Indictment as to Gregory Scott Keough (1) count(s) 1, 2-3, 4-7, 8-11 w/forfeiture — USA v. Keough (Dkt. 17, S.D. Fla. No. 9:23-mj-08393, docketed in No. 9:23-cr-80154)

Record facts

U.S. District Court for the Southern District of Florida · No. 9:23-cr-80154-DMM · Doc. 17 · 2023-08-24 · Docket on CourtListener

Full text

. . 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. --------------
18 u.s.c. § 1349 
18 u.s.c. § 1343 
18 U.S.C. § 1957(a) 
18 U.S.C. § 981(a)(l)(C) 
18 U.S.C. § 982(a)(2)(A) 
18 U.S.C. § 982(a)(l) 
UNITED STATES OF AMERICA 
FILED BY ?f2 
vs. 
GREGORY SCOTT KEOUGH, 
Defendant. 
I 
--------------
INDICTMENT 
The Grand Jury charges that: 
GENERAL ALLEGATIONS 
At all times relevant to this Indictment: 
The Economic Injury Disaster Loan Program 
AUG 2 4 2023 
ANGELA E. NOBLE 
CLERK U.S. DIST. CT. 
S.D. OF FLA. - W.P.B. 
D.C. 
1. 
The Coronavirus Aid, Relief, and Economic Security ("CARES") Act was a federal 
law enacted in or around March 2020 and designed to provide emergency financial assistance to 
Americans suffering economic harm from the COVID-19 pandemic. 
2. 
The Economic Injury Disaster Loan ("EIDL") program was a U.S. Small Business 
Administration ("SBA") program that existed before the COVID-1 9 pandemic to provide low-interest 
financing to small business, renters, and homeowners in regions affected by declared disasters. 
3. 
The CARES Act authorized the SBA to provide ElDLs to eligible small businesses 
experiencing substantial financial disruptions due to the COVID-19 pandemic. In order to obtain a 
COVID-19 EIDL, a qualifying business was required to submit an EIDL application to the SBA and 
23-cr-80154-Middlebrooks/Matthewman
Case 9:23-cr-80154-DMM   Document 17   Entered on FLSD Docket 08/24/2023   Page 1 of 16

provide information about its operations, such as the number of employees, gross revenues, and the 
cost of goods sold for the 12-month period preceding January 31 , 2020. The applicant was also 
required to certify that all of the information in the application was true and correct to the best of the 
applicant's knowledge. In addition, the CARES Act authorized the SBA to issue advances of up to 
$10,000 to smal I businesses within three days of applying for an EIDL. The amount of the advance 
was determined by the number of employees the applicant certified having. The advances did not have 
to be repaid. 
4. 
All EIDL applications were submitted online. All applications subm itted on July 11 , 
2020 or after were handled by an SBA contractor with servers located in Des Moines, Iowa. Prior to 
July 11, 2020, EIDL applications were submitted through three different servers, located in Boydton, 
VA, West Des Moines, IA, or Quincy, WA. 
5. 
EIDL applications were submitted directly to the SBA and processed by the SBA with 
support from a government contractor. The amount of the loan was determined based, in part, on the 
information provided in the application concern ing the number of employees, gross revenues, and cost 
of goods sold. Any EIDL funds were issued directly by the SBA. 
Paycheck Protection Program 
6. 
Another source of relief provided by the CARES Act was the authorization of 
forgivable loans to small businesses for payroll, mortgage interest, rent/lease, util ities, through a 
program referred to as the Paycheck Protection Program ("PPP"). 
In April 2020, Congress 
authorized additional PPP funding. 
7. 
The PPP allowed qualifying small businesses and other organizations to receive 
PPP loans. Businesses were required to use PPP loan proceeds on payroll costs, interest on 
mortgages, rent, and utilities. The PPP allowed the interest and principal on the PPP .loan to be 
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entirely forgiven if the business spent the loan proceeds on these expense items within a designated 
period of time and used a certain percentage of the PPP loan proceeds on payroll expenses. 
8. 
The amount of PPP loan that a small business was entitled to receive was 
determined by the number of employees employed by the business and the business' average 
monthly payroll costs. 
9. 
