profit entity,
Stigma-Free International, for use in carrying out the scheme. They immediately
used their new non-profit to open a number of new Federal Child Nutrition Program
sites. At the same time, other conspirators, including ABDIKADIR MOHAMUD,
ABDINASIR ABSHIR, ASAD ABSHIR, and HAMDI OMAR, created additional shell
companies to serve as meal vendor companies purporting to provide the meals to be
served to children at these Stigma-Free International sites. Together, the defendants
claimed to be serving meals to tens of thousands of children each day throughout the
state of Minnesota, for which they fraudulently claimed and received millions of

dollars in Federal Child Nutrition Program funds.

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The Stigma-Free Willmar Site

50. As part of the conspiracy, AHMED ARTAN and ABDIKADIR
MOHAMUD opened the Stigma-Free Willmar site in October 2020. The Stigma-Free
Willmar site purported to serve meals to 2,000 or 3,000 children a day, seven days a
week, from FaaFan restaurant, a small storefront restaurant in downtown Willmar.
Prior to 2020, FaaFan Restaurant served a few dozen people a day. FaaFan
Restaurant had only $500 or $600 in daily sales and less than $200,000 in annual
revenue. The owner of FaaFan Restaurant leased the storefront restaurant space for
approximately $1,600 per month. In or about October 2020, ABDIKADIR
MOMAHUD approached the owner of FaaFan Restaurant and offered to pay him
$40,000 per month to use his small storefront restaurant for the Stigma-Free Willmar
site. From January to November 2021, ABDIKADIR MOHAMUD paid more than
$570,000 to the owner of FaaFan Restaurant. ABDIKADIR MOHAMUD also created
a shell company called Tunyar Trading that purported to be a meal vendor providing
meals to be served at the Stigma-Free Willmar site.

51. During the one-year period from November 2020 to November 2021,
ABDIKADIR MOHAMUD and his co-conspirators claimed to have served
approximately 1.6 million meals at the Stigma-Free Willmar site. In support of these
claims, ABDIKADIR MOHAMUD prepared and submitted fraudulent meal count
sheets and invoices.

52. The conspirators submitted a fake attendance roster purporting to list
the names and ages of approximately 2,000 children who attended the Stigma-Free

Willmar site’s “after-school program.” The list was fake and submitted to support

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their fraudulent claims. The 2,000 names on the roster would have represented
nearly half of the total number of students who attended school in the Willmar public
school district. But, in reality, only approximately 33 of the names on the roster
matched the names of actual students attending school in the Willmar Public School
District.

53. Based on these claims, ABDIKADIR MOHAMUD and his co-
conspirators received more than $4 million in Federal Child Nutrition Program funds.
Rather than use this money to serve meals or feed children, the conspirators
fraudulently misappropriated and stole much of it. ABDIKADIR MOHAMED
transferred more than $2 million from Tunyar Trading to himself and other co-
conspirators, including SALIM SAID, ABDULKADIR SALAH, ADBI SALAH, and
AHMED GHEDI. The bulk of this money was not transferred directly to the
defendants, but instead routed to entities set up and used to disguise the source and
use of the proceeds of the fraud scheme.

54. Feeding Our Future received nearly $500,000 in administrative fees for
sponsoring the Stigma-Free Willmar site’s fraudulent participation in the program.
ABDIKADIR MOHAMED also paid more than $225,000 in bribes and kickbacks from
Tunyar Trading LLC to ABDIKERM EIDLEH, the Feeding Our Future employee
who served as the site support manager for the Stigma-Free Willmar site, in exchange
for the sponsoring and facilitating Stigma-Free Willmar’s fraudulent participation in

the Federal Child Nutrition Program.

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The Stigma-Free Mankato Site

55. ABDINASIR MAHAMED ABSHIR and ASAD MOHAMED ABSHIR
opened the Stigma-Free Mankato site in October 2020. The Stigma-Free Mankato
site purported to serve meals to 3,000 children a day, seven days a week. ABDINASIR
MAHAMED ABSHIR and ASAD MOHAMED ABSHIR also created a shell company
called Horseed Management that purported to serve as a meal vendor providing
meals to be served at the site.

56. ABDINASIR ABSHIR and ASAD ABSHIR claimed to be operating the
Stigma-Free Mankato site out of J’s Sambusa, a small restaurant in North Mankato.
ABDINASIR ABSHIR and Horseed Management LLC paid more than $440,000 to
the owner of J’s Sambusa from December 2020 to December 2021 in exchange for
using the restaurant for the Stigma-Free Mankato site.

57. During the one-year period from November 2020 to November 2021,
ABDINASIR ABSHIR, ASAD ABSHIR, and their co-conspirators claimed to have
served more than 1.6 million meals at the Stigma-Free Mankato site. In support of
these claims, ABDINASIR ABSHIR and his co-conspirators prepared and submitted
fraudulent meal count sheets, attendance rosters, and invoices.

58. Aswith the Stigma-Free Willmar site, the conspirators submitted a fake
roster in support of its fraudulent claims for the Stigma-Free Mankato site. The
roster purported to list the names and ages of approximately 2,032 children who
attended and received meals at their “after school program” in Mankato. Again, the
list was fake. Only 16 of the names on the roster matched the names of students who

attended school in the Mankato Area Public School district.

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59. Based on these claims, the co-conspirators received approximately $5.
million in Federal Child Nutrition Program funds. ABDINASIR ABSHIR, in turn,
transferred millions of dollars from Horseed Management to himself and other co-
conspirators, including defendants SALIM SAID, ASAD ABSHIR, and AHMED
GHEDI, through entities set up and used to disguise the source and use of the
proceeds of the fraud scheme.

60. Feeding Our Future also received nearly $420,000 in administrative fees
for sponsoring the Stigma-Free Mankato site’s fraudulent participation in the
program. ABDINASIR ABSHIR also paid more than $100,000 in kickbacks from
Horseed Management LLC to EIDLEH in exchange for sponsoring and facilitating
Stigma-Free Mankato’s fraudulent participation in the Federal Child Nutrition
Program.

The Stigma-Free Waite Park Site

61. As part of the conspiracy, AHMED ARTAN and HAMDI OMAR opened
the Stigma-Free Waite Park site in or about April 2021. The Stigma-Free Waite Park
site claimed to have served 2,000 children a day, seven days a week, at the Green
Market, a small market and grocery located in a strip mall in Waite Park. HAMDI
OMAR created a company called Feeding Our Youth that purported to serve as a

meal vendor for the site.

62. During the eight-month period from April to November 2021, HAMDI
OMAR and her co-conspirators claimed to have served more than 500,000 meals at
the Stigma-Free Waite Park site. In support of these claims, HAMDI OMAR and her

co-conspirators prepared and submitted fraudulent meal counts and invoices.

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63. The conspirators also prepared and submitted a fake attendance roster
purporting to contain the names and ages of approximately 2,000 children who
attended the Stigma-Free Waite Park site’s “after school program.” But there was no
after-school program, and this roster was fake. Indeed, the age column on the roster
spreadsheet contained an imbedded formula that inserted a random number between
7 and 17 in the age column of the spreadsheet. For this reason, each time HAMDI
OMAR and her co-conspirators prepared and submitted the attendance roster for the
Stigma-Free Waite Park site, the roster contained the same names but different,
randomly generated ages for the “children” on the list.

64. Based on these claims, HAMDI OMAR and her co-conspirators received
more than $1 million in Federal Child Nutrition Program reimbursements. Feeding
Our Future received more than $100,000 in administrative fees for sponsoring the
Stigma-Free Waite Park site’s fraudulent participation in the program.

Bet on Better Future

65. As part of the scheme in late 2021, ABDULKADIR SALAH registered
another non-profit entity, Bet on Better Future, for use in carrying out the scheme.
ABDULKADIR SALAH and his co-conspirators opened several Federal Child
Nutrition Program sites through Bet on Better Future, including sites in Rochester,
Minneapolis, Burnsville, Faribault, and St. Paul.

66. ABDULKADIR SALAH and his co-conspirators claimed to be serving
meals to thousands of children per day at the Bet on Better Future sites. In all,

ABDULKADIR SALAH received more than $1 million in Federal Child Nutrition

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Program funds into Bet on Better Future bank accounts in December 2021 and

January 2022.

