Sentencing Memorandum by USA as to Fatiu Ismaila Lawal — United States v. Lawal (Dkt. 70, W.D. Wash. No. 3:23-cr-05034)

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U.S. District Court for the Western District of Washington · No. 3:23-cr-05034-TMC · Doc. 70 · 2025-01-21 · Docket on CourtListener

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United States’ Sentencing Memorandum - 1 
United States v. Fatiu Lawal, CR23-5034-TMC-01 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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The Honorable Tiffany M. Cartwright 
 
 
 
 
 
 
 
 
 
UNITED STATES DISTRICT COURT FOR THE 
WESTERN DISTRICT OF WASHINGTON 
AT TACOMA 
 
 
UNITED STATES OF AMERICA, 
 
Plaintiff 
 
v. 
FATIU ISMAILA LAWAL, 
       Defendant. 
NO. CR23-5034-RJB-01 
 
UNITED STATES’ SENTENCING  
MEMORANDUM 
 
 
Fatiu Lawal is a Canadian resident and Nigerian citizen who stole over $1.3 million 
dollars in pandemic relief that should have gone to American workers suffering from the 
devastating economic impacts of the COVID-19 pandemic.  His exploitation of a 
vulnerable time in our nation was the culmination of years of fraudulent activities—
including the use of stolen American identities to submit fraudulent U.S. tax returns 
seeking refunds—while he lived in Nigeria and Canada.  Lawal and Sakiru Ambali, his co-
conspirator and close friend of over 20 years, were well-versed in executing sophisticated 
frauds and had stolen the personal identifying information of more than 14,700 unwitting 
Americans.  At the onset of the pandemic in 2020, the pair used these stolen identities to 
submit more than 1,700 fraudulent claims for COVID-19 unemployment benefits in at least 
27 states and to submit fraudulent applications for small business assistance.  Lawal also 
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United States’ Sentencing Memorandum - 2 
United States v. Fatiu Lawal, CR23-5034-TMC-01 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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used the stolen American identities to submit thousands of fraudulent U.S. tax returns 
seeking refunds.  Lawal personally participated in the submission of over 3,791 fraudulent 
claims seeking American government funds. 
The United States recommends that the Court sentence Lawal to 41 months of 
imprisonment for wire fraud (Count 3), to run consecutive to the mandatory 24-month 
sentence for aggravated identity theft (Count 16), for a total of 65 months of imprisonment.  
This sentence is necessary to reflect the serious nature of the offense and to deter others—
particularly those who perpetrate fraud from abroad—from engaging in similar conduct.   
The Court should also impose the special conditions proposed by Probation, including that 
upon deportation, he may not reenter the United States without permission of the 
Department of Homeland Security.  The court should further order Lawal to pay restitution 
in the amount of $1,345,472, as agreed upon in the Plea Agreement. 
I. 
BACKGROUND 
A. 
Lawal Has Been Defrauding the United States Since at Least 2013. 
Fatiu Lawal is a seasoned fraudster who maintained thousands of email addresses 
to perpetrate various sophisticated fraud schemes.  See, e.g., PSR at ¶¶ 9, 16, 21.  Since as 
early as 2013, Lawal utilized several Google Gmail accounts to execute these frauds under 
monikers such as “John Smith,” “Banks Smith,” and “Barbara Jenkins.”  See id. at ¶ 9.  
Beginning in December 2020, Lawal created an extra layer of obfuscation by creating and 
owning seven web domain names such as sensormargin.com, that he used to generate 
thousands of email addresses that funneled to central inboxes. 
The contents of these email accounts reflected the breadth of fraud Lawal undertook 
for years.  In several accounts, including js755641@gmail.com (created on November 27, 
2013 under “John Smith”), the email contents included entire inboxes of unknowing 
victims whose accounts had been hacked to auto-forward all emails to Lawal.  Sometimes 
these emails included personal financial information of the victim that could be exploited.  
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United States’ Sentencing Memorandum - 3 