To obtain a PPP Loan, a qualifying business was required to submit a PPP loan 
application which was signed by an authorized representative of the business. The PPP loan 
application required the business (through its authorized representative) to acknowledge the 
program rules and make certain affirmative certifications to be eligible to obtain the PPP loan. In 
the PPP loan application (SBA Form 2483), the small business (through its authorized 
representative) was required to state, among other things, its: (a) average monthly payroll 
expenses; and (b) number of employees. These figures were used to cal cu late the amount of money 
the small business was eligible to receive under the PPP. In addition, businesses applying for a 
PPP loan were required to provide documentation confirming their payroll expenses. 
10. 
A PPP loan application was processed by a participating lender. If a PPP loan 
application was approved, the participating lender disbursed the loan funds to the applicant. While 
a participating lender issued the PPP loan, the loan was 100% guaranteed by the SBA. Data from 
the application, including information about the borrower, the total amount of the loan, and the 
listed number of employees, was transmitted by a wire transfer by the lender to the SBA in the 
course of processing the loan. 
11. 
In addition, businesses applying for the PPP loan were required to provide 
documentation confirming their payroll expenses. Typically, businesses supplied documents 
showing the amount of payroll taxes reported to the Internal Revenue Service ("IRS"). Small 
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businesses (non-sole proprietorship) had to report and document the business' income and 
expenses, as typically reported to the IRS on Form W3 or Form 941. 
These figures and 
documentation were used to calculate the amount of money the small business was eligible to 
receive under the PPP. 
The Defendant and Relevant Entities 
12. 
GREGORY SCOTT KEOUGH was a resident of Palm Beach Gardens, Florida. 
13. 
Derek Acree was a resident of Palm Beach Gardens, Florida. 
14. 
National Financial Holdings Inc. ("NFHI"), formerly National Financial Holdings 
LLC, was a Delaware corporation with a registered address in Wilmington, Delaware and a principal 
address in Palm Beach Gardens, Palm Beach County, Florida. GREGORY SCOTT KEOUGH was 
the Chief Executive Officer of NFHI. Derek James Acree was the Chief Operating Officer of NFHI. 
15. 
NFH Florida LLC ("NFH Florida") was a Delaware limited liability company with a 
registered address in Wilmington, Delaware. 
16. 
Finova Financial LLC ("Finova Financial") was a Florida limited liability company 
with a principal address in Palm Beach Gardens, Palm Beach County, Florida. NFH Florida LLC is 
the named manager of Fi nova Financial. 
17. 
NFH Partners LLC ("NFH Partners") was a Florida limited liabi lity company with a 
registered address in West Palm Beach, Palm Beach County, Florida. 
GREGORY SCOTT 
KEOUGH was the Managing Member ofNFH Partners. 
18. 
Grupo Keough LLC ("Grupo Keough"), was a Florida limited liability company with 
a registered address in West Palm Beach, Palm Beach County, Florida. GREGORY SCOTT 
KEOUGH and Individual 1 were the Managing Members of Grupo Keough. 
19. 
Enclave Partners LLC ("Enclave") was a Florida limited liability company with a 
registered address in West Palm Beach, Palm Beach County, Florida. 
GREGORY SCOTT 
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KEOUGH and Individual I were the managing members of Enclave. 
Relevant Financial Institutions 
20. 
Bank of America was a federally insured financial institution headquartered m 
Charlotte, North Carolina, with offices located in the state of Florida. 
21. 
First Home Bank ("FH Bank"), now known as Bay First National Bank, was a federally 
insured financial institution headquartered in St. Petersburg, Florida. 
22. 
Si licon Valley Bank ("SY Bank") was a federally insured fmancial institution 
headquartered in Santa Clara, California. 
23. 
TD Bank ("TD Bank") was a federally insured financial institution headquartered in 
Cherry Hill, New Jersey, with offices located in the state of Florida. 
24. 
Truist Bank, formerly known as BB&T Bank, was a federally insured financial 
institution headquartered in Charlotte, North Carolina, with offices located in the state of Florida. 
COUNT 1 
Conspiracy to Commit Wire Fraud 
18 u.s.c. § 1349 
1. 
The General Allegations section of this Indictment is re-alleged and incorporated 
by reference as though fully set forth herein. 
2. 
From in or around March 2020, and continuing through in or around October 2020, 
the exact dates being unknown to the grand jury, in Palm Beach County, in the Southern District 
of Florida, and elsewhere, the defendant, 
GREGORY SCOTT KEOUGH, 
did knowingly and willfully combine, conspire, confederate, and agree with Derek Acree to 
commit an offense against the United States, that is, to knowingly devise and intend to devise a 
scheme and artifice to defraud and for obtaining money and property by means of false and 
fraudulent pretenses, representations, and promises and to transmit and cause to be transmitted by 
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means of wire communication in interstate commerce writings, signs, signals, and pictures for the 
purpose of executing such scheme and artifice, in violation of Title 18, United States Code, Section 
1343. 
