Court filing
INDICTMENT as to Anuli Okeke (1) count(s)… — INDICTMENT as to Anuli Okeke (1) count(s) 1, 2, 3, 4 — USA v.… (Dkt. 12)
Filed January 12, 2022 in Docket NYED 474435, the only filing from this case in the archive.
Record facts
| Court | U.S. District Court for the Eastern District of New York |
|---|---|
| Filed | 2022-01-12 |
U.S. District Court for the Eastern District of New York · No. 1:22-cr-00020-FB · Doc. 12 · 2022-01-12 · Docket on CourtListener
Full text
DCP:CWE F. #2020R00955 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ---------------------------X UNITED STATES OF AMERICA - against - ANULI OKEKE, Defendant. ---------------------------X THE GRAND JURY CHARGES: COUNT ONE INDICTMENT Cr.No. ----------- (T. 18, U.S.C., §§ 982(a)(l ), 982(a)(2), 982(b)(l), 1343, 1344, 1349, 1956(h), 2 and 3551 etllil.; T. 21, U.S.C., § 853(p)) (Conspiracy to Commit Wire Fraud and Bank Fraud) 1. In or about and between March 2020 and August 2020, both dates being approximate and inclusive, within the Eastern District of New York and elsewhere, the defendant ANULI OKEKE, together with others, did knowingly and intentionally conspire to execute a scheme and artifice, to wit: (a) to defraud and to obtain money and property from Bank I, an entity the identity of which is known to the Grand Jury, which was a federally-insured financial institution, and the United States Small Business Administration by means of one or more materially false and fraudulent pretenses, representations and promises, and to transmit and cause to be transmitted by means of wire communications in interstate commerce, writings, signs, signals, pictures and sounds, for the purpose of executing the scheme to defraud, contrary to Title 18, United States Code, Section 1343; and 1:22-cr-00020(CBA)(JRC) Case 1:22-cr-00020-FB Document 12 Filed 01/12/22 Page 1 of 6 PageID #: 28 (b) to defraud Bank 1, a financial institution, and to obtain money, funds, credits and other property owned by and under the custody and control of Bank 1, by means of one or more materially false and fraudulent pretenses, representations and promises, contrary to Title 18, United States Code, Section 1344. (Title 18, United States Code, Sections 1349 and 3551 et seq.) COUNT TWO (Wire Fraud) 2. In or about and between March 2020 and August 2020, both dates being 2 approximate and inclusive, within the Eastern District of New York and elsewhere, the defendant ANULI OKEKE, together with others, did knowingly and intentionally devise a scheme and artifice to defraud and to obtain money and property from Bank 1 and the United States Small Business Administration by means of one or more materially false and fraudulent pretenses, representations and promises, and for the purpose of executing and attempting to execute such scheme and artifice did transmit and cause to be transmitted, by means of wire communications in interstate commerce, writings, signs, signals, pictures and sounds, to wit: electronic submission of applications and supporting documentation. (Title 18, United States Code, Sections 1343, 2 and 3551 et seq.) COUNT THREE (Bank Fraud) 3. In or about and between March 2020 and August 2020, both dates being approximate and inclusive, within the Eastern District of New York and elsewhere, the defendant ANULI OKEKE, together with others, did knowingly and intentionally execute and attempt to execute a scheme and artifice to defraud Bank 1, the deposits of which were insured by the Federal Deposit Insurance Corporation, and to obtain moneys, funds, credits and other property Case 1:22-cr-00020-FB Document 12 Filed 01/12/22 Page 2 of 6 PageID #: 29 owned by, and under the custody and control of, Bank 1 by means of one or more materially false and fraudulent pretenses, representations and promises. (Title 18, United States Code, Sections 1344, 2 and 3551 et~-) COUNTFOUR (Money Laundering Conspiracy) 4. In or about and between March 2020 and August 2020, both dates being 3 approximate and inclusive, within the Eastern District of New York and elsewhere, the defendant ANULI OKEKE, together with others, did knowingly and intentionally conspire to engage in one or more financial transactions in and affecting interstate commerce, to wit: deposits, withdrawals and transfers of funds and monetary instruments, in and affecting interstate and foreign commerce, by, though and to one or more financial institutions; in criminally derived property that was of a value greater than $10,000 and that was derived from specified unlawful activity, to wit: wire fraud, in violation of Title 18, United States Code, Section 1343, and bank fraud, in violation of Title 18, United States Code, Section 1344, contrary to Title 18, United States Code, Section l 957(a). (Title 18, United States Code, Sections 1956(h) and 3551 et seq.) CRIMINAL FORFEITURE ALLEGATIONS ASTOCOUNTSONETHROUGHTHREE 5. The United States hereby gives notice to the defendant that, upon her conviction of any of the offenses charged in Counts One through Three, the government will seek forfeiture in accordance with Title 18, United States Code, Section 982(a)(2), which requires any person convicted of such offenses to forfeit any property constituting, or derived from, proceeds obtained directly or indirectly as a result of such offenses. Case 1:22-cr-00020-FB Document 12 Filed 01/12/22 Page 3 of 6 PageID #: 30 4 6. If any of the above-described forfeitable property, as a result of any act or omission of the defendant: (a) cannot be located upon the exercise of due diligence; (b) has been transferred or sold to, or deposited with, a third party; (c) has been placed beyond the jurisdiction of the court; (d) has been substantially diminished in value; or (e) has been commingled with other property which cannot be divided without difficulty; it is the intent of the United States, pursuant to Title 21 , United States Code, Section 853(p), as incorporated by Title 18, United States Code, Section 982(b )(1 ), to seek forfeiture of any other property of the defendant up to the value of the forfeitable property described in this forfeiture allegation. (Title 18, United States Code, Sections 982(a)(2) and 982(b )(1 ); Title 21 , United States Code, Section 853(p )) CRIMINAL FORFEITURE ALLEGATION AS TO COUNT FOUR 7. The United States hereby gives notice to the defendant that, upon her conviction of the offense charged in Count Four, the government will seek forfeiture in accordance with Title 18, United States Code, Section 982(a)(l), which requires any person convicted of such offense to forfeit any property, real or personal, involved in such offense, or any property traceable to such property. 8. If any of the above-described forfeitable property, as a result of any act or omission of the defendant: (a) cannot be located upon the exercise of due diligence; Case 1:22-cr-00020-FB Document 12 Filed 01/12/22 Page 4 of 6 PageID #: 31 5 (b) has been transferred or sold to, or deposited with, a third party; (c) has been placed beyond the jurisdiction of the court; (d) has been substantially diminished in value; or (e) has been commingled with other property which cannot be divided without difficulty; it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title 18, United States Code, Section 982(b)(l), to seek forfeiture of any other property of the defendant up to the value of the forfeitable property described in this forfeiture allegation. (Title 18, United States Code, Sections 982(a)(l) and 982(b)(l); Title 21, United States Code, Section 853(p)) B¥:ONPEACE I UNITED STATES ATTORNEY EASTERN DISTRICT OF NEW YORK JO EPH S. BEEMSTERBOER ACTING CHIEF CRIMINAL DIVISION, FRAUD SECTION U.S. DEPARTMENT OF JUSTICE A TRUE BILL Case 1:22-cr-00020-FB Document 12 Filed 01/12/22 Page 5 of 6 PageID #: 32 F.#:2020R00955 FORM DBD-34 JUN. 85 No. UNITED STATES DISTRICT COURT EASTERN District a/NEW YORK CRIMINAL DIVISION THE UNITED STATES OF AMERICA vs. ANULI OKEKE, INDICTMENT Defendant. (T 18, U.S.C., §§ 982(a)(I), 982(a)(2), 982(b)( l ), 1343, 1344, 1349, 1956(h), 2 and 3551 filfilill.; T. 2 1, U.S.C., § 853(p)) Filed in open court this ____ _ _____ _ ______ day, of __ _ _________ A.D. 20 ___ _ _ Clerk Bail, $ _ ___ ______ _ Chand W. Edwards-Balfour, Assistant U.S. Attorney (718) 254-6238 and Michael McCarthy, Trial Attorney (202) 305-3995 Case 1:22-cr-00020-FB Document 12 Filed 01/12/22 Page 6 of 6 PageID #: 33
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