United States v. Fatiu Lawal, CR23-5034-TMC-01 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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See Ex. A, Bates USAO-00051420–23 (email of victim emailing herself images of bank 
statements with a blind copy to an email account Lawal controlled). 
From at least 2018 until 2022, Lawal used three Gmail accounts and four custom 
web domains to file over 3,000 fraudulent U.S. tax returns using stolen American identities 
and seeking refunds totaling approximately $7.5 million.  PSR at ¶ 21.  The IRS disbursed 
refunds for three of the returns, totaling $30,000.  Id.   
B. 
Lawal Stole Funds Intended for American Workers Suffering From the 
Economic Impacts of the COVID-19 Pandemic. 
Lawal’s perpetration of fraud against the United States and its residents culminated 
at the onset of the COVID-19 pandemic.  In March 2020, following presidential 
declarations of a nationwide emergency and major disasters in every state, the federal 
government enacted measures to mitigate the devasting economic impact the COVID-19 
pandemic was exacting on American workers and businesses.  Id. at ¶ 12.  Among these 
measures was federal funding for expanded and increased unemployment benefits 
administered by state workforce agencies, including the Washington Employment Security 
Department (ESD).  Id. at ¶ 13.   
Between May 4, 2020 and at least until June 10, 2022, Lawal personally used his 
cache of stolen identities to submit over 790 fraudulent claims for pandemic unemployment 
benefits in the names of over 790 American workers to at least 28 state workforce agencies 
across the country, including Washington’s ESD.  Id. at ¶ 16.  Lawal also submitted over 
3,000 fraudulent tax returns seeking refunds using the stolen identities of real Americans.  
See id. at ¶ 11.  Lawal used at least four different email accounts and four different web 
domain names to submit the claims, including gamework393@gmail.com and 
bankupdates2014@gmail.com.  To circumvent fraud safeguards and prevent the state 
workforce agencies from recognizing that a single email account was being used for 
hundreds of claims, Lawal inserted periods at various places in the Gmail email addresses, 
e.g., g.a.mewor.k.3.9.3@gmail.com.  Id. at ¶ 16-17.  After state workforce agencies 
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United States’ Sentencing Memorandum - 4 
United States v. Fatiu Lawal, CR23-5034-TMC-01 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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detected this modus operandi and blocked its usage, Lawal began purchasing custom 
domain names (e.g., sensormargin.com, unitedgsat.com, minderpower.com), to generate 
thousands of email addresses (e.g., 123@sensormargin.com, ja@sensormargin.com, 
jaa@sensormargin.com) that funneled to a single inbox for the domain.  See id. at ¶ 16.  To 
further evade detection, Lawal used tools that routed his submissions through IP addresses 
located within the United States. 
Washington was one of the first states in the nation to implement federal pandemic 
unemployment benefits, and Lawal directed his earliest efforts in May 2020 to submitting 
fraudulent applications to Washington’s ESD.  Within three weeks, Lawal filed 
approximately 38 fraudulent claims and caused ESD to disburse benefits totaling 
approximately $31,324 for about six of them.  Over the next two years, Lawal submitted 
over 700 additional of fraudulent claims to 27 additional states.  In total, Lawal caused 
state workforce agencies to disburse over $1.3 million in pandemic unemployment 
benefits.  Id. at ¶ 16. 
Lawal and his co-conspirators directed unemployment benefits to be paid to money 
mules in the United States who then withdrew and transferred the funds according to 
instructions given by Lawal and his co-conspirators.  Id. at ¶ 18. 
C. 
Lawal’s Personally Received a Significant Portion of Fraudulent Proceeds 
Because the United States has limited avenues for obtaining financial records 
located abroad, the government does not have a comprehensive analysis of Lawal’s 