PURPOSE OF THE CONSPIRACY 
3. 
It was the purpose of the conspiracy for the conspirators to unlawfully enrich 
themselves and others by, among other things, submitting and causing the submission of false and 
fraudulent applications for EIDL and PPP loans and diverting the proceeds of those loans for 
GREGORY SCOTT KEOUGH's and Derek Acree's personal use and benefit and to further the 
conspiracy. 
MANNER AND MEANS OF THE CONSPIRACY 
The manner and means by which the defendant and his coconspirator sought to accomplish 
the object and purpose of the conspiracy included, among others, the following: 
4. 
In or around March 2020, GREGORY SCOTT KEOUGH and Derek Acree 
entered an agreement whereby Derek Acree would submit EIDL and PPP loan applications that 
contained fraudulent and false statements on behalf of NFHJ. Once EIDL and PPP loan funds 
were received, GREGORY SCOTT KEOUGH and Derek Acree personally benefitted and 
shared the proceeds. 
5. 
On or about March 31, 2020, Derek Acree submitted an EIDL application on behalf 
NFHI to SBA's online portal. This EIDL application, which sought approximately $509,900 in 
EIDL funds, included false statements about the NFHI's gross revenues for the twelve months 
prior to the date of the disaster (January 31, 2020). 
As a result of the false and fraudulent 
statements, SBA approved the application and sent the requested funds to Finova Financial's Truist 
Bank account ending in 5893. 
6 
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6. 
On or about April 3, 2020, Derek Acree submitted a PPP loan application on behalf 
NFHI to FH Bank's online portal. This PPP application, which sought approximately $376,300 in 
PPP funds, included fal se statements about NFHI's number of employees and NFHI's average 
monthly payroll. As a result of the false and fraudulent statements, FH Bank approved the PPP 
loan application and transferred approximately $376,300 into NFHI's SV Bank account ending in 
0470. 
7. 
GREGORY SCOTT KEOUGH and Derek Acree each spent much of the loan 
proceeds for his personal use and benefit, not for payro ll costs, interest on mortgages, rent, or 
utilities. 
All in violation of Title 18, United States Code, Section 1349. 
COUNTS 2-3 
Wire Fraud 
18 u.s.c. § 1343 
1. 
The General Allegations section of this Indictment is re-alleged and incorporated 
by reference as though fully set forth herein. 
2. 
From in or around March 2020, and continu ing through in or around October 
2020, the exact dates being unknown to the grand jury, in Palm Beach County, in the Southern 
District of Florida, and elsewhere, the defendant, 
GREGORY SCOTT KEOUGH, 
did knowingly, and with the intent to defraud, devise, and intend to devise a scheme and artifice 
to defraud, and to obtain money and property by means of materially false and fraudulent 
pretenses, representations, and promises, knowing that the pretenses, representations, and 
promises were false and fraudu lent when made, and for the purpose of executing the scheme and 
artifice, did knowingly transmit and cause to be transmitted, by means of wire communication in 
interstate commerce, certain writings, signs, signals, pictures, and sounds. 
7 
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PURPOSE OF THE SCHEME AND ARTIFICE 
3. 
It was the purpose of the scheme and artifice for the Defendant and Derek Acree to 
each unlawfully enrich himself and others by, among other things, submitting and causing the 
submission of false and fraudulent applications for EIDL and PPP loans and diverting the proceeds 
of those loans for GREGORY SCOTT KEOUGH's and Derek Acree's personal use and benefit 
and to further the conspiracy. 
MANNER AND MEANS OF THE SCHEME AND ARTIFICE 
4. 
The allegations contained in paragraphs 4 through 7 of the Manner and Means of 
the Conspiracy section of Count 1 are realleged and incorporated by reference as though fully stet 
forth herein as a description of the scheme and artifice. 
USE OF THE WIRES 
5. 
On or about the dates specified below, in Palm Beach County, in the Southern 
District of Florida, and elsewhere, the defendant, 
GREGORY SCOTT KEOUGH, 
and Derek Acree for the purpose of executing and in furtherance of the aforesaid scheme and 
artifice to defraud, and to obtain money and property by means of materially false and fraudulent 
pretenses, representations, and promises, knowing that the pretenses, representations, and 
promises were false and fraudu lent when made, did knowingly transmit and cause to be transmitted 
in interstate commerce, by means of wire communication, certain writings, signs, signals, pictures, 
and sounds, that is, an electronic transmission of a fraudulent EIDL or PPP application in the name 
of the entity described in the table below to SBA. 
COUNT 
APPROXIMATE DATE 
ENTITY 
LOAN TYPE 
OF WIRE 
TRANSMISSION 
2 
March 31, 2020 
NFHI 
EIDL 
8 
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3 
April 3, 2020 
NFHT 
In violation of Title 18, United States Code, Sections l 343 and 2. 
COUNTS 4-7 
Wire Fraud 
18 u.s.c. § 1343 
PPP 
6. 
The General Al legations section of this Indictment is re-alleged and incorporated 
by reference as though fully set forth herein. 
7. 
From in or around March 2020, and continuing through in or around June 2020, the 
exact dates being unknown to the grand jury, in Palm Beach County, in the Southern District of 
Florida, and elsewhere, the defendant, 
GREGORY SCOTT KEOUGH, 
did knowingly, and with the intent to defraud, devise, and intend to devise a scheme and artifice 
to defraud, and to obtain money and property by means of materially false and fraudulent 
pretenses, representations, and promises, knowing that the pretenses, representations, and 
promises were false and fraudulent when made, and for the purpose of executing the scheme and 
artifice, did knowingly transmit and cause to be transmitted, by means of wire communication in 
interstate commerce, certain writings, signs, signals, pictures, and sounds. 
PURPOSE OF THE SCHEME AND ARTIFICE 
8. 
It was the purpose of the scheme and artifice for the defendant to unlawfully enrich 
himself and others by, among other things, submitting and causing the submission of false and 
fraudulent applications for EIDL and PPP loans and diverting the proceeds of those loans for the 
defendant's own personal use and benefit. 
9 
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MANNER AND MEANS OF THE SCHEME AND ARTIFICE 
9. 
On or about March 31, 2020, GREGORY SCOTT KEOUGH submitted and 
caused to be submitted an EIDL application on behalfNFH Partners to SBA's online portal. This 
EIDL application, which sought approximately $150,000 in EIDL funds, included fa lse statements 
about NFH PARTNERS' gross revenues for the twelve months prior to the date of the disaster 
(January 31, 2020). 
10. 
As a result of the false and fraudulent representations made in this EIDL 
application, SBA approved the application. SBA disbursed EIDL proceeds in the amount of 
$149,900 into NFH Partners' TD Bank account ending in 5925, for which GREGORY SCOTT 
KEOUGH was a signatory. 
11. 
On or about Apri 1 8, 2020, GREGORY SCOTT KEOUGH submitted and caused 
to be submitted an EIDL application on behalf of Grupo Keough to SBA's online portal. This 
appl ication, which sought approximately $150,000 in EID L funds, included false statements about 
Grupo Keough 's gross revenues for the twelve months prior to the date of the disaster (January 31 , 
2020). 
12. 
As a result of the false and fraudulent representations made in this EJDL 
application, SBA disbursed EIDL proceeds in the amount of $149,900 into Grupo Keough's Bank 
of America account ending in 1970, for which GREGORY SCOTT KEOUGH was a signatory. 
13. 
On or about April 8, 2020, GREGORY SCOTT KEOUGH submitted and caused 
to be submitted a PPP application on behalf Grupo Keough to Bank of America's online portal. 
This application sought approximately $126,750 in PPP funds. This PPP application, which sought 
approximately $126,750, included false statements about Grupo Keough's average monthly 
payroll and number of employees. This application was not approved by Bank of America. 
10 
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14. 
On or about Apri l 9, 2020, GREGORY SCOTT KEOUGH submitted and caused 
to be submitted an EIDL application on behalf of Enclave to SBA's online portal. This EIDL 
application included false statements about Enclave's gross revenues for the twelve months prior 
to the date of the disaster (January 31, 2020). This application was not approved by SBA. 
USE OF THE WIRES 
15. 
On or about the dates specified below, in Palm Beach County, in the Southern 
District of Florida, and elsewhere, the defendant, 
GREGORY SCOTT KEOUGH, 
for the purpose of executing and in furtherance of the aforesaid scheme and artifice to defraud, and 
to obtain money and property by means of materially false and fraudulent pretenses, 
representations, and promises, knowing that the pretenses, representations, and promises were 
false and fraudulent when made, did knowingly transmit and cause to be transmitted in interstate 
commerce, by means of wire communication, certain writings, signs, signals, pictures, and sounds, 
that is, an electronic transm ission of a fraudulent EIDL or PPP application in the name of the entity 
described in the table below to SBA. 