Acts in Furtherance of the Conspiracy

67. In furtherance of the conspiracy and to affect its unlawful objections, the
defendants committed and caused to be committed the following overt acts, among
others, in the state and District of Minnesota, and elsewhere:

AIMEE BOCK and Safari Restaurant

68. In or about April 2020, during the early days of the Covid-19 pandemic,
defendants AIMEE BOCK and SALIM SAID submitted an application to open a
Federal Child Nutrition Program site at Safari Restaurant under the sponsorship of
Feeding Our Future.

69. Onor about April 10, 2020, BOCK and SAID signed a contract providing
that Feeding Our Future would disburse Federal Child Nutrition Program funds to
Safari Restaurant for serving meals at the Safari Restaurant site.

70. In July 2020, Safari Restaurant claimed to be serving meals to 5,000
children a day, seven days a week. Safari Restaurant claimed to be entitled to millions
of dollars in Federal Child Nutrition Program reimbursements for serving these

meals.

71. On or about March 1, 2021, SAID sent an email to EIDLEH with the
subject line “February summer meal counts Claims for Safari restaurant.” Attached
to the email were meal count forms claiming that the Safari Restaurant site served
breakfast and lunch to 6,000 children a day, seven days a week, during February

2021.

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The ASA Limited Site

72. On or about September 4, 2020, ABDIHAKIM ALI AHMED registered
ASA Limited LLC with the Minnesota Secretary of State.

73. Four days later, on or about September 8, 2020, BOCK and
ABDIHAKIM AHMED submitted an application to open the ASA Limited site in St.
Paul.

74. BOCK and SAID signed a vendor contract stating that Safari
Restaurant would serve as a meal vendor providing food and meals for the ASA
Limited site, for which Safari Restaurant would receive Federal Child Nutrition
Program reimbursements from Feeding Our Future.

75. Beginning on September 25, 2020—just 3 weeks after the company was
registered with the Minnesota Secretary of State, SAID, ABDIHAKIM AHMED, and
AHMED GHEDI claimed that the ASA Limited site served both breakfast and lunch
to approximately 2,500 children a day. By September 27, 2020, they claimed the site
was serving breakfast and lunch to 3,000 children a day.

76. On or about September 2, 2021, ABDIHAKIM AHMED emailed to
Feeding Our Future meal counts and invoices claiming that the ASA Limited site
served breakfast and lunch to 2,000 children a day every day in August 2021.

77. On or about October 7, 2021, ABDIHAKIM AHMED responded to an
email containing a list purporting to show attendance for the ASA Limited “After
School Program for the Month of September 2021.” ABDIHAKIM AHMED asked,

“can you make all the kids ages 6-17?”

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78. Later that day, ABDIHAKIM AHMED submitted a spreadsheet
containing another version of the fake attendance list with a formula that inserted a
random number between 7 and 17 in the age column for each “child.”

79. On or about November 3, 2021, ABDIHAKIM AHMED sent BOCK an
email containing meal counts, a fake attendance roster, and invoices claiming,
fraudulently, that the ASA Limited site served supper and a snack to 2,000 children

a day every day in October 2021.

80. On or about December 16, 2020, ABDIHAKIM AHMED sent $250,000
from ASA Limited to Salim Limited LLC, a shell company created and used by SAID
to receive and launder fraud proceeds.

81. Onor about January 6, 2021, ABDIHAKIM AHMED wrote a $203,700
check from ASA Limited to AG Limited LLC, a shell company created and used by
AHMED GHEDI to receive and launder fraud proceeds.

82. Onor about February 23, 2021, ABDIHAKIM AHMED wrote a $130,000
check from ASA Limited to Salim Limited LLC, the shell company created and used

by SAID to receive and launder fraud proceeds.

83. On or about March 31, 2021, ABDIHAKIM AHMED wrote a $20,000
check from ASA Limited to 3017 LLC, the shell company created and used by
ABDULKADIR SALAH to receive and launder fraud proceeds.

84. On or about May 12, 2021, ABDIHAKIM AHMED wrote a $190,000
check from ASA Limited to AG Limited LLC, the shell company created and used by

AHMED GHEDI to receive and launder fraud proceeds.

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85. Onor about May 25, 2021, ABDIHAKIM AHMED wrote a $40,000 check
from ASA Limited to 3017 LLC, the shell company created and used by
ABDULKADIR SALAH to receive and launder fraud proceeds.

The Olive Management Site

86. Onor about September 7, 2020, AHMED OMAR-HASHIM incorporated
Olive Management, Inc.

87. Two days later, on or about September 9, 2020, OMAR-HASHIM
submitted an application for Olive Management Inc. to participate in the Federal
Child Nutrition Program under the sponsorship of Feeding Our Future.

88. By September 28, 2020—less than 3 weeks after the company was
formed—Olive Management Inc. claimed to be serving both breakfast and lunch to
nearly 3,000 children a day at a small storefront deli located in a strip mall in St.
Cloud, Minnesota.

89. Onor about December 29, 2020, BOCK wrote a check for $1,135,171 in
Federal Child Nutrition Program funds from Feeding Our Future to Olive
Management.

90. On or about October 4, 2021, ABDULKADIR SALAH sent OMAR-
HASHIM an email containing fake meal counts, invoices, and receipts purporting to
show that the Olive Management site served meals to 2,000 children a day the first
week of September 2021.

91, Onor about October 5, 2021, ABDULKADIR SALAH sent Feeding Our
Future a fake roster purporting to list the names of approximately 2,040 children who

attended the Olive Management-St. Cloud “after-school program” in September 2021.

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92. On or about November 10, 2021, AHMED ARTAN sent an email to
OMAR-HASHIM containing meal counts claiming that the Olive Management site
served meals to 3,000 children beginning on September 28, 2020, and through
December 31, 2020.

93. Onor about January 18, 2021, OMAR-HASHIM wrote a $313,000 check
from Olive Management to Salim Limited LLC, a shell company created and used by
SALIM SAID to receive and launder fraud proceeds.

94. Onor about January 18, 2021, OMAR-HASHIM wrote a $125,000 check
from Olive Management to 3017 LLC, a shell company created and used by
ABDULKADIR NUR SALAH to receive and launder fraud proceeds.

95. Onor about February 19, 2021, OMAR-HASHIM wrote a $80,000 check
from Olive Management to 3017 LLC, a shell company created and used by
ABDULKADIR SALAH to receive and launder fraud proceeds.

96. On or about February 22, 2021, OMAR-HASHIM wrote a $229,000
check to Salim Limited LLC, a shell company created and used by SALIM AHMED
SAID to receive and launder fraud proceeds.

97. On or about May 24, 2021, OMAR-HASHIM wrote a $150,000 check
from Olive Management to Salim Limited LLC, a shell company created and used by

SAID to receive and launder fraud proceeds.

98. On or about September 15, 2021, OMAR-HASHIM wrote a $20,000
check from Olive Management to AG Limited LLC, a shell company created and used

by AHMED GHEDI to receive and launder fraud proceeds.

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Stigma-Free International

99. Defendants ABDI SALAH and AHMED ARTAN acquired Stigma-Free
International Inc., a non-profit organization that had been created by Individual A in
or about August 2019.

100. On or about October 7, Individual A sent Stigma-Free International
incorporation documents and board minutes for Stigma-Free International to ABDI
SALAH. ABDI SALAH forwarded the documents to AHMED ARTAN.

101. On or about October 7, 2020, ABDI SALAH sent Individual A board
minutes announcing the resignation of Individual A as president of Stigma-Free
International and the appointment of AHMED ARTAN as the new president of
Stigma-Free International.

102. On or about October 8, 2020, AHMED ARTAN replaced Individual A as
the signatory on the Stigma-Free International bank account.

103. On or about October 9, 2020, AHMED ARTAN and BOCK prepared and
signed on behalf of Stigma-Free International applications to open Federal Child
Nutrition Program sites in Willmar and Mankato, Minnesota, under the sponsorship
of Feeding Our Future.

The Stigma-Free Willmar Site

104. BOCK and AHMED ARTAN submitted an application to open the
Stigma-Free Willmar site on or about October 19, 2020.

105. A few weeks earlier, on or about September 28, 2020, ABDIKADIR

MOHAMUD created a company called Tunyar Trading LLC.

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106. On or about October 10, 2020, ABDIKADIR MOHAMUD and BOCK
entered into a vendor contract between Tunyar Trading LLC and Feeding Our Future
providing that Tunyar Trading LLC would be reimbursed for providing meals to be
served to children at the Stigma-Free Willmar site.

107. By October 20, 2020, less than a month after creating the Stigma-Free
Willmar site, ABDIKADIR MOHAMUD and AHMED ARTAN claimed to be serving
meals to 3,000 children a day, seven days a week, at the storefront restaurant.

108. On or about December 30, 2020, ABDIKADIR MOHAMUD sent Feeding
Our Future meal counts claiming that the Stigma-Free Willmar site was serving
nearly 3,000 meals a day in October 2020.

109. On or about February 28, 2021, AHMED ARTAN sent an email to
EIDLEH and Feeding Our Future containing meal counts claiming that the Stigma-
Free Willmar site had served nearly 3,000 meals a day in February 2021.

110. On or about November 3, 2021, ARTAN sent an email to Feeding Our
Future that included meal counts claiming that the Stigma-Free Willmar site had
served supper and a snack to 2,000 children a day in October 2021, as well as a fake
attendance roster purporting to list the names and ages of approximately 2,000

> “cc

children that attended the Stigma-Free Willmar site’s “after-school program.”

111. On or about February 19, 2021, ABDIKADIR MOHAMED wrote a
$150,000 check from Tunyar Trading to Stone Bridge Development LLC, a shell

company created by ABDI SALAH to receive and launder fraud proceeds.

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112. On or about May 27, 2021, ABDIKADIR MOHAMED wrote a $70,000
check from Tunyar Trading to 3017 LLC, a shell company created by ABDULKADIR
SALAH to receive and launder fraud proceeds.

113. On or about June 4, 2021, ABDIKADIR MOHAMED wrote a $270,000
check from Tunyar Trading to Stone Bridge Development LLC, a shell company
created by ABDI SALAH to receive and launder fraud proceeds.

114. On or about May 27, 2021, ABDIKADIR MOHAMED wrote a $150,000
check from Tunyar Trading to Salim Limited LLC, a shell company created by SALIM
SAID to receive and launder fraud proceeds.

115. On or about May 27, 2021, ABDIKADIR MOHAMED wrote a $80,000
check from Tunyar Trading to AG Limited LLC, a shell company created by AHMED
GHEDI to receive and launder fraud proceeds.

The Stigma-Free Mankato Site

116. BOCK and AHMED ARTAN completed and signed an application to
open the Stigma-Free Mankato site on or about October 9, 2020.

117. On or about October 9, 2020—the same day that BOCK and ARTAN
signed the Stigma-Free Mankato application—ABDINASIR ABSHIR and ASAD
ABSHIR created a company called Horseed Management LLC to carry out the

fraudulent scheme.

118. Inor about October 2020, ABDINASIR ABSHIR and BOCK entered into
a vendor contract between Horseed Management and Feeding Our Future providing
that Horseed Management would be reimbursed for providing meals to children at

the Stigma-Free Mankato site.

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119. On or about December 30, 2020, ABDIKADIR MOHAMUD submitted
meal counts indicating that Stigma-Free Mankato was serving both breakfast and
lunch to 3,000 children a day, seven days a week, beginning on October 19, 2020—
the same day that BOCK and ABDINASIR ABSHIR applied to open the site and two
months before they rented out the restaurant.

120. On or about April 1, 2021, AHMED ARTAN sent an email to EIDLEH
and Feeding Our Future containing meal counts claiming that the Stigma-Free
Mankato site served breakfast and lunch to 3,000 children a day, seven days a week,
during March 2021.

121. On or about November 2, 2021, AHMED ARTAN sent Feeding Our
Future meal counts claiming that Horseed Management had served meals to 2,000
children a day, seven days a week in October 2021 as well as a fake attendance roster
purporting to list the names and ages of approximately 2,032 children who attended
Horseed Management Mankato’s “after-school program” in October 2021.

122. On or about January 28, 2021, ABDINASIR ABSHIR wrote a $155,000
check from Horseed Management to Salim Limited LLC, the shell company created
by SALIM SAID to receive and launder fraud proceeds.

123. On or about February 8, 2021, ABDINASIR ABSHIR wrote a $70,000
check from Horseed Management to AG Limited LLC, the shell company created by
AHMED GHEDI to receive and launder fraud proceeds.

124. On or about February 22, 2021, ABDINASIR ABSHIR wrote a $75,391
check from Horseed Management to Santana LLC, the shell company created by

ASAD ABSHIR to receive and launder fraud proceeds.

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125. Onor about February 24, 2021, ABDINASIR ABSHIR wrote a $125,000
check from Horseed Management to Salim Limited LLC.

126. On or about March 17, 2021, ABDINASIR ABSHIR wrote a $118,958
check from Horseed Management to Santana LLC.

127. On or about May 26, 2021, ABDINASIR ABSHIR transferred $298,958
from Horseed Management to Calikamin Enterprise, a shell company he created to
receive and launder fraud proceeds.

128. On or about May 27, 2021, ABDINASIR ABSHIR transferred $294,187
from Horseed Management to Calikamin Enterprise.

The Stigma-Free Waite Park Site

129. Onor about December 30, 2020, BOCK and AHMED ARTAN signed and
submitted an application to open the Stigma-Free Waite Park site.

130. On or about April 9, 2021, HAMDI OMAR created a company called
Feeding Our Youth LLC, ostensibly to run the Stigma-Free Waite Park site.

131. On or about June 18, 2021, AHMED ARTAN and HAMDI OMAR
prepared and submitted to Feeding Our Future meal counts purporting to show that
the Stigma-Free Waite Park site served both an afternoon snack and supper to 1,700
to 2,000 children a day, seven days a week beginning on April 4, 2021—five days
before HAMDI OMAR registered Feeding Our Youth LLC with the Minnesota

Secretary of State.

132. On or about November 2, 2021, HAMDI OMAR sent meal counts
claiming that the Stigma-Free Waite Park site had served meals to more than 2,000

children a day, seven days a week in October 2021. In support of that claim, HAMDI

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OMAR also sent a fake attendance roster containing the names and ages of
approximately 2,000 children who attended Feeding Our Youth’s “after-school
program” in October 2021.

133. On or about August 10, 2021, HAMDI OMAR wrote a $116,000 check
from Feeding Our Youth to Salim Limited LLC, the shell company created and used
by SALIM SAID to receive and launder fraud proceeds.

134. On or about August 30, 2021, HAMDI OMAR wrote a $90,000 check
from Feeding Our Youth to Salim Limited LLC.

135. On or about August 31, 2021, HAMDI OMAR wrote a $38,000 check
from Feeding Our Youth to Omar Management Corporation, a shell company that
OMAR created and used to receive and launder fraud proceeds.

136. On or about January 6, 2022, HAMDI OMAR wrote a $250,000 check
from Feeding Our Youth to a newly created company that used the money to purchase
commercial bakery equipment for use in starting a new bakery company.

Bet on Better Future

137. Onor about June 21, 2021, ABDULKADIR SALAH created another non-
profit company called Bet on Better Future.

138. On or about November 24, 2021, ARBDULKADIR SALAH submitted on
behalf of Bet on Better Future applications to open Federal Child Nutrition Program
sites at anumber of locations, including Minneapolis, St. Paul, Burnsville, Rochester,
and St. Cloud.

139. On or about December 2, 2021, ABDULKADIR SALAH submitted to

Feeding Our Future claims that Stigma-Free International and Bet on Better Future

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sites had served more than 250,000 meals to children at 12 sites located around the
state of Minnesota during the month of November 2021.

The Southcross Site

140. On or about October 13, 2020, BOCK and Feeding Our Future opened a
Federal Child Nutrition Program site in Burnsville, Minnesota (the “Southcross
site”).

141. On or about August 18, 2021, BOCK sold the Southcross site to
ABDULKADIR SALAH, SALIM SAID, and Cosmopolitan Business Solutions for
$310,000. In order to make this transaction appear legitimate, BOCK created a
contract stating that the transaction involved the sale of a childcare center.

142. On or about December 2, 2021, ABDULKADIR SALAH submitted to
Feeding Our Future meal count sheets claiming that the Southcross site provided
food to 1,718 children per day in November 2021. ABDULKADIR SALAH also
attached a fake roster purporting to identify the children who received meals at the
Southcross site.

All in violation of Title 18, United States Code, Section 371.

Counts 2-14
(Wire Fraud)

148. Paragraphs 1 through 141 are incorporated herein.

144. From at least in or about April 2020 through in or about January 2022,
in the State and District of Minnesota, and elsewhere, the defendants as set forth
below, and others known and unknown to the grand jury, did knowingly devise and

participate in a scheme and artifice to defraud and to obtain money by means of

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materially false and fraudulent pretenses, representations, and promises, and by
concealment of material facts.

145. On or about the dates listed below, in the State and District of
Minnesota and elsewhere, the defendants, as set forth below, for the purpose of
executing the scheme described above, knowingly caused to be transmitted by means
of a wire communication in interstate commerce, certain writings, signs, signals, and

sounds, including the following:

2 AIMEE BOCK September | An email from BOCK to MDE
SALIM SAID 8, 2020 containing an application to
ABDIKAHKIM AHMED open the ASA Limited site that
AHMED GHEDI traveled through servers located

outside the state of Minnesota

3 ABDI SALAH October 8, | An email from ABDI SALAH to
AHMED ARTAN 2020 AHMED ARTAN containing

resignation letter and board
minutes announcing the

appointment of AHMED
ARTAN as president of Stigma-
Free International that traveled
through servers located outside
the state of Minnesota

4 AIMEE BOCK October An email from BOCK to MDE
ABDI SALAH 19, 2020 containing an application to
AHMED ARTAN open the Stigma-Free Willmar
ABDIKADIR MOHAMUD site that traveled through

servers located outside the state
of Minnesota

5 AIMEE BOCK October An email from BOCK to MDE
SALIM SAID 20, 2020 with the subject line “For-Profit
ABDULKADIR SALAH Restaurant Clarifications” that
AHMED OMAR-HASHIM traveled through servers located
ABDIHAKIM AHMED outside the state of Minnesota

AHMED GHEDI
6 ABDIKERM EIDLEH December | An email from ABDIKADIR
ABDI SALAH 30, 2020 MOHAMUD to ABDIKERM
AHMED ARTAN ’ | EIDLEH with the subject line

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ABDIKADIR MOHAMUD

“Stigma-Free (Willmar)
October/November” that
traveled through servers located
outside the state of Minnesota

ABDIKERM EIDLEH
AHMED ARTAN
ABDINASIR ABSHIR
ASAD ABSHIR

December
30, 2020

An email from ABIDKADIR
MOHAMUD to ABDIKERM
EIDLEH with the subject line
“Stigma-Free (Mankato)
October/November” that passed
through servers located outside
the state of Minnesota

ABDIKERM EIDLEH
SALIM SAID
ABDULKADIR SALAH

March 1,
2021

An email from SALIM SAID to
ABDIKERM EIDLEH with the
subject line “February summer
meal counts Claims for Safari
Restaurant” that traveled
through servers located outside
the state of Minnesota

AHMED ARTAN
HAMDI OMAR

June 18,
2021

An email from AHMED ARTAN
to Feeding Our’ Future
containing meal count sheets for
Stigma-Free Waite Park that
traveled through servers located
outside the state of Minnesota

10

AHMED ARTAN
HAMDI OMAR

November
2, 2022

An email from HAMDI OMAR to
AHMED ARTAN containing a
Feeding Our Youth meal counts
and attendance roster that
traveled through servers located
outside the state of Minnesota

11

AHMED OMAR-HASHIM

November
3, 2021

An email from AHMED OMAR-
HASHIM to Feeding Our Future
containing meal counts and a
fake roster for the Olive
Management site that traveled
through servers located outside
the state of Minnesota

12

AIMEE BOCK

SALIM SAID
ABDIHAKIM AHMED
AHMED GHEDI

November
4, 2021

An email from ABDIHAKIM
AHMED to BOCK containing
fraudulent meal counts and a
fake roster for the ASA Limited
site that traveled through
servers located outside the state
of Minnesota

13

ABDULKADIR SALAH
AHMED ARTAN

December
2, 2021

An email from ABDULKADIR
SALAH containing meal counts

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ABDINASIR ABSHIR and a fake roster for the Stigma-
ASAD ABSHIR Free Mankato site that traveled
through servers located outside
the state of Minnesota

14 ABDULKADIR SALAH December | An email from ABDULKADIR
2, 2021 SALAH to Feeding Our Future
with the subject line “all the
companies” that traveled
through servers located outside
the state of Minnesota

All in violation of Title 18, United States Code, Section 1343.

Count 15
(Conspiracy to Commit Federal Programs Bribery)

146. Paragraphs 1 through 141 are incorporated herein.

147. From in or about April 2020 to in or about January 2022, in the state

and District of Minnesota, the defendants,

AIMEE MARIE BOCK,
ABDIKERM ABDELAHI EIDLEH,
SALIM AHMED SAID,
ABDULKADIR NUR SALAH,
AHMED SHARIF OMAR-HASHIM,
also known as “Salah Donyale,”
ABDIHAKIM ALI AHMED,
AHMED MOHAMED ARTAN,
ABDIKADIR AINANSHE MOHAMUD,
also known as “AK,” and
ABDINASIR MOHAMED ABSHIR,

conspired with each other and with others known and unknown to the Grand Jury to
commit federal programs bribery, that is, to corruptly solicit, demand, accept, or
agree to accept, and to give, offer, and agree to give, anything of value to any person,
with intent to influence and reward an agent of an organization, to wit, agents of
Feeding Our Future, in connection with any business, transaction and series of

transactions with Feeding Our Future involving anything of value of $5,000 or more,

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that is, in exchange for sponsoring their fraudulent participation in the Federal Child
Nutrition Program, where Feeding Our Future received benefits in excess of $10,000
under federal programs involving grants, contracts, subsidies, loan guarantees,
insurance and other forms of federal assistance in any one-year period, in violation of
Title 18, United States Code, Sections 666(a)(1)(B) and (a)(2).

Purpose and Object of the Conspiracy

148. The object and purpose of the conspiracy was for individuals and entities
participating in the fraudulent scheme to obtain Federal Child Nutrition Program
funds to pay bribes and kickbacks to Feeding Our Future employees in exchange for
Feeding Our Future’s sponsorship of their participation in the Federal Child
Nutrition Program.

Manner and Means of the Conspiracy

149. The conspirators used the following manner and means, among others,
to accomplish the objects and purpose of the conspiracy:

a. Employees of Feeding Our Future solicited and accepted bribes
and kickbacks from individuals who opened Federal Child Nutrition Program sites
under the sponsorship of Feeding Our Future.

b. Employees of Feeding Our Future created shell companies for use
in accepting and hiding the bribe and kickback payments.

c. Individuals who ran sites under the sponsorship of Feeding Our
Future paid bribes and kickbacks to Feeding Our Future employees. Many of these
bribes and kickbacks were disguised as consulting payments or other legitimate

payments to shell companies created by Feeding Our Future employees.

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Overt Acts in Furtherance of the Conspiracy

150. The conspirators used the following manner and means, among others,
to accomplish the objects and purpose of the conspiracy:

151. On or about July 28, 2020, SALIM SAID wrote a $1,500 check from
Cosmopolitan Business Solutions LLC to Eidleh Inc.

152. On or about August 20, 2020, SALIM SAID wrote a $2,500 check from
Cosmopolitan Business Solutions LLC to Eidleh Inc.

153. On or about September 15, 2020, SALIM SAID wrote a $5,000 check
from Cosmopolitan Business Solutions LLC to Eidleh Inc.

154. On or about November 24, 2020, ABDIKERM EIDLEH registered
Bridge Consulting & Logistics LLC with the Minnesota Secretary of State.

155. Onor about November 25, 2020, SALIM SAID wrote a $5,000 check from
Cosmopolitan Business Solutions LLC to Eidleh Inc.

156. On or about November 28, 2020, ABDULKADIR SALAH wrote a $5,000
check from Cosmopolitan Business Solutions to Eidleh Inc.

157. On or about December 4, 2020, EIDLEH registered Bridge Logistics

LLC with the Minnesota Secretary of State.

158. On or about December 14, 2020, EIDLEH registered Hope Suppliers

LLC with the Minnesota Secretary of State.

159. Onor about December 30, 2020, ABDIHAKIM AHMED wrote a $14,000

check from ASA Limited LLC to Hope Suppliers LLC.

160. On or about January 8, 2021, ABDULKADIR SALAH wrote a $7,000

check from Cosmopolitan Business Solutions to Eidleh Inc.

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161. On or about January 13, 2021, AHMED GHEDI made a $5,000 online
payment from AG Limited LLC to ABDIKERM EIDLEH.

162. On or about January 18, 2021, ABDULKADIR SALAH wrote a $7,000
check from Cosmopolitan Business Solutions LLC to Eidleh Inc.

163. On or about January 18, 2021, AHMED OMAR-HASHIM wrote a
$24,000 check from Olive Management Inc. to Eidleh Inc.

164. On or about January 29, 2021, ABDIHAKIM AHMED wrote a $7,000
check from ASA Limited LLC to Hope Suppliers LLC.

165. On or about February 8, 2021, ABDINASIR ABSHIR wrote a $56,000
check from Horseed Management LLC to Eidleh Inc.

166. On or about February 8, 2021, ABDINASIR ABSHIR wrote a $56,000

check from Horseed Management LLC to Bridge Logistics LLC.

167. On or about February 19, 2021, ABDIKADIR MOHAMUD wrote a

$68,333 check from Tunyar Trading LLC to Bridge Logistics LLC.

168. On or about February 19, 2021, ABDIKADIR MOHAMUD wrote a

$68,333 check from Tunyar Trading LLC to Hope Suppliers LLC.

169. On or about February 19, 2021, ABDIKADIR MOHAMUD wrote a

$68,333 check from Tunyar Trading LLC to Eidleh Inc.

170. On or about February 25, 2021, SALIM SAID wrote a $14,000 check

from Salim Limited LLC to Eidleh Inc.

171. On or about March 1, 2021, AHMED OMAR-HASHIM wrote a $7,000

check from Olive Management Inc. to Hidleh Inc.

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172. On or about March 9, 2021, SALIM SAID wrote a $14,000 check from
Salim Limited LLC to Hope Suppliers LLC.

173. On or about March 19, 2021, AHMED OMAR-HASHIM wrote a $7,000
check from Olive Management Inc. to Eidleh Inc.

174. On or about March 23, 2021, SALIM SAID wrote a $7,000 check from
Cosmopolitan Business Solutions LLC to Eidleh Inc.

175. On or about March 25, 2021, SALIM SAID wrote a $7,000 check from
Salim Limited LLC to Eidleh Inc.

176. On or about May 27, 2021, SALIM SAID wrote a $14,000 check from
Cosmopolitan Business Solutions to Eidleh Inc.

177. On or about May 27, 2021, AHMED OMAR-HASHIM wrote a $7,000
check from Olive Management to Eidleh Inc.

178. On or about August 13, 2021, ABDULKADIR SALAH obtained a
$310,000 cashier’s check from Cosmopolitan Business Solutions LLC to AIMEE
MARIE BOCK.

All in violation of Title 18, United States Code, Section 371.

Counts 16-40
(Federal Programs Bribery)

179. Paragraphs 146 through 180 are incorporated herein.

180. On or about the dates set forth below, in the State and District of
Minnesota, and elsewhere, the defendants as set forth below, corruptly gave, offered
and agreed to give anything of value to any person with intent to influence and
reward an agent of an organization, as set forth below, in connection with any

business, transaction and series of transactions of each organization involving

39
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anything of value of $5,000 or more, where such organization received benefits in
excess of $10,000 annually under federal programs involving grants, contracts,
subsidies, loan guarantees, insurance and other forms of federal assistance in any

one-year period, as follows:

16 ABDIKERM EIDLEH July 28, A $1,500 check from
SALIM SAID 2020 Cosmopolitan Business
Solutions LLC to Eidleh Inc.
17 ABDIKERM EIDLEH August 20, |; A $2,500 check from
SALIM SAID 2020 Cosmopolitan Business
Solutions LLC to Eidleh Inc.
18 ABDIKERM EIDLEH September |A $5,000 check from
SALIM SAID 15, 2020 Cosmopolitan Business
Solutions LLC to Eidleh Inc.
19 ABDIKERM EIDLEH November |A_ $5,000 check from
SALIM SAID 25, 2020 Cosmopolitan Business
Solutions LLC to Eidleh Inc.
20 ABDIKERM EIDLEH November |A_ $5,000 check from
ABDULKADIR SALAH 28, 2020 Cosmopolitan Business
Solutions LLC to Eidleh Inc.
21 ABDIKERM EIDLEH December A $14,000 check from ASA
ABDIHAKIM AHMED 30, 2020 Limited LLC to Hope
Suppliers LLC
22 ABDIKERM EIDLEH January 8, |A $7,000 check from
ABDULKADIR SALAH 2021 Cosmopolitan Business
Solutions LLC to Eidleh Inc.
23 ABDIKERM EIDLEH January 8, | A $5,000 payment from AG
AHMED GHEDI 2021 Limited LLC to
ABDIKERM EIDLEH
24 ABDIKERM EIDLEH January 18,;A $7,000 check from
ABDULKADIR SALAH 2021 Cosmopolitan Business
Solutions LLC to Eidleh Inc.
25 ABDIKERM EIDLEH January 18, | A $24,000 check from Olive
AHMED OMAR-HASHIM 2021 Management Inc. to Hidleh
Inc.
26 ABDIKERM EIDLEH January 29, | A $7,000 check from ASA
ABDIHAKIM AHMED 2021 Limited LLC to Hope
Suppliers LLC

40
CASE 0:22-cr-00223-NEB-TNL

Doc. 1 Filed 09/13/22 Page 41 of 58

27 | ABDIKERM EIDLEH February 8, /A $56,000 check from
ABDINASIR ABSHIR 2021 Horseed Management LLC
to Kidleh Inc.
28 ABDIKERM EIDLEH February 8, | A $56,000 check from
ABDINASIR ABSHIR 2021 Horseed Management to
Bridge Logistics LLC
29 ABDIKERM EIDLEH February A $68,333 check from
ABDIKADIR MOHAMUD 19, 2021 Tunyar Trading LLC to
Ejidleh, Inc.
30 ABDIKERM EIDLEH February A $68,333 check from
ABDIKADIR MOHAMUD 19, 2021 Tunyar Trading LLC to
Hope Suppliers LLC
31 ABDIKERM EIDLEH February A $68,333 check from
ABDIKADIR MOHAMUD 19, 2021 Tunyar Trading to Bridge
Logistics LLC
32 ABDIKERM EIDLEH February A $14,000 check from Salim
SALIM SAID 25, 2021 Limited LLC to Eidleh Inc.
33 ABDIKERM EIDLEH March 1, A $7,000 check from Olive
AHMED OMAR HASHIM 2021 Management Inc. to Eidleh
Inc.
34 ABDIKERM EIDLEH March 9, A $14,000 check from Salim
SALIM SAID 2021 Limited to Hope Suppliers
LLC
35 ABDIKERM EIDLEH March 19, | A $7,000 check from Olive
AHMED OMAR-HASHIM 2021 Management Inc. to Eidleh
Inc.
36 ABDIKERM EIDLEH March 23, |A $7,000 check from
SALIM SAID 2021 Cosmopolitan Business
Solutions LLC to Eidleh Inc.
37 ABDIKERM EIDLEH March 25, A $7,000 check from Salim
SALIM SAID 2021 Limited to Eidleh Inc.
38 ABDIKERM EIDLEH May 27, A $14,000 check from
SALIM SAID 2021 Cosmopolitan Business
Solutions LLC to EFidleh Inc.
39 ABDIKERM EIDLEH May 27, A $7,000 check from Olive
AHMED OMAR-HASHIM 2021 Management Inc. to Eidleh
Inc.
40 AIMEE BOCK August 13, | A $810,000 check from
ABDULKADIR SALAH 2021 Cosmopolitan Business
Solutions to BOCK