finances.  Nevertheless, relying on the contents of cloud storage and contents of email 
accounts  Lawal controlled, the government can reasonably conclude that Lawal received 
a significant portion of the $1.3 million in pandemic benefits.   
Specifically, the Google Drive for gamework393@gmail.com—one of the accounts 
Lawal used for fraudulent unemployment claims—contained a Nigerian bank statement for 
a child’s savings accounts held in Lawal’s minor son’s identity.  The statement shows that 
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United States’ Sentencing Memorandum - 5 
United States v. Fatiu Lawal, CR23-5034-TMC-01 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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between March 1, 2020, and July 22, 2020, the balance for the account grew from the 
equivalent of approximately US$8.00 to US$70,000.  Nearly all of the deposits originated 
from an account belonging to Lawal.  During this same time period, the 
gamework393@gmail.com account was used to file over 100 pandemic unemployment 
claims that resulted in benefit payments of over US$80,000.  Id. at ¶ 11.   In other words, 
it appears that Lawal personally received 87.5% of his fraudulent proceeds.  Nothing in his 
self-reported employment history accounts for this dramatic increase in assets during the 
first six months of the unprecedented global pandemic, and Lawal’s attempt to hide these 
funds in his minor son’s savings account shows consciousness of guilt.  See id. at ¶ 70.     
D. 
Lawal Continued His Fraudulent Activities Until His Arrest. 
Incident to Lawal’s arrest, with the assistance of Canadian officials, federal agents 
lawfully seized and searched his personal cell phone.  The contents of the phone show that 
Lawal’s fraudulent conduct was broad, sophisticated, and enlisted others.  Multi-year text 
chains on encrypted applications contained endless exchanges of stolen personal 
identifying information (including Social Security numbers, dates of birth, driver’s license 
numbers, addresses, and phone numbers) of Americans, and images of real credit or debit 
cards.  In at least one text chain, it appears Lawal is in a supervisory position, directing an 
individual how to instruct a money mule (who is euphemistically referred to as a “client”) 
to collect what appear to be debit cards issued by state workforce agencies to disburse 
unemployment benefits.  See, e.g., Ex. B.  As Probation’s sentencing recommendation 
notes, Lawal’s fraudulent efforts is likened to a full-time job.  His criminal activities 
persisted until his arrest in Ontario, Canada on February 21, 2023.   
II. 
PROCEDURAL HISTORY 
On January 25, 2023, the Grand Jury returned a 17-count indictment charging Lawal 
and his co-defendant Sakiru Ambali with conspiracy (Count 1), in violation of 18 U.S.C. 
§ 1349; wire fraud in connection with a presidentially declared emergency or major disaster 
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United States’ Sentencing Memorandum - 6 
United States v. Fatiu Lawal, CR23-5034-TMC-01 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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(Counts 2-11), in violation of 18 U.S.C. §§ 1343 and 2; and aggravated identity theft 
(Counts 12-17), in violation of 18 U.S.C. § 1028A.  Dkt. 1. 
On February 22, 2023, Canadian authorities arrested Lawal pursuant to the warrant 
in this case, and Lawal remained in custody until Canada granted the United States’ request 
to extradite him to this district in July 2024.  PSR at ¶ 4.  Lawal made his initial appearance 
in this district on July 12, 2024, and has been detained since then. 
On September 12, 2024, Lawal pled guilty to Counts 3 (wire fraud) and 16 
(aggravated identity theft).  Id. at ¶ 2 
Ambali, who was extradited from Germany approximately a year before Lawal, also 
pled guilty to wire fraud and aggravated identity theft.  Dkt. 35.  On March 14, 2024, the 
Honorable Robert J. Bryan sentenced Lawal to a total of 42 months of incarceration. 
III. 
SENTENCING GUIDELINES CALCULATIONS 
The United States agrees with the Probation Office on the Sentencing Guidelines 
calculations and has no objections to the facts contained in the PSR. 
 