COUNT 
APPROXIMATE 
ENTITY 
LOAN TYPE 
DATE OF WIRE 
TRANSMISSION 
4 
March 31 , 2020 
NFH Partners 
EIDL 
5 
April 8, 2020 
Grupo Keough 
EIDL 
6 
April 8, 2020 
Grupo Keough 
PPP 
7 
April 9, 2020 
Enclave 
EIDL 
In violation of Title 18, United States Code, Section 1343. 
11 
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COUNTS 8-11 
Money Laundering 
(18 U.S.C. § 1957(a)) 
J. 
The General A llegations section of this Indictment is re-alleged and incorporated 
by reference as though fully set forth herein. 
2. 
On or about the dates specified below, in Palm Beach County, in the Southern 
District of Florida, and elsewhere, the defendant, 
GREGORY SCOTT KEOUGH, 
did knowingly engage in a monetary transaction by, through, and to a financial institution affecting 
interstate commerce in criminally deri ved property of a value greater than $10,000, such property 
having been derived from a specified unlawfu l activity, knowing that the property involved in the 
monetary transactions represented the proceeds of some form of unlawful activity, in violation of 
Title 18 United States Code, Section 1343. 
COUNT 
APPROXIMATE 
DESCRIPTION OF TRANSACTION 
DATE OF 
TRANSACTION 
8 
May 26, 2020 
Cash withdrawal in the amount of $57,500 and 
identified with w ithdrawal transaction TD #: 
745900276. 
9 
June 17, 2020 
Cash withdrawal in the amount of $44,500 and 
identified with withdrawal transaction ID #: 
546686426. 
10 
July 15, 2020 
Cash withdrawal in the amount of $52,500 and 
identified with withdrawal transaction ID #: 
7645533 16. 
11 
August 12, 2020 
Cash withdrawal in the amount of $45,000 and 
identified with withdrawal transaction ID #: 
7673 1563 1. 
In violation of Title 18, United States Code, Section 1957. 
12 
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FORFEITURE ALLEGATIONS 
1. 
The allegations of this Indictment are hereby realleged and incorporated by 
reference for the purpose of alleging forfe iture to the United States of America of certain property 
in which the defendant, GREGORY SCOTT KEOUGH, has an interest. 
2. 
Upon conviction of a violation of Title 18, United States Code, Section 1349, as 
alleged in this Indictment, the defendant, shall forfeit to the United States, any property, real or 
personal, wh ich constitutes or is derived from proceeds traceable to such offense, pursuant to Title 
18, United States Code, Section 98l(a)(l)(C). 
3. 
Upon conviction of a violation of Title 18, United States Code, Section 1343, as 
alleged in this Indictment, the defendant shall forfeit to the United States any property constituting, 
or derived from, proceeds obtained, di rectly or indirectly, as a result of such offense, pursuant to 
Title 18, United States Code, Section 982(a)(2)(A). 
4. 
Upon conviction of a violation of Title 18, United States Code, Section 1957, as 
alleged in th is Indictment, the defendant shall forfeit to the United States any property, real or 
personal, involved in such offense, and any property traceable to such property, pursuant to Title 
18, United States Code, Section 982(a)(l). 
5. 
If any of the property described above, 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 
13 
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difficulty, 
the United States of America shall be entitled to forfeiture of substitute property pursuant to Title 
21 , United States Code, Section 853(p ). 
All pursuant to Title 18, United States Code, Sections 981 (a)(l)(C), 982(a)(l), and 
982(a)(2)(A), and the procedures set forth at Title 21, United States Code, Section 853, as 
incorporated by Title 18, United States Code, Section 982(6)(1), and Title 28, United States 
Code, Section 2461(c). 
/ 
g~ 
,~I~ S~~~~RNEY 
:i::SlH 
ASSIST ANT UNITED STA TES ATTORNEY 
14 
Case 9:23-cr-80154-DMM   Document 17   Entered on FLSD Docket 08/24/2023   Page 14 of 16

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
UNITED STATES OF AMERICA 
CASE NO.: _____________ _ 
v. 
CERTIFICATE OF TRIAL ATTORNEY 
GREGORY SCOTT KEOUGH, 
I 
------~~~-----
Superseding Case Information: 
Defendant. 
New Defendant( s) (Yes or No) ---
Court Division (select one) 
Number of New Defendants 
D Miami 
□ Key West 
FTP 
Total number of counts 
□FTL 
~WPB 
I do hereby certify that: 
1. 
I have carefully considered the allegations of the indictment, the number of defendants, the number of probable 
witnesses and the legal complexities of the Indictment/Information attached hereto. 
2. 
I am aware that the information supplied on this statement will be relied upon by the Judges of this Court in setting 
their calendars and scheduling criminal trials under the mandate of the Speedy Trial Act, Title 28 U .S.C. §3161. 
3. 
Interpreter: (Yes or No) No ---
List language and/or dialect: ------
4. 
This case will take _ 6_ days for the parties to try. 
5. 
Please check appropriate category and type of offense listed below: 
(Check only one) 
I 
D Oto 5 days 
II 
[E'.] 6 to 10 days 
III D 11 to 20 days 
IV □ 21 to 60 days 
V 
D 61 days and over 
(Check only one) 
□ Petty 
D Minor 
□ Misdemeanor 
IE:! Felony 
6. 
Has this case been previously filed in this District Court? (Yes or No) N_o __ 
If yes, Judge ___________ Case No. ______________ _ 
7. 
Has a complaint been filed in this matter? (Yes or No) Yes 
Ifyes, Magistrate Case No. 23-mj-8393-WM 
---
8. 
Does this case relate to a previously filed matter in this District Court? (Yes or No) __ _ 
If yes, Judge___________ Case No. _______________ _ 
9. 
Defendant(s) in federal custody as of .... A .... 
u._g_..u .... st~9~2 .... 0_2 .... 3 _______________ _ 
10. 
Defendant(s) in state custody as of _____________________ _ 
11. 
Rule 20 from the ____ District of -------
12. 
Is this a potential death penalty case? (Yes or No) _N_o __ 
13. 
Does this case originate from a matter pending in the Northern Region of the U.S. Attorney's Office 
prior to August 8, 2014 (Mag. Judge Shaniek Maynard? (Yes or No) No 
---
14. 
Does this case originate from a matter pending in the Central Region of the U.S. Attorney's Office 
prior to October 3, 2019 (Mag. Judge Jared Strauss? (Yes or No) No 
---
15. 
Did this matter involve the participation of or consultation with now Magistrate Judge Eduardo I. Sanchez 
during his tenure at the U.S. Attorney's Office, which concluded on January 22, 2023? N_o __ 
By ~-~ 
~w.Waug 
Assistant United States Attorney 
FL Bar No. 
0537837 
23-cr-80154-Middlebrooks/Matthewman
Case 9:23-cr-80154-DMM   Document 17   Entered on FLSD Docket 08/24/2023   Page 15 of 16

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
PENAL TY SHEET 
Defendant's Name: ___ 
G=-RE=;..::G=-O=R=Y-'S=-C=--O=--=-T--=T'--'KE=--=Oc.....:U=-G=H=------------
Case No: ---------------------- - - --------
Count #: 1 
Conspiracy to Commit Wire Fraud 
18 U.S.C. § 1349 
* Max. Term oflmprisonment: 20 years' imprisonment 
* Mandatory Min. Term oflmprisonment (if applicable): N/A 
* Max.Supervised Release: 3 years term of supervised release 
* Max. Fine: $250,000 fine or twice the gross loss or gross gain 
Count #s: 2 - 7: 
Wire Fraud 
18 U.S.C. § 1343 
*Max.Term oflmprisonment: 20 years' imprisonment 
* Mandatory Min. Term oflmprisonment (if applicable): N/A 
* Max. Supervised Release: 3 years term of supervised release 
* Max. Fine: $250,000 fine or twice the gross loss or gross gain 
Count #s: 8 and 11 : 
Engaging in Monetary Transactions in Criminally Derived Property 
l 8 u.s.c. § 1957 
* Max.Term oflmprisonment: 10 years' imprisonment 
* Mandatory Min. Term oflmprisonment (if applicable): N/A 
* Max.Supervised Release: 3 years term of supervised release 
* Max. Fine: $250,000 fine or twice the value of the criminally derived property involved 
in the transaction 
*Refers only to possible term of incarceration, supervised release and fines. It does not include 
restitution, special assessments, parole terms, or forfeitures that may be applicable. 
23-cr-80154-Middlebrooks/Matthewman
Case 9:23-cr-80154-DMM   Document 17   Entered on FLSD Docket 08/24/2023   Page 16 of 16

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