Complaint as to Chris Recamier. In Violation of 18 U.S.C. 1031 — USA v. Ilori et al. (Dkt. 1, S.D.N.Y.)

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U.S. District Court for the Southern District of New York · No. 1:21-cr-00746-MKV · Doc. 1 · 2021-10-08 · Docket on CourtListener

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ORIGINAL 
Approved : 
Before : 
DANIEL G. NESSIM 
Assistant United States Attorney 
THE HONORABLE KATHARINE H. PARKER 
United States Magistrate Judge 
Southern District of New York 
- - - - - - - - - - -x 
UNITED STATES OF AMERICA 
-
v . -
CHRIS RECAMI ER , 
· Defendant . 
- - - - - - - - - - - - - - - - - -x 
SOUTHERN DISTRICT OF NEW YORK, ss.: 
21 MAG 971 0 
SEALED COMPLAINT 
Violations of 
18 U. S.C . §§ 1028A, 
1031, 1343, 
1344, 134 9 & 1956 
COUNTY OF OFFENSE: 
NEW YORK 
KERWIN JOHN , being duly sworn, deposes and says that he is 
a Special Agent with the Department of Justice, Office of the 
Inspector Gene r al ("DOJ- OIG") , and charges as follows : 
COUNT ONE 
(Major Fraud Against the United States) 
1. 
From at least in or about August 202 0 through at least 
i n or about October 2021 , in the Southern District of New York and 
elsewhere, CHRIS RECAMI ER, the defendant , willfully and knowingly 
executed, and attempted to execute, a scheme and artifice with the 
i ntent to defraud the Uni ted States , 
and to obtain money and 
property 
by 
means 
of 
false 
and 
fraudulent 
pretenses, 
representations, a nd promises , in a grant, contract, subcontract, 
subsidy , 
l oa n , 
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 , 
RECAMIER engaged in a 
scheme to 
obtain , 
by 
means 
of 
false 
and 
fraudulent 
pretenses, 
representations , 
and 
documents , 
more 
than 
$ 7 
million 
in 
Government - guarant eed loans fo r several companies controlled by 
RECAMIER (collecti vely , the "Companies " ) , through a loan program 
of the United States Small Business Administration (the "SBA" ) 
designed to provide relief to small businesses during the novel 
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coronavirus/COVID- 19 
pandemic, 
namely the 
Paycheck Protection 
Program (the "PPP"). 
(Title 18 , United States Code, Sections 1031 and 2.) 
COUNT TWO 
(Conspiracy to Commit Wire and Bank Fraud) 
2 . 
From at least in or about August 2020 through at least 
in or about October 2021 , in the Southern District of New York and 
elsewhere, CHRIS RECAMIER, the defendant, and others known and 
unknown, 
willfully 
and 
knowingly, 
did 
combine, 
conspire, 
confederate, and agree together and with each other to commit: (a) 
wire fraud, in violation of Title 18, United States Code, Section 
1343; and (b) bank fraud, in violation of Title 18, United States 
Code, Section 1344 . 
3. 
It was a part and an object of the conspiracy that CHRIS 
RECAMIER, the defendant, and others known and unknown, willfully 
and knowingly, having devised and intending to devise a scheme and 
artifice to defraud and for obtaining money and property by means 
of false and fraudulent pretenses, representations, and promises, 
would and did transmit and cause to be transmitted by means of 
wire, 
radio , 
and television communication in interstate and 
foreign commerce, writings, signs, signals, pictures, and sounds 
for the purpose of executing such scheme and artifice, in violation 
of Title 18, United States Code, Section 1343. to wit, RECAMIER 
and others known and unknown, engaged in a scheme to fraudulently 
obtain Government - guaranteed loans for the Companies from the SBA 
and financial institutions through the 
PPP, 
by making false 
statements and submitting fraudulent documents in support of loan 
applications, 
including 
through 
electronic 
communications 
transmitted into and out of the Southern District of New York. 
4 . 
It was further a part and an object of the conspiracy 
that CHRIS RECAMIER, the defendant, and others known and unknown, 
willfully and knowingly, would and did execute and attempt to 
execute, a scheme and artifice to defraud a financial institution, 
the deposits of which were then insured by the Federal Deposit 
Insurance Corporation, 
and to obtain moneys, 
funds, 
credits, 
assets, securities, and other property owned by, and under the 
custody and control of, such financial institution, by means of 
false and fraudulent pretenses, representations, and promises, in 
violation of Title 18 , United States Code, Section 1344, to wit, 
RECAIMER and others known and unknown, engaged in a scheme to 
obtain, 
by 
means 
of 
false 
and 
fraudulent 
pretenses, 
representations , 
and documents, Government-guaranteed loans for 
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the Companies from FDIC- insured banks through the PPP. 
(Title 18, United States Code, Section 1349.) 
COUNT THREE 
(Bank Fraud) 
5 . 
From at least in or about August 2020 through at least 
in or about October 2021, in the Southern District of New York and 
elsewhere, CHRIS RECAMIER, the defendant, willfully and knowingly 
executed, 
and attempted to execute, 
a 
scheme and artifice to 
defraud a financial institution, the deposits of which were insured 
by the Federal Deposit Insurance Corporation 
("FDIC" ) , 
and to 
obtain moneys, 
funds , 
credits, assets, 
securities, 
and other 
property owned by, and under the custody and control of, such 
financial institution, by means of false and fraudulent pretenses, 
representations and promises, to wit, RECAMIER engaged in a scheme 
to 
obtain, 
by 
means 
of 
false 
and 
fraudulent 
pretenses, 
representations, and documents, Government-guaranteed loans for 
the Companies from FDIC- insured banks through the PPP. 
(Title 18, United States Code, Sections 1344 and 2.) 
COUNT FOUR 
(Wire Fraud) 
6 . 
From at least in or about August 2020 through at least 
in or about October 2021, in the Southern District of New York and 
elsewhere, 
CHRIS 
RECAMIER, 
the defendant, 
having devised and 
intending t o devise a scheme and art if ice 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, which affected a financial 
institution , to wit, RECAMIER engaged in a scheme to fraudulently 
obtain Government - guaranteed loans for the Companies from the SBA 
and financial ins ti tut ions through the PPP, by making false statements 
and submitting fraudulent documents in support of loan applications, including 
through electronic communications transmitted into and out of the 
Southern District of New York. 
(Title 18, United States Code, Sections 1343 and 2.) 
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COUNT FIVE 
(Aggravated Identi ty Theft) 
7. 
From at least in or about August 2020 through at least 
in or about October 2021, CHRIS RECAMIER, the defendant, knowingly 
did transferred , possessed, and used, without lawful authority, a 
means of identification of another person, during and in relation 
to a felony violation enumerated in Title 18, United States Code, 
Section 1028A(c) , to wit, RECAMIER used the name and identity of 
at least two different people in connection with the submission of 
fraudulent 
loan applications 
and supporting documentation to 
multiple financial institutions during and in relation to the fraud 
offenses charged in Counts One through Four of this Complaint. 
(Title 18, United States Code, Sections 1028A(a) (1), (b ) 
& 
( c) ( 4 ) - ( 5) , and 2 . ) 
COUNT SIX 
(Conspiracy to Commit Money Laundering ) 
8 . 
From at least in or about August 2020, through at least 
in or about October 2021, CHRIS RECAMIER, the defendant, and others 
known 
and 
unknown , 
intentionally and 
knowingly did 
combine, 
conspire, confederate and agree together and with each other to 
commit money laundering, in violation of Title 18, United States 
Code , Section 1956 (a) (1) (B) (i). 
9 . 
It was a part and an object of the conspiracy that CHRIS 
RECAMIER, 
the defendant, and others known and unknown, 
knowing 
that the property involved in certain financial transactions 
represented the proceeds of some form of unlawful activity, would 
and did conduct and attempt to conduct such financial transactions, 
which in fact involved the proceeds of specified unlawful activity, 
to wit, the wire and bank fraud offenses charged in Counts and One 
through Four of this Complaint, knowing that the transactions were 
designed in whole or in part to conceal and disguise the nature, 
the location , the source , the ownership, and the control of the 
proceeds of specified unlawful activity, in violation of Title 18, 
United States Code , Section 1956(a) (1) (B) (i). 
(Title 18 , United States Code, Section 1956(h) . ) 
The bases for my knowledge and for the foregoing charges 
are, in part, as follows: 
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10. 
I am a Special Agent with the DOJ-OIG and I have been 
personally involved in the investigation of this matter. 
This 
affidavit 
is 
based 
upon 
my 
personal 
participation 
in 
the 
investigation 
of 
this 
matter, 
my 
conversations 
with 
law 
enforcement 
agents, 
witnesses, 
and 
others, 
as 
well 
as 
my 
examination of report and records. 
Because this affidavit is being 
submitted for the limited purpose of establishing probable cause, 
it does not include all the facts that I have learned during the 
course of my investigation. 
Where the contents of documents and 
the actions, statements, and conversations of others are reported 
herein, they are reported in substance and in part, except where 
otherwise indicated. 
Where figures, calculations, and dates are 
set forth herein, they are approximate, unless stated otherwise. 
Overview of the Fraudulent Conduct 
11. 
From at least in or about August 2020 through at least 
in or about May 2021, 
CHRIS RECAMIER, 
the defendant, used the 
identities of at least two other indi victuals to submit online 
applications for 
a 
total of over 
$7 million in government-
guaranteed loans for the Companies through the SBA' s 
PPP. 
In 
connection with these loan applications, 
RECAMIER represented, 
among other things, that other individuals were the sole owners of 
the Companies 
and that the Companies together had over 
230 
employees and paid a total of approximately $3.2 million in wages 
to those employees on a monthly basis. 
RECAMIER applied for these 
loans using the stolen identities of two indi victuals ("ID Theft 
Victim- 1" and "ID Theft Victim- 2," and together, the "ID Theft 
Victims"), including by submitting fraudulent driver's licenses 
and other identity information of the ID Theft Victims to financial 
institutions . RECAMIER also submitted multiple purported IRS tax 
filings that were not actually filed with the IRS. 
12 . 
Based on the PPP loan applications submitted by CHRIS 
RECAMI ER, the defendant , a total of more than $700,000 in PPP loans 
were approved for the Companies, 
and at least approximately 
$700 , 000 in PPP loan proceeds were deposited into bank accounts 
RECAMIER opened and was an authorized signatory on. 
Based on my 
review of bank records received to date, instead of using the PPP 
loan proceeds for payroll costs, mortgage interest, rent, and/or 
utilities for the purported Companies, as required by the PPP, and 
as certified to the banks, RECAMIER and other participants in the 
fraud and identity theft scheme used at least approximately 
$534,000 of the fraudulently obtained loan proceeds he received as 
follows: 
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a . 
A total of at least approximately $424,300 in PPP 
loan proceeds was transferred to a cryptocurrency account in the 
name of ID Theft Victim- 1 (the "Cryptocurrency Account"). 
b. 
A total of at least approximately $50,000 in PPP 
loan proceeds was transferred to a stock trading platform in the 
name of ID Theft Victim- 1 (the "Trading Account"). 
c . 
A total of at least approximately $60,000 in PPP 
loan proceeds was withdrawn in cash. 
Background on SBA Lending in Response to COVID-19 
13. 
The SBA is a federal agency of the Executive Branch that 
administers 
assistance 
to 
American 
small 
businesses. 
This 
assistance includes guaranteeing loans that are issued by certain 
lenders to qualifying small businesses. 
Under the 
SBA 
loan 
guarantee programs, the actual loan is issued by a commercial 
lender, but the lender receives the full faith and credit backing 
of the United States Federal Government on a percentage of the 
loan . 
Therefore, if a borrower defaults on an SBA-guaranteed loan, 
the commercial lender may seek reimbursement from the SBA, up to 
the percentage of the guarantee. 
By 
reducing the risk to 
commercial lenders, the SBA loan guarantee programs enable lenders 
to provide loans to qualifying small businesses when financing is 
otherwise unavailable to them on reasonable terms through normal 
lending channels. 
When a borrower seeks an SBA-guaranteed loan, 
the borrower must meet both the commercial lender's eligibility 
requirements for the loan as well as the 
SBA's eligibility 
requirements . 
14 . 
The 
Coronavirus Aid , 
Relief, 
and 
Economic Security 
("CARES " ) Act is a federal law enacted on March 29, 2020 designed 
to provide emergency financial assistance to the millions of 
Americans who are suffering the economic effects caused by the 
COVID- 19 pandemic . 
One source of relief provided by the CARES Act 
was the authorization of up to $349 billion in forgivable loans to 
small businesses for job retention and certain other business 
expenses through the 
PPP . 
On April 24, 
2020, 
the Paycheck 
Protection Program and Health Care Enhancement Act was signed into 
law, authorizing over $300 billion in additional PPP funding. 
15 . 
The PPP allows qualifying small businesses and other 
organizations to receive unsecured SBA-guaranteed loans with a 
maturity of two years and interest rate of one percent. 
PPP loan 
proceeds must be used by businesses on payroll costs, mortgage 
interest , rent, and/or utilities . 
The PPP allows the interest and 
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principal to be forgiven if businesses spend the proceeds on these 
expenses under certain conditions. 
Pursuant to the CARES Act, the 
amount of PPP funds a business is eligible to receive is determined 
by the number of employees employed by the business and their 
average payroll costs . 
Businesses applying for a PPP loan must 
provide documentation to confirm that they have in the past paid 
employees the compensation represented in the loan application. 
The PPP is overseen by the SBA, which has authority over all PPP 
loans, but individual PPP loans are issued by approved commercial 
lenders who receive and process PPP applications and supporting 
documentation , and then make loans using the lenders' own funds. 
The Companies 
16. 
Based on my review of publicly available information on 
the Internet and f rom the website of the New York State Department 
of State , Division of Corporations, as well as records provided to 
financial institutions regarding the Companies, I have learned the 
following , in substance and in part: 
a . 
APPSERD Incorporated (" Company- 1") is a New York 
Corporation that was formed on or about April 2, 2014. The name 
for its service of process is provided as "The Corporation," and 
its service - of- process address is a residential address in Midtown 
Manhattan . 
b. 
M2 Gold Jet LLC ("Company- 2") is a New York Limited 
Liability Company that was formed on or about March 6, 2012. The 
name for its servi ce of process is provided as "The LLC," and its 
service-of- process address is a residential address on Seventh 
Avenue , in Brooklyn , New York (the "Seventh Avenue Address") 
c . 
APPSENSIBLE. COM 
LLC 
( "Company-3") is a 
New York 
Limited Liability Company that was formed on or about January 22, 
2016 . The name for its service of process is provided as "The LLC," 
and its service- of- process address is an address in Buffalo, New 
York . 
d. 
BRS Consul ting Corporation ( "Company-4") is a New 
York Corporation that was formed on or about April 1, 2016. The 
name for its service of process is provided as "The Corporation," 
and its service - of- process address is an address in Midtown 
Manhattan. 
The PPP Loan Application for Company-1 
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17 . 
Based on my review of records in connection with a PPP 
loan 
application 
for 
Company- 1 
submitted 
to 
a 
FDIC-insured 
financial 
ins ti tut ion 
headquartered 
in 
Buffalo, 
New 
York 
("Bank- 1"), I have learned the following, in substance and in part: 
a. 
On or about March 15 , 
2021, 
ID Theft Victim-1 
purportedly submitted an application to Bank- 1 for a PPP loan in 
the amount of $4 , 409 , 560 for Company-1. 
The loan application 
represented, among other things , the following , in substance and 
in part: 
i. 
Company-1 had 79 employees and a total average 
monthly payroll of $1 , 763,824 . 
ii . 
Company- 1 was located at a residential address 
on Seventh Street, in Brooklyn (the "Seventh Street Address"). 
The documents also provided a second address located on Bleecker 
Street in Manhattan (the "Bleecker Street Address" ) . 
iii . 
ID Theft Victim- 1 was listed as the sole owner 
and President of Company- 1 . 
iv . 
The 
purposes 
of 
the 
loan 
included: 
(a ) 
payroll; (b) "covered supplier costs"; and (c) "covered operations 
expenditures." 
v . 
The 
information 
provided 
in 
the 
loan 
application and all supporting documents and forms was certified 
as "true , accurate , and correct . " 
vi . 
The business phone number for Company-1 was a 
phone number ending in 0642 (the "0642 Number" ) . 
b . 
CHRIS 
RECAMIER, 
the defendant, 
submitted this 
application in person at a Bank- 1 location in Manhattan, New York. 
c . 
I n order to support the representations regarding 
the number of employees and average monthly payroll for Company-1 
in the loan application , the following documents were provided to 
Bank- 1 , among others : 
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i. 
A purported, undated, IRS Form 940 (Employer's 
Annual Federal Unemployment ("FUTA" ) Tax Return) 1 for Company-1, 
which was purportedly signed electronically by ID Theft Victim-1 
and reported total payments of $6,686,381 to employees in 2019. 
ii. 
A purported IRS Form 941 (Employer's Quarterly 
Federal Tax Return) 2 for Company-1 for the first quarter of 2019, 
dated April 24, 2020, which was purportedly signed electronically 
by a person listed as the Chief Executive Officer of Company-1 
(the "Alleged CEO") and reported total payments of $1,897,523 to 
18 employees in the first quarter of 2019. 
iii. 
A purported IRS Form 941 for Company-1 for the 
second quarter of 2019, dated July 20, 2020, which was purportedly 
signed electronically by the Alleged CEO 
and reported total 
payments of $1,483,980 to 79 employees in the second quarter of 
2019. 
iv. 
A purported IRS Form 941 for Company-1 for the 
third quarter 
of 
2019, 
dated 
October 
26 , 
2020, 
which 
was 
purportedly signed electronically by the Alleged CEO and reported 
total payments of $1,541,054 to 79 employees in the third quarter 
of 2019 . 
v. 
A purported IRS Form 941 for Company-1 for the 
fourth quarter of 
2019, 
dated January 
17, 
2020, 
which 
was 
purportedly signed electronically by the Alleged CEO and reported 
total payments of $1,763,824 to 18 employees in the fourth quarter 
of 2019 . 
vi. 
An unsigned purported IRS individual income 
tax return for ID Theft Victim-1 for tax year 2019. 
The form 
claims $384,656 in taxable income, and provides a home address of 
the Seventh Street Address. 
The return also includes a Schedule 
C claiming profit or loss from a business, claiming that Company-1, 
1 
IRS Form 940 is used to report an employer's annual FUTA tax. 
Together with state unemployment tax systems, the FUTA tax provides 
funds for paying unemployment compensation to workers who have 
lost their jobs. 
2 
IRS Form 941 is used to report wages a business has paid as well 
as employment taxes withheld on a quarterly basis. 
Form 941 is 
generally due by the last day of the month following the end of 
the quarter. 
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located at the Bleecker Street Address, had $10,385,095 in gross 
receipts and net profit of $384,656. 
d . 
The indi victual claiming to be ID Theft Victim-1 
provided Bank- 1 with the O 652 Number. In his interactions with 
Bank- 1, the individual claiming to be ID Theft Victim- 1 submitted 
a particular New Jersey Driver ' s license in ID Theft Victim- l's 
name with a license number ending in 16073 
(the "New Jersey 
License") . 
e. 
Bank- 1 denied the loan application for Company-1. 
The PPP Loan Application for Company- 2 
18 . 
Based on my review of records in connection with a PPP 
loan application for Company- 2 submitted to an FDIC- insured lender 
headquartered in 
New 
Jersey 
("Bank- 2"), 
I 
have 
learned the 
following, in substance and in part: 
a . 
On or about March 15, 
2021, 
ID Theft Victim-2 
purportedly submitted an online application to Bank-2 for a PPP 
loan in the amount of $172 , 573 for Company-2. 
The loan application 
represented, among other things, the following, in substance and 
in part: 
i. 
Company-2 had 18 employees and a total average 
monthly payroll of $69,030 . 
ii. 
Company- 2 was located at the Seventh Avenue 
Address . 
iii . 
ID Theft Victim-2 was the sole owner and Chief 
Executive Officer of Company-2 . 
iv . 
The 
information 
provided 
in 
the 
loan 
application and all supporting documents and forms was certified 
as "true and accurate in all material respects." 
b . 
In order to support the representations regarding 
the number of employees and average monthly payroll for Company-2 
in the loan application, Bank- 2 was provided with a purported 
undated IRS Form 940 for Company- 2 for 2019, which was purportedly 
signed electronically by ID Theft Victim- 2, as Chief Executive 
Officer of Company- 2, and reported total payments of $828,354 to 
employees in 2019 . 
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c. 
On or about March 1 7, 
2 021, 
Bank-2 approved a 
$172,573 PPP loan to Company-2. 
ID Theft Victim-2 purportedly 
signed the promissory note for the loan electronically on or about 
March 18, 2021. 
19. 
Based on my review of bank records relating to the 
Companies, 
I have learned, in substance and in part, that the 
$172,573 PPP loan to Company-2 was disbursed on or about March 22, 
2021, to an account in the name of Company-2, purportedly opened 
by 
ID 
Theft Victim-1, 
and maintained at 
a 
commercial 
bank 
("Bank-3"). 
In documents submitted to Bank-3 in opening this 
account in Company-2' s name, 
ID Theft Victim-1, using the 0642 
Number, 
was listed as the owner of Company-2. In opening this 
account, the individual claiming to be ID Theft Victim-1 submitted 
the New Jersey License. This Company-2 account had a balance of 
approximately $170 prior to the loan disbursement. 
A portion of 
the loan proceeds issued to Company-2 was spent by CHRIS RECAMIER, 
the defendant, as described above in paragraph 12. Among other 
things, on or about March 26, 2021, approximately $140,000 was 
transferred to a bank account in the name of Company-3. 
20. 
Based on my review of records maintained by the New York 
Department of Motor Vehicles, I have learned that the driver's 
license in 
ID Theft Victim-2's 
name 
provided to Bank-2 
was 
fraudulent and was not actually issued. 
Based on my review of 
databases compiling publicly available identifying information, I 
have learned that the individual depicted in the driver's license 
is not in fact ID Theft Victim-2, who is a real person with the 
name used by CHRIS RECAMIER, the defendant, living in New York 
state. 
The PPP Loan Application for Company-3 
21. 
Based on my review of records in connection with a PPP 
loan application for Company-3 submitted to an FDIC-insured lender 
headquartered 
in 
Manhattan 
("Bank-4"), 
I 
have 
learned 
the 
following, in substance and in part: 
a. 
On or about March 2 6, 
2 02 0, 
ID Theft Victim-1 
purportedly submitted an application to Bank-4 for a PPP loan in 
the amount of $2,163,560 for Company-3. 
The application was 
submitted at a 
Bank-4 branch located in Manhattan. 
The loan 
application represented, among other things, the following, in 
substance and in part: 
i. 
Company-3 had 70 employees and a total average 
monthly payroll of $865,424. 
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ii. 
ID 
Theft 
Victim-1 
was 
the sole 
owner 
of 
Company-1 . 
iii. 
The 
information 
provided 
in 
the 
loan 
application and all supporting documents and forms was certified 
as "true and accurate in all material respects." 
iv. 
0642 Number. 
The contact phone number for Company-3 was the 
b. 
In order to support the representations regarding 
the number of employees and average monthly payroll for Company-3 
in the loan application, the following documents were provided to 
Bank-4: 
i. 
An undated purported IRS Form 940 for Company-
3 for 2019, which was purportedly signed electronically by ID Theft 
Victim-1 and reported total payments of $6,180,556 to employees in 
2019. This form placed Company-3 at the Bleecker Street Address. 
ii. 
A purported IRS Form 941 for Company-3 for the 
first quarter of 2019, dated April 24, 2020, which was purportedly 
signed electronically by ID Theft Victim-1 and reported total 
payments of $1,897,523 to 70 employees in the first quarter of 
2019. This form placed Company-3 at the Bleecker Street Address. 
iii. 
A purported IRS Form 941 for Company-3 for the 
second quarter of 2019, dated July 20, 2020, which was purportedly 
signed electronically by ID Theft Victim-1 and reported total 
payments of $1,493,980 to 70 employees in the second quarter of 
2019 . This form placed Company-3 at the Bleecker Street Address. 
iv. 
A purported IRS Form 941 for Company-3 for the 
third quarter 
of 
2019, 
dated 
October 
26, 
2020, 
which 
was 
purportedly 
signed electronically by 
ID 
Theft 
Victim-1 
and 
reported total payments of $1,541,054 to 70 employees in the third 
quarter of 2019. This form placed Company-3 at the Bleecker Street 
Address. 
v. 
A purported IRS Form 941 for Company-3 for the 
fourth quarter of 
2019, 
dated 
January 
17, 
2021, 
which 
was 
purportedly 
signed electronically by 
ID 
Theft 
Victim-1 
and 
reported total payments of $1,763,824 to 70 employees in the fourth 
quarter of 2019. This form placed Company-3 at the Bleecker Street 
Address. 
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vi . 
An unsigned purported IRS indi victual income 
tax return for ID Theft Victim- 1 for tax year 2019 . The form claims 
$384 , 656 in taxable income, and provides a home address of the 
Seventh Street Address . 
The return also includes a Schedule C 
claiming profit or loss from a business , claiming that Company-3, 
located at the Bleecker Street Address, had $10 , 385,095 in gross 
receipts and net profit of $384 , 656. 
c . 
Bank- 4 denied the loan application for Company- 3 . 
The PPP Loan Application for Company- 4 
22 . 
Based on my review of records in connection with a PPP 
loan application for Company- 4 submitted to an FDIC- insured lender 
headquartered 
in 
Virginia 
( "Bank- 5") , 
I 
have 
learned 
the 
following , in substance and in part : 
a . 
On or about April 13, 
2021, 
ID Theft Victim-1 
purportedly submitted an application to Bank- 5 for a PPP loan in 
the amount of $531 , 218 for Company- 4 . 
The loan application 
represented , among other things , the following , in substance and 
in part : 
i . 
Company-4 had 70 employees and a total average 
monthly payroll of $212 , 488 . 
ii . 
Company- 4 
was 
located 
at 
Address - 2, 
a 
residential address in Brooklyn , New York. 
iii . 
ID Theft Victim-1 was the sole owner and Chief 
Executive Officer of Company-4. 
iv . 
The individual claiming to be ID Theft Victim-
1 provided the 0642 Number to Bank- 4 as a point of contact. The 
individual claimi ng to be ID Theft Victim-1 also presented Bank-4 
with the New Jersey License . 
v . 
The purposes of the loan were "payroll costs," 
"covered worker protection expenditures," and "covered operations 
expenditures . " 
The individual claiming to be ID Theft Victim-1 
initialed a provision certifying that "the funds will be used to 
retain workers and maintain payroll; or make payments for mortgage 
interest, rent , utilities, covered property damage costs, covered 
supplier costs, and covered worker protection expenditures, and 
not more than 40% of the forgiven amount may be for non- payroll 
costs . " 
As described above, this representation was false in light 
of the misuse of the PPP loan proceeds by CHRIS RECAMIER, 
the 
13 
Case 1:21-cr-00746-MKV     Document 1     Filed 10/08/21     Page 13 of 18

defendant, and other scheme participants, including in substantial 
part, 
the 
proceeds 
of 
this 
loan, 
toward 
cryptocurrency 
investments, other investments, and cash withdrawals, as described 
above in paragraph 12 . 
vi. 
The individual claiming to be ID Theft Victim-
1 represented that neither Company-4 nor Identity Theft Victim-1 
owned "any other business." 
Based on my involvement in this 
investigation, including the information described above, this 
statement is contradicted by representations CHRIS RECAMIER, the 
defendant, and other scheme participants made to other financial 
institutions concerning Identity Theft Victim-l's 
b . 
The information provided in the loan application 
and all supporting documents and forms was "true and accurate in 
all material respects." ID Theft Victim-1 purportedly signed the 
loan application electronically on or about May 16, 2021. 
c . 
In order to support the representations regarding 
the number of employees and average monthly payroll for Company-4 
in the loan application, the following documents were provided to 
Bank- 5: 
i. 
A purported IRS Form 1120 U.S. Corporation 
Income Tax Return for tax year 2019, dated March 11, 2020, which 
was purportedly signed electronically by ID Theft Victim-1 as 
President of Company-4. This tax return claimed gross receipts of 
$10,385,095 and salaries and wages of $6,180,556, 
among other 
items . 
d. 
On 
or about 
May 
$531,218 PPP loan to Company- 4 . 
signed the promissory note for the 
May 16, 2021. 
15, 
2021, 
Bank-5 
approved 
a 
ID Theft Victim-1 purportedly 
loan electronically on or about 
23 . 
Based on my review of bank records relating to the 
Companies , 
I have learned, in substance and in part, that the 
$531 , 218 PPP loan to Company-4 was disbursed to an account in the 
name of Company- 4 solely controlled by ID Theft Victim-1, which as 
described 
in 
further detail 
below, 
I 
believe 
was 
actually 
controlled by CHRIS RECAMIER, the defendant. This account had a 
balance of approximately $170 prior to the loan disbursement . 
A 
portion of the loan proceeds issued to Company-4 was spent by 
RECAMIER as described above in paragraph 12. 
14 
Case 1:21-cr-00746-MKV     Document 1     Filed 10/08/21     Page 14 of 18

Information Obtained from the Internal Revenue Service 
24. 
Based on my conversations with law enforcement officers 
and information obtained from the IRS, 
I have learned that for 
Company-1 , Company- 2 , Company- 3, and Company-4, either (i) no IRS 
filings were made at all by such company, 
(ii) no such company 
could be 
located in 
IRS 
systems, 
or 
(iii) 
the 
information 
concerning the company did not match the information provided in 
the documents submitted by CHRIS RECAMIER, the defendant, and other 
coconspirators , in support of the PPP loans for the Companies. 
Evidence of Attribution of Fraudulent Loan Applications to 
RECAMIER 
25 . 
As 
part 
of 
my 
review 
of 
records 
provided 
by 
a 
cryptocurrency 
exchange 
( the 
"Exchange") 
relating 
to 
the 
Cryptocurrency Account , 
I 
have reviewed the know-your-customer 
information provided by the user of that Account. Based on this 
review, I have seen the New Jersey License in ID Theft Victim-l's 
name . The New Jersey License is the same form of identification 
submitted to Bank- 1 and Bank-3 in opening accounts in the names of 
Company- 1 and Company- 2, as described above in paragraphs 17 and 
19 . 
I 
have also seen photographs taken by the user of the 
Cryptocurrency Account of himself and submitted to the Exchange. 
Based on my comparison of the driver's license photograph and the 
photographs submitted to the Exchange, I believe they depict the 
same person , CHRIS RECAMIER, the defendant . 
2 6 . 
Based on my review of records maintained by the New 
Jersey Motor Vehicle Commission , I have learned that the New Jersey 
License is a fraudulent license that was not actually issued by 
the state of New Jersey . I have also learned that the real ID Theft 
Victim-1 lives in New Jersey and is not the person depicted on the 
New Jersey License. 
27. 
As described above, the same phone number, the 0642 
Number , 
was provided to banks in connection with Company-1, 
Company- 2 , 
Company- 3 , 
and 
Company-4, 
as 
described 
above 
in 
paragraphs 17, 19 , 21 , and 22. 
Based on my involvement in this 
investigation , conversations with others, and surveillance, I know 
that CHRIS RECAMIER, the defendant, used the 0642 Phone to interact 
with employees at financial institutions concerning attempted PPP 
loans . 
I have also learned that at least one other individual not 
named as a co- conspirator herein ("CC-1") has possessed the phone 
assigned the 0642 Number . 
15 
Case 1:21-cr-00746-MKV     Document 1     Filed 10/08/21     Page 15 of 18

28. 
As described above, the same purported personal income 
tax returns in ID Theft Victim-l's name were submitted to Bank-1 
and Bank-4 in connection with the attempted PPP loans relating to 
Company-1 
and 
Company-3, 
as 
described 
above 
in 
paragraphs 
17 (c) (vi) 
and 21 (b) (vi) . 
Although these documents were almost 
identical, the relevant company responsible for ID Theft Victim-
l's purported income was altered to match the company for which 
PPP funds were sought. 
2 9. 
Based on my review of records related to the Trading 
Account, I have learned that between on or about May 7, 2021 and 
on or about July 15, 2021, the Trading Account was accessed from 
a particular internet protocol ("IP" ) Address ("IP Address-1") . 3 
This time period coincides with the time that proceeds from the 
Company-4 loan were transferred into the Trading Account, 
as 
described above in paragraph 12. 
Based on records obtained from 
an internet service provider, I have learned that, during this 
timeframe, IP Address-1 was assigned to a particular apartment in 
Long Island City, Queens (the "Long Island City Apartment"). 
Based 
on my review of records produced by the property management company 
that manages the Long Island City Apartment, I have learned that 
the Long Island City Apartment was purportedly rented by an 
identity theft victim ("ID Theft Victim-3" ), with the individual 
claiming to be ID Theft Victim-3 taking possession of the Long 
Island City Apartment on or about May 1, 2021. 
The individual 
claiming to be ID Theft Victim-3 provided the 0642 Number as that 
individual's contact number. 
The indi victual claiming to be ID 
Theft Victim-3 submitted a New York driver's license in the name 
of ID Theft Victim-3, as well as a photograph that the individual 
claiming to be ID Theft Victim-3 took of himself. 
Based on my 
review of this driver's license and photograph, 
I have learned 
that both depict CHRIS RECAMIER, the defendant. 
Based on my review 
of records maintained by the New York Department of Motor Vehicles, 
I have learned that the driver's license in ID Theft Victim- 3's 
name provided in connection with renting the Long Island City 
Apartment was fraudulent and was not actually issued. 
30. 
Based on my involvement in this investigation and my 
training and experience, I have learned that, on or about July 28, 
2021 , 
law enforcement officers separately presented a set of 
photographs- including a photograph of the individual depicted in 
3 Based on my training and experience, 
each electronic device 
connected to the Internet must be assigned a unique IP address so 
that communications from or directed to that electronic device are 
routed properly. 
16 
Case 1:21-cr-00746-MKV     Document 1     Filed 10/08/21     Page 16 of 18

the Cryptocurrency Account photographs-to two employees of Bank- 1 
who had interacted directly with CHRIS RECAMIER, the defendant. 
Both Bank- 1 employees identified the individual depicted in the 
photographs as the person with whom they had interacted concerning 
Company- 1 , the attempted PPP loan, and other accounts. 
31. 
Based on my involvement in this investigation, and my 
conversation with other law enforcement officers, I have learned 
that a United States Magistrate Judge in the Southern District of 
New York issued a tracking warrant for the 0642 Number. 
I have 
learned that on or about September 8, 
2021, while conducting 
surveillance based on GPS location information obtained pursuant 
to the tracking warrant, 
law enforcement observed the person 
depicted in the New Jersey License, that is CHRIS RECAMIER, the 
defendant, in Manhattan, 
New York . 
Law enforcement has also 
observed CC- 1 in possession of the cellphone assigned to the 0642 
Number . 
32. 
Based on my training and experience and my familiarity 
this investigation as set forth above, including the relationship 
between and among CHRIS RECAMIER , the defendant, and the Companies 
based on shared physical addresses, shared phone numbers, shared 
employees , tax documents purportedly prepared and signed by the 
same persons, and the common investment accounts and financial 
institution accounts in the name of ID Theft Victim-1, I believe 
that RECAMIER 
was involved in submitting the fraudulent loan 
applications for the Companies and had access to and control over 
the fraudulent loan proceeds received by the Companies. 
The Defendant's Arrest 
33. 
Based 
on 
my 
involvement in this investigation and 
conversations with other law enforcement officers, I have learned 
that on or about October 7, 2 021, law enforcement searched the 
Long Island City Apartment 
and arrested CHRIS 
RECAMIER, 
the 
defendant , pursuant to a search warrant. 
A search of the Long 
Island Apar tment recovered, among other things , documents in the 
name of companies used by RECAMIER and other co- conspirators in 
the course of the fraud and identity theft scheme . 
After his 
arrest , RECAMIER was advised of his Miranda rights, waived those 
rights , and made the following video-recorded statements to law 
enforcement , in substance and in part: 
a . 
RECAMIER acknowledged using false driver's licenses 
and other identifying documents in the name of third parties, some 
of which bear RECAMIER's photograph . 
17 
Case 1:21-cr-00746-MKV     Document 1     Filed 10/08/21     Page 17 of 18

b. 
RECAMIER worked with a particular co-conspirator 
("CC-1") to fraudulently apply for COVID- 19 relief loans, up to 
and including the time of his arrest on or about October 7, 2021. 
c . 
CC- 1 maintains approximately 15-20 fake identity 
cards used by RECAMIER and CC- 1 in furtherance of the fraud and 
identity theft scheme described in this Complaint. 
WHEREFORE, 
I respectfully request that CHRIS RECAMIER, the 
defendant , be imprisoned or bailed, as the case may be. 
KERWIN JOHN 
Special Age 
Department of Justice, 
Office of the Inspector General 
Sworn to me , 
this 8th day of October, 2021 
THE ~ 
tL~S. 
PAR 
UNITED STATES MAGISTRATE JUDGE 
SOUTHERN DISTRICT OF NEW YORK 
18 
Case 1:21-cr-00746-MKV     Document 1     Filed 10/08/21     Page 18 of 18

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