41

Allin violation of Title 18, United States Code, Sections 666(a)(1)(B) and (a)(2).
CASE 0:22-cr-00223-NEB-TNL Doc. 1 Filed 09/13/22 Page 42 of 58

Count 41
(Conspiracy to Commit Money Laundering)

181. Paragraphs 1 through 141 are incorporated herein.
182. From at least in or about April 2020 through in or about January 2022,
in the State and District of Minnesota, the defendants,

ABDIKERM ABDELAHI EIDLEH,
SALIM AHMED SAID,
ABDULKADIR NUR SALAH,
AHMED SHARIF OMAR-HASHIM,
also known as “Salah Donyale,”
ABDI NUR SALAH,
ABDIHAKIM ALI AHMED,
AHMED MOHAMED ARTAN,
ABDIKADIR AINANSHE MOHAMUD,
also known as “AK,”
ABDINASIR MAHAMED ABSHIR,
ASAD MOHAMED ABSHIR,
HAMDI HUSSEIN OMAR,
AHMED ABDULLAHI GHEDI, and
ABDIRAHMAN MOHAMUD AHMED,
also known as “Chef Abcos.”

conspired with each other and with others known and unknown to the Grand Jury to
conduct and attempt to conduct financial transactions knowing that the property
involved in such transactions represented the proceeds of some sort of unlawful
activity and which, in fact, involved the proceeds of a specific unlawful activity, that
is, wire fraud, in violation of Title 18, United States Code, Section 13438, and knowing
those transactions were designed, in whole and in part, to conceal and disguise the
nature, location, source, ownership, and control of the proceeds of specific unlawful

activity, in violation of Title 18, United States Code, Section 1956(a)(1)(B)(@).

42,
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Purpose and Object of the Conspiracy

183. The purpose and object of the conspiracy was to conceal, hide, and
launder the proceeds of the fraudulent scheme to obtain Federal Child Nutrition
Program funds.

Manner and Means of the Conspiracy

184. The conspirators used the following manner and means, among others,
to accomplish the objects and purpose of the conspiracy:

a. The defendants created limited liability companies for use in
hiding the source and ownership of proceeds of the fraudulent scheme to obtain
Federal Child Nutrition Program funds.

b. Some of these companies purported to be meal vendors providing
meals and food to the Federal Child Nutrition Program sites. In reality, these
companies were shells designed to disguise the source and ownership of the proceeds
of the fraud scheme.

Cc. The defendants also created shell companies in order to receive,
misappropriate, and launder the proceeds of their fraud scheme.

d. The defendants transferred funds among their shell companies in
order to conceal the source of nature of the funds. After laundering the proceeds of
their scheme, the defendants used their shell companies to purchase real estate, cars,
and other personal items.

e. On or about September 4, 2020, SALIM SAID, ABDIHAKIM
AHMED, and AHMED GHEDI created a company called ASA Limited LLC to carry

out the fraudulent scheme. ASA Limited purported to be a meal vendor company that

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provided food and meals to be served at the ASA Limited site in St. Paul. In reality,
SALIM SAID, ABDIHAKIM AHMED, and AHMED GHEDI used ASA Limited as a
shell company to obtain and launder fraud proceeds. In all, SALIM SAID,
ABDIHAKIM AHMED, and AHMED GHEDI deposited more than $4 million in
Federal Child Nutrition Program funds into ASA Limited bank accounts.

f. On or about September 7, 2020, AHMED OMAR-HASHIM
created a company called Olive Management Inc. to carry out the fraudulent scheme.
Olive Management purported to be a meal vendor company that provided food and
meals to be served at the Olive Management site in St. Cloud, Minnesota. In reality,
AHMED OMAR-HASHIM used Olive Management as a shell company to obtain and
launder fraud proceeds. In all, AHMED OMAR-HASHIM deposited more than $6
million in Federal Child Nutrition Program funds into Olive Management bank

accounts.

g. On or about September 28, 2020, ABDIKADIR MOHAMUD
created a company called Tunyar Trading LLC to carry out the fraudulent scheme.
Tunyar Trading purported to be a meal vendor company that provided food and meals
to be served at the Stigma-Free Willmar site. In reality, ABDIKADIR MOHAMUD
used Tunyar Trading as a shell company to obtain and launder fraud proceeds. In all,
ABDIKADIR MOHAMUD deposited more than $5 million in Federal Child Nutrition
Program funds into Tunyar Trading bank accounts.

h. On or about October 7, 2020, ABDI SALAH and AHMED ARTAN
acquired control over Stigma-Free International for use in carrying out the fraud

scheme. Stigma-Free International purported to be a non-profit company involved in

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providing free meals to children at various sites around the state of Minnesota. In
reality, ABDI SALAH and AHMED ARTAN used Stigma-Free International as a
shell company to obtain and launder fraud proceeds. In all AHMED ARTAN
deposited more than $10 million in Federal Child Nutrition Program funds into
Stigma-Free International bank accounts.

i. On or about October 9, 2020, ABDINASIR ABSHIR and ASAD
ABSHIR created a company called Horseed Management LLC to carry out the
fraudulent scheme. Horseed Management purported to be a food vendor company
that provided food and meals to be served at the Stigma-Free Mankato site. In reality,
ABDINASIR ABSHIR and ASAD ABSHIR used Horseed Management as a shell
company to obtain and launder fraud proceeds. In all, ABDINASIR ABSHIR and
ASAD ABSHIR deposited more than $5 million in Federal Child Nutrition Program
funds into Horseed Management bank accounts.

j. On or about March 17, 2021, ABDIHAKIM AHMED created 1130
Holdings LLC to carry out the fraudulent scheme. 1130 Holdings LLC purported to
be a food vendor company that provided food and meals to be served at a Federal
Child Nutrition Program site in St. Paul. In reality, ABDIHAKIM AHMED used 1130
Holdings as a shell company designed to obtain and launder fraud proceeds. In all,
ABDIHAKIM AHMED deposited more than $1 million in Federal Child Nutrition
Program funds into 1130 Holdings bank accounts.

k. On or about April 9, 2021, HAMDI OMAR created a company
called Feeding Our Youth LLC, ostensibly to run the Stigma-Free Waite Park site.

Feeding Our Youth purported to be a food vendor company that provided food and

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meals to be served at the Stigma-Free Waite Park site. In reality, HAMDI OMAR
used Feeding Our Youth as a shell company designed to obtain and launder fraud
proceeds. In all, HAMDI OMAR deposited more than $1 million in Federal Child
Nutrition Program funds into Feeding Our Youth bank accounts.

185. As part of the conspiracy, the defendants also created a series of
companies for use in receiving their cut of the fraud proceeds while hiding the source
and their ownership of those funds.

186. For example, on or about July 30, 2020, SALIM SAID created Salim
Limited LLC. SAID used Salim Limited LLC as a shell company to hide and disguise
the source and ownership of his portion of the fraud proceeds. From in or about
August 2020 to January 2022, SAID deposited more than $6 million in Federal Child
Nutrition Program funds into Salim Limited LLC bank accounts. Among other
things, he used this money to purchase real estate and cars.

187. ABDULKADIR SALAH used 3017 LLC as a shell company to hide and
disguise the source and ownership of his portion of the fraud proceeds. Between in or
about November 2020 and January 2022, ABDULKADIR SALAH deposited more
than $4 million in Federal Child Nutrition Program funds into 3017 LLC bank
accounts. Among other things, he used this money to purchase real estate and cars.

188. On or about May 14, 2021, SALIM SAID, ABDULKADIR SALAH and
ABDIRAHMAN AHMED, also known as “Chef Abcos,” registered Afrikan Village
LLC with the Ohio Secretary of State. SALIM SAID, ABDULKADIR SALAH, and
ABDIRAHMAN AHMED each transferred more than $800,000 in Federal Child

Nutrition Program funds to an Afrikan Village bank account in June and July 2021.

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They then used this money to purchase a commercial building in Columbus, Ohio,
that formerly housed the Columbus Culinary Institute for approximately $2.4
million.

189. ABDIRAHMAN AHMED also used another company, Afra Grill LLC, to
receive and launder his share of the fraud proceeds. Between approximately
September 2020 to May 2021, ABDIRAHMAN AHMED deposited more than $2
million in Federal Child Nutrition Program funds into Afra Grill accounts. He then
transferred the bulk of this money into his personal bank accounts. Among other
things, ABDIRAHMAN AHMED used this money to purchase a single-family home
in Delaware, Ohio, and a Lexus RX350 sport utility vehicle.

190. On or about December 14, 2020, AHMED GHEDI created AG Limited
LLC. GHEDI used AG Limited as a shell company to hide and disguise the source
and ownership of his portion of the fraud proceeds. Between December 2020 and
November 2021, AHMED GHEDI deposited more than $2 million in Federal Child
Nutrition Program funds into AG Limited LLC bank accounts. GHEDI used this
money to purchase more than $245,000 in motor vehicles, to fund more than $200,000

in credit card spending, and to purchase real estate.

191. Onor about January 11, 2021, ABDINASIR ABSHIR created Calikamin
Enterprise LLC. ABDINASIR ABSHIR used Calikamin Enterprise LLC as a shell
company to hide and disguise the source and ownership of his portion of the fraud
proceeds. In 2021, ABDINASIR ABSHIR deposited more than $1.8 million in Federal
Child Nutrition Program funds into Calikamin Enterprise bank accounts. He used

the money to pay personal expenses and fund international travel.

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192. On or about January 11, 2021, ASAD ABSHIR registered Santana LLC
with the Minnesota Secretary of State. ASAD ABSHIR used Santana LLC as a shell
company to hide and disguise the source and ownership his cut of the fraud proceeds.
In 2021, ASAD ABSHIR deposited more than $750,000 in Federal Child Nutrition
Program funds into Santana LLC bank accounts. He used this money to, among other
things, pay for personal spending, international travel, and to purchase a 2022 GMC
Sierra 1500 pickup truck for approximately $78,000.

193. On or about September 24, 2020, HAMDI OMAR registered Omar
Management Corporation, which she used as a shell company to receive and launder
her cut of the fraud proceeds.

194. ABDI SALAH created two shell companies to receive and launder his
share of the fraud proceeds. On or about January 20, 2021, ABDI SALAH created
Stone Bridge Development LLC, which he used as a shell company to receive and
launder his share of the fraud proceeds. ABDI SALAH used Stone Bridge
Development LLC to receive more than $1 million in Federal Child Nutrition
Program funds, which he used to purchase real estate and to fund his own personal
spending.

195. ABDI SALAH then sent much of the money to other entities he created
in order to purchase real estate, including $200,000 to ANS Projects LLC, an entity
that ABDI SALAH created in August 2021. ABDI SALAH used ANS Projects LLC to
purchase a multi-family home in Minneapolis along with another individual involved

in the scheme to fraudulently obtain Federal Child Nutrition Program funds,

Sharmarke Issa.

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196. In October 2021, ABDI SALAH, ABDIKADIR MOHAMUD, AHMED
ARTAN, ABDIHAKIM AHMED, and AHMED OMAR-HASHIM created a shell
company Five A’s Projects LLC, a shell company in which they were all equal
partners. ABDI SALAH, ABDIKADIR MOHAMUD, AHMED ARTAN, ABDIHAKIM
AHMED, and AHMED OMAR-HASHIM together transferred more than $1 million
in Federal Child Nutrition Program funds to Five A’s Projects LLC, which they used
to purchase the former location of Kelly’s 19th Hole, a bar and restaurant in Brooklyn
Park, Minnesota.

197. ABDIKERM EIDLEH created and used a number of shell companies to
receive and conceal the bribe and kickback payments he received from individuals
involved in the fraud scheme, including Hope Suppliers LLC, Bridge Logistics LLC,
Bridge Consulting and Logistics LLC, and Eidleh Inc. In all, he deposited more than
$5 million in kickbacks, bribes, and other fraud proceeds into bank accounts opened
in the name of these companies.

All in violation of Title 18, United States Code, Section 1956(h).

Counts 42-61
(Money Laundering)

198. Paragraphs 1 through 141 and 183 to 196 are incorporated herein.

199. On or about the dates listed below, in the State and District of
Minnesota and elsewhere, the defendants as set forth below, knowingly engaged and
attempted to engage in monetary transactions by, through, or to a financial
institution, affecting interstate or foreign commerce, in criminally derived property

of a value greater than $10,000, as describe below, such property having been derived

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from specified unlawful activities, namely, wire fraud, in violation of Title 18, United

States Code, Section 1348:

42 ALIM SAID February | Payment of approximately
24, 2021 $47,000 towards the
purchase of a 2021
Chevrolet Silverado truck
43 AHMED GHEDI March 3, Payment of approximately
2021 $114,887 to Gretna Auto
Outlet for the purchase of a
2021 Cadillac Escalade
44 SALIM SAID March 4, Payment of approximately
2021 $60,000 towards the
purchase of a 2021
Mercedes Benz GLA
45 | ABDINASIR ABSHIR March 8, Payment of approximately
2021 $45,000 towards the
purchase of a 2021 Land
Rover
46 AHMED GHEDI March 25, | Payment of approximately
2021 $35,000 to Dodge of
Burnsville towards the
purchase of a 2020 Dodge
Charger Hellcat
47 AHMED OMAR-HASHIM April 27, Payment of approximately
2021 $100,000 towards the
purchase of the single-
family home located at
1336 Vincent Avenue N,
Minneapolis, Minnesota
48 ABDIRAHMAN AHMED May 4, Payment of approximately
2021 $42,233 towards the
purchase of a 2021 Lexus
RX350
49 ABDIKERM EIDLEH May 6, Payment of approximately
2021 $95,000 towards mortgage
on residence at 15101
County Road 5, Burnsville,
Minnesota
50 ABDIHAKIM AHMED May 17, Payment of approximately
2021 $44,037 towards the

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purchase of a 2022 Mini
Cooper S Countryman

51

SALIM SAID

July 1,
2021

Purchase of the single-
family home located at
5150 Alvarado Lane N,
Plymouth, Minnesota, for
approximately $1,175,000
million

52

SALIM SAID
ABDULKADIR SALAH

July 26,
2021

Purchase of the commercial
building located at 2722-42
Park Avenue S,
Minneapolis, Minnesota for
approximately $2,735,000

53

AHMED GHEDI

July 29,
2021

A check for approximately
$48,474 to Dodge of
Burnsville towards the
purchase of a 2021 Dodge
Ram 1500

54

AHMED OMAR-HASHIM

August 9,
2021

Payment of approximately
$30,000 towards the
purchase of a 2020 Lexus
RX 350

55

ABDIKADIR MOHAMUD

August 11,
2021

Payment of approximately
$39,276 towards the
purchase of the single-
family home located at
1485 66th Avenue NE,
Fridley, Minnesota

56

AHMED GHEDI

August 26,
2021

A $45,000 wire transfer to
Eurocar of Costa Mesa for
the lease of a 2021
Mercedes S-Class S580
sedan

57

SALIM SAID
ABDULKADIR SALAH
ABDIRAHMAN AHMED

August 30,
2021

Payment of approximately
$2.4 million towards the
purchase of the commercial
building located at 2435
Stelzer Road, Columbus,
Ohio

58

ABDULKADIR SALAH,
ABDI SALAH,
ABDIKAHAKIM AHMED,
AHMED ARTAN,
AHMED OMAR-HASHIM

October
22, 2021

Purchase of the bar and
restaurant located at 8432
Noble Avenue N, Brooklyn
Park, Minnesota, for
approximately $1 million

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59 ABDI SALAH October Purchase of the residential
29, 2021 property located at 2529
12th Avenue South,
Minneapolis, Minnesota,
for approximately $386,000
60 ABDIRAHMAN AHMED November | Payment of approximately
12, 2021 $291,981 towards the
purchase of a single-family
home located at 185
Harness Way, Delaware,

Ohio
61 ASAD ABSHIR December | Payment of approximately
30, 2021 $77,353 towards the
purchase of a 2022 GMC

Sierra 1500 truck

All in violation of Title 18, United States Code, Section 1957.

FORFEITURE ALLEGATIONS

1. Counts 1 through 61 of this Indictment are incorporated by reference for
the purpose of alleging forfeiture pursuant to Title 18, United States Code, Section
981(a)(1)(C) in conjunction with Title 28, United States Code, Section 2461(c), and
pursuant to Title 18, United States Code, Section 982(a)(1).

2. If convicted of any of Counts 1-40 of this Indictment, the defendant 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 property, real or
personal, which constitutes or is derived from proceeds traceable to Counts 1-40 of

the Indictment.

3. If convicted of any of Counts 41-61 of this Indictment, the defendants
shall also forfeit to the United States, pursuant to Title 18, United States Code,

Section 982(a)(1), any property, real or personal, involved in a transaction or

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attempted transaction in violation of 18 U.S.C. §§ 1956 and 1957 and any property
traceable to such property.
A. The property subject to forfeiture includes, but is not limited to:

a. $3,506,066.80 seized from Bank of America account No.
374004673156, held in the name of Feeding Our Future DBA Teaching Our Future,
(AIMEE BOCK);

b. $6,347.85 seized from US Bank, account No. 104791224223, held
in the name of AIMEE BOCK;

C. $179.455.87 seized from US Bank, account No. 204788895306,
held in the name of AIMEE BOCK;

d. 2013 Porsche Panamera, VIN: WPOAA2A79DL015044, registered
to AIMEE BOCK;

e. $13,462.00 in U.S. Currency seized from AIMEE BOCK on
January 20, 2022;

f. miscellaneous clothing, accessories and jewelry seized from 13299
Bronze Parkway, Rosemount, Minnesota (the residence of AIMEE BOCK), on
January 20, 2022;

g. miscellaneous electronics seized from 13299 Bronze Parkway,
Rosemount, Minnesota (the residence of AIMEE BOCK), on January 20, 2022;

h. miscellaneous clothing, accessories and jewelry seized from 5150

Alvarado Lane, Plymouth, Minnesota (the residence of SALIM SAID), on January 20,

2022;

53
CASE 0:22-cr-00223-NEB-TNL Doc.1 Filed 09/13/22 Page 54 of 58

1. miscellaneous electronics seized from 5150 Alvarado Lane,
Plymouth, Minnesota (the residence of SALIM SAID), on January 20, 2022;

j. TD Ameritrade acct no. 235832888 held in the name of
ABDIKERM EIDLEH, ($500,948.72 balance at the time of seizure);

k. Firearms seized from 2722 Park Avenue, Minneapolis, Minnesota
the registered business location of Cosmopolitan Business Solutions (PSA serial
number SCB003791 and Anderson serial number 20113938);

1. miscellaneous Electronics seized from 2722 Park Avenue,
Minneapolis, Minnesota the registered business location of Cosmopolitan Business
Solutions;

m. Coinbase account in the name of EIDLEH valued at $94,984.36
at the time of seizure in January 2022;

n. $1,231.07 seized from Bell Bank, account No. 6521110434, in the
name of ASA Limited LLC (ABDIHAKIM AHMED, SALIM SAID, and AHMED
GHEDI); |

oO. $309,882.51 seized from Bell Bank account No. 6521112638 held
in the name of Cosmopolitan Business Solutions D.B.A. Safari Restaurant;

p. $485,512.44 seized from Bell Bank account No. 6521116548 held
in the name 3017 LLC (ABDULKADIR SALAH);

q. $378,207.20 seized from JPMorgan Chase Bank account No.
702380061 held in the name of Tunyar Trading LLC (ABDIKADIR MOHAMUD);

Yr. $472,889.08 seized from Northeast Bank account

number1075100 held in the name of 3017 LLC (ABDULKADIR SALAH);

54
CASE 0:22-cr-00223-NEB-TNL Doc.1 Filed 09/13/22 Page 55 of 58

Ss. $343,418.98 seized from Star Choice Credit Union account No.
31109-10 held in the name of Stone Bridge Development, LLC (ABDI SALAH);

t. $424,762.51 seized from Think Mutual Bank account No.
7450000590146 held in the name of Santana LLC (ASAD ABSHIR);

u. $973.03 seized from Wells Fargo Bank account No. 6817825661
held in the name of SALIM SAID;

Vv. $196,744.11 seized from Wells Fargo Bank account No.
3665380451 held in the name of Salim Limited LLC (SALIM SAID);

w. $5,050.20 seized from Wells Fargo Bank account No. 6338840173
held in the name of Salim Limited LLC (SALIM SAID);

x. $300,790.88 seized from Wells Fargo Bank account No.
9988038718 held in the name of Olive Management Inc. (AHMED OMAR-HASHIM);

y. $96,130.50 seized from Wells Fargo Bank account No.
2133303996, held in the name of AHMED OMAR-HASHIM;

Z. $664,812.22 seized from Bank of America . account No.
374004831833 held in the name Bridge Consulting and Logistics LLC (ABDIKERM
EIDLEH);

aa. $95,085.21 seized from JPMorgan Chase Bank account No.
706558175 held in the name of Delta Food Services LLC (ABDIKERM EIDLEH);

bb. $88,779.49 seized from JPMorgan Chase Bank account No.
675303306 held in the name of Math Tech Tutoring LLC (ABDIKERM EIDLEH);

ce. $320.00 seized from JPMorgan Chase Bank account No.

3860250571 held in the name of Math Tech Tutoring LLC (ABDIKERM EIDLER);

55
CASE 0:22-cr-00223-NEB-TNL Doc.1 Filed 09/13/22 Page 56 of 58

dd. $31,372.65 seized from JPMorgan Chase Bank account No.
776023092, held in the name of Hope Suppliers LLC (ABDIKERM EIDLEH);

ee. $33,513.74 seized from Wells Fargo Bank account No.
3230374864, held in the name of Eidleh Inc. (ABDIKERM EIDLEH);

ff. miscellaneous Electronics seized from 3055 Old Highway 8, St.

Anthony, Minnesota;

gg. 2018 Lexus RX 350, VIN 2T2BZMCA1JC153144, registered to

Sagal Aden (ABDIRAHMAN AHMED);

hh. 2022 GMC Sierra 1500 Ltd. Denali, VIN: 3GTUSFELING140144,

registered to Santana LLC (ASAD ABSHIR);

li. 2021 Chevrolet Silverado, VIN: 1GC4YUEY4MF160143,

registered to SALIM SAID;
jj. 2021 Mercedes Benz GLA, VIN: 4JGFF5KE1MA421736,

registered to SALIM SAID and Individual A.C.;

kk. 2022 Mini Cooper S Countryman, VIN: WMZ83BRO09N3N39411,

registered to ABDIHAKIM AHMED;

ll. 2021 Jeep Grand Cherokee, VIN: 1C4RJFN96MC659204,

registered to AHMED GHEDI;

mm. 2020 Lexus RX, VIN: 2T2HZMDA0LC212244, registered to

OMAR SHARIFF OMAR-HASHIM;

nn. 2021 Range Rover, VIN: SALWV2SE2MA776221, registered to

ABDINSANIR ABSHIR;

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CASE 0:22-cr-00223-NEB-TNL Doc. 1 Filed 09/13/22 Page 57 of 58

oo. The real property located at 2722 Park Avenue South,

Minneapolis, Minnesota;

pp. The real property located at 2742 Park Avenue South,

Minneapolis, Minnesota;

qq. The real property located at 5150 Alvarado Lane, Plymouth,

Minnesota;

rr. The real property located at 2529 12th Avenue South,

Minneapolis, Minnesota;

ss. The real property located at 8432 Noble Avenue, North Brooklyn

Park, Minnesota, known previously as Kelly’s 19th Hole.

tt. The real property located at 15101 County Road 5, Burnsville,

Minnesota;

uu. The real property located at 1336 Vincent Avenue N,

Minneapolis, Minnesota;

vv. The real property located at 185 Harness Way, Delaware, Ohio;

and

ww. The real property located at 2435 Stelzer Road, Columbus, Ohio.

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CASE 0:22-cr-00223-NEB-TNL Doc.1 Filed 09/13/22 Page 58 of 58

If any of the above-described forfeitable property is unavailable for forfeiture,
the United States intends to seek the forfeiture of substitute property as provided for
in Title 21, United States Code, Section 853(p) as incorporated by Title 18, United

States Code, Section 982(b)(1) and Title 28, United States Code, Section 2461(c).

A TRUE BILL

UNITED STATES ATTORNEY FOREPERSON

58


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