The following calculation applies for Count 3 (wire fraud):   
Item  
Guideline 
Adjustment  
Base Offense 
2B1.1(a)(1) 
+7 
Intended Loss in Excess 
of $550,000  
2B1.1(b)(1)(H) 
+14 
10 or More Victims 
2B1.1(b)(2) 
+2 
Sophisticated Means  
2B1.1(b)(10) 
+2 
Disaster Benefits 
2B1.1(b)(12) 
+2 
Acceptance  
3E1.1 
-3 
Zero-Point Offender 
4C1.1 
-2 
Total 
 
22 
See PSR at ¶¶ 29-42. 
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United States’ Sentencing Memorandum - 7 
United States v. Fatiu Lawal, CR23-5034-TMC-01 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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For Count 16 (aggravated identity theft), the Guideline range is the minimum 
required by statute, two years, which must run consecutive to Count 3.  USSG § 2B1.6; see 
PSR at ¶ 28. 
 
The defendant’s criminal history category is I.  PSR at ¶ 45.  The resulting 
Guidelines range is 41 to 51 months for Count 5 (wire fraud) and a mandatory consecutive 
sentence of 24 months imprisonment for Count 15 (aggravated identity theft). 
IV. 
FACTORS RELATED TO SENTENCING RECOMMENDATION 
The United States recommends that the Court impose a total term of imprisonment 
of 65 months.   
For the reasons set forth below, this recommendation is appropriate given “the 
nature and circumstances of the offense,” and the need for the sentence “to reflect the 
seriousness of the offense, to promote respect for the law, and to provide just punishment 
for the offense,” to ensure adequate general deterrence, and “to protect the public from 
further crimes of the defendant.” 18 U.S.C. §§ 3553(a)(1), (a)(2)(A), and (a)(2)(C).   
A. 
The Nature and Circumstances of the Offense—Lawal’s Exploitation of 
Three Disaster Periods in the United States is an Aggravating Factor. 
Because nearly five years have lapsed since the onset of the COVID-19 pandemic, 
it is easy to forget the chaotic, desperate, and dire circumstances facing our nation and our 
government’s attempts to stem the catastrophic economic impact of the first six months of 
the COVID-19 pandemic.  In March 2020, schools, businesses, and restaurants abruptly 
shuttered, and hospitals were overwhelmed with patients dying of COVID-19.1  Yet, Lawal 
saw the pandemic and its consequences not as a public health catastrophe but as an 
opportunity to enrich himself through fraud. 
 
1 See, e.g., Ariana Cha, “Faced with a crush of patients, besieged NYC hospitals struggle with life-or-death 
decisions,” The Washington Post (Mar. 31, 2020), available at 
https://www.washingtonpost.com/health/2020/03/31/new-york-city-hospitals-coronavirus/. 
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United States’ Sentencing Memorandum - 8 
United States v. Fatiu Lawal, CR23-5034-TMC-01 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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As Lawal began executing his scheme to use stolen identities of American workers 
to file fraudulent unemployment claims in May 2020, approximately 20.6 million 
American were unemployed, far surpassing the Great Recession’s peak of 15.2 million in 
2009.2  American business owners saw their livelihoods vanish overnight.  In fact, a survey 
in April 2020 showed that 43 percent of small businesses in the nation had at least 
temporarily closed, which was unprecedented in our nation’s history and a far more severe 
economic impact than the 1918 influenza.3 
During major disasters and nationwide emergencies, it is particularly important for 
the government to be able to disburse aid quickly to real victims to mitigate the impact of 
the crisis. The actual monetary loss to the government comes secondary to the fact that a 
real person or business behind each stolen identity had difficulty accessing assistance 
because a fraudulent claim was already paid in their identity. These difficulties were 
further compounded by the onslaught of fraudulent claims that clogged the infrastructure 
in place distribute the aid.  The estimated loss from these fraudulent pandemic 
unemployment claims is over $100 billion.4 
 
In this case, Lawal used the stolen identities of over 790 real individuals who may 
have qualified for pandemic assistance and may have needed it urgently.  Lawal’s earliest 
submissions to ESD began within two months of the President’s declaration of a national 
emergency.  By then, ESD had been flooded with imposter claims like Lawal’s, and 
approximately a week after his first submissions, on May 13, 2020, ESD was forced to halt 
all benefit payments to more than a million people for three days.6  Lawal had experience 
 
2 U.S. Bureau of Labor Statistics, “Unemployment Rises in 2020, as the country battles the COVID-19 pandemic” 
(June 2021), available at https://www.bls.gov/opub/mlr/2021/article/unemployment-rises-in-2020-as-the-country-
battles-the-covid-19-pandemic.htm.  
3 Alexander Bartik, et al., “How Are Small Businesses Adjusting to COVID-19? Early Evidence From a Survey,” 
Nat’l Bureau of Economic Research (Apr. 2020), at 3, 8, available at 
https://www.nber.org/system/files/working_papers/w26989/w26989.pdf.  
4 U.S. Gov’t Accountability Ofc, “More Fraud Has Been Found in Federal COVID Funding – How Much Was Lost 
Under Unemployment Insurance Programs” (Sept. 13, 2023), available at https://www.gao.gov/blog/more-fraud-
has-been-found-federal-covid-funding-how-much-was-lost-under-unemployment-insurance-
programs#:~:text=In%20our%20new%20report%2C%20we,paid%20out%20during%20the%20pandemic.  
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United States’ Sentencing Memorandum - 9 
United States v. Fatiu Lawal, CR23-5034-TMC-01 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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using stolen American identities to commit fraud before the pandemic, but this time, his 
criminal conduct contributed to victimizing even people whose identities he did not steal and 
urgently needed assistance that could not be disbursed because of criminals like Lawal. 
Notably, both Congress and the Sentencing Commission have endorsed sentencing 
enhancements during national emergencies and major disasters.  See 18 U.S.C 1343 
(increases maximum penalties to 30 years imprisonment and $1 million fine); USSG § 
2B1.1(b)(2)(12) (two-level increase applied for offenses involving disaster fraud).  
Congress enacted the enhanced statutory penalty for wire (and mail) fraud in response to 
reports of widespread fraud and abuse in connection to disaster funds disbursed for 
Hurricanes Katrina and Rita.  The Senate Judiciary Committee report noted: 
We want to help ensure that federal money goes to the right people and 
does not get stolen by criminals posing as victims. Congress wants to 
provide appropriate recovery and relief resources to affected States, and 
also ensure that these resources are protected and distributed only to the 
real victims–not to individuals seeking to take advantage of the disaster. 
Senate Report No. 110-69, 110th Cong., 1st Session (May 22, 2007). 
 
In this case, there are no circumstances under which Lawal—a Canadian resident 
and Nigerian citizen—was a real victim.  Rather, he was a criminal seeking to take 
advantage of our nation’s crisis.  
B. 
A Substantial Term of Imprisonment is Necessary to Deter and is Just 
Punishment for the Offense. 
The impact the sentence in this case has on general deterrence cannot be overstated.  
Media in Nigeria and Canada have covered the legal developments in this case.  See, e.g., 
Abby O’Brien, “Toronto men defrauded U.S. government of more than $2M using 
‘thousands’ of stolen identities: investigators,” CP24 (Jan. 4, 2024), available at 
https://www.cp24.com/news/toronto-men-defrauded-u-s-government-of-more-than-2m-
using-thousands-of-stolen-identities-investigators-1.6710612?cache=%2F7.323885.  
Kehinde Folarin, “Two Nigerians risk 32 years in jail for allegedly defrauding US of $25m 
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United States’ Sentencing Memorandum - 10 
United States v. Fatiu Lawal, CR23-5034-TMC-01 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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COVID 
benefits,” 
Politics 
Nigeria 
(Aug. 
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2023), 
available 
at 
https://politicsnigeria.com/two-nigerians-risk-32-years-in-jail-for-allegedly-defrauding-
us-of-25m-covid-benefits/.   
The evidence in this case confirms that there are thousands of individuals around 
the world will steal American identities to perpetrate fraud against the United States.  When 
those criminals read the sentence imposed on Lawal, it must be substantial enough to deter 
them from further illegal activity and underscore that they are not beyond the reach of the 
United States judicial system.   
Moreover, because it is not a secret that extraterritorial monetary judgments are 
difficult to enforce and Probation will not be able to monitor Lawal’s behavior after 
deportation, a significant term of imprisonment may be the only assured punishment 
available to hold Lawal accountable for exploiting a time of crisis in the United States. 
C. 
A 65-Month Term of Imprisonment Would Be Consistent with Sentences 
Imposed for Similar Conduct. 
The crimes Lawal committed and the circumstances under which he committed 
them are nearly identical to Abidemi Rufai, who was sentenced to 60 months in prison by 
the Honorable Benjamin H. Settle in September 2022.  See United States v. Rufai, Dkt. 56, 
Judgment, CR21-5186-BHS (Sept. 26, 2022).  Like Lawal, Rufai is a Nigerian citizen who 
had a history of committing fraud against the United States prior to the pandemic.  Id., Dkt. 
54, United States’ Sentencing Memorandum at 6-7.  Like Lawal, Rufai was also in 
possession of thousands of stolen American identities that he primarily used to file 
fraudulent pandemic unemployment claims but also used to file applications for small 
business assistance and U.S. tax returns seeking refunds.  Id. Dkt. 54 at 7-9.  Although 
Rufai had aggravating factors in his history and characteristics, the number of claims he 
filed and the amount of loss he caused was significantly less than Lawal.  Whereas Rufai 
filed approximately 238 fraudulent pandemic unemployment claims and caused a total loss 
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United States’ Sentencing Memorandum - 11 
United States v. Fatiu Lawal, CR23-5034-TMC-01 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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of approximately $600,000, Lawal filed over 790 fraudulent pandemic unemployment 
claims and caused over $1.3 million in loss.   
The government recommended a sentence of 60 months for Lawal’s co-conspirator, 
Sakiru Ambali, and Judge Bryan sentenced Ambali to 42 months.  Although Lawal and 
Ambali pled guilty to the same offenses, sentencing Lawal to 65 months would not create 
an unwarranted sentencing disparity because Lawal was far more prolific in his efforts to 
defraud the United States, appears to have begun his fraudulent activities at least four years 
earlier than Ambali, and personally obtained a significant portion of the fraudulent 
pandemic benefits he sought.   
Specifically, while Lawal filed more than 790 pandemic unemployment 
applications and more than 3,000 tax returns, Ambali personally submitted approximately 
630 pandemic unemployment applications and eight tax returns.  Lawal’s submissions 
caused more than $300,000 more in loss to the United States.   
Additionally, Lawal personally reaped greater financial gain from his criminal 
conduct than his co-conspirator.  Ambali claimed that he only received US$6,000 of the 
approximately $1 million in loss that he caused.  See Dkt. 43 at 4.  While the government 
disputes this representation based on circumstantial evidence concerning his known 
expenditures and income during the relevant time period, the government has no evidence 
that Ambali obtained a significant portion of the fraud proceeds.  In contrast, as discussed 
above, the government has conclusive evidence that, at least for the first six months of the 
pandemic, Lawal received more than 87% of the fraud proceeds he caused to be paid by 
submitting fraudulent pandemic unemployment applications using the stolen identities of 
American workers.  See supra at 4–5. If Lawal’s share of the proceeds is extrapolated for 
the entire duration of the fraud, he personally obtained more than $1 million in pandemic 
assistance intended for American workers while living unemployed in Canada and Nigeria.  
See PSR at ¶ 56.   
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United States’ Sentencing Memorandum - 12 
United States v. Fatiu Lawal, CR23-5034-TMC-01 
UNITED STATES ATTORNEY 
700 STEWART STREET, SUITE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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Accordingly, sentencing Lawal to 65 months of imprisonment would be appropriate 
and avoid a sentencing disparity with similarly situated defendants including Abidemi 
Rufai and his co-defendant Sakiru Ambali.   
V. 
CONCLUSION 
The Court should sentence Lawal to 65 months of imprisonment and the special 
conditions recommended by Probation, including, upon deportation, prohibiting reentry 
into the United States without permission of the Department of Homeland Security.  The 
Court should further order restitution in the amount of $1,345,472, as agreed upon in the 
Plea Agreement.   
Dated: January 21, 2024 
Respectfully submitted, 
 
TESSA M. GORMAN 
United States Attorney 
 
/s/ Cindy Chang 
 
 
 
CINDY CHANG 
Assistant United States Attorney 
United States Attorney’s Office 
700 Stewart Street, Suite 5220 
Seattle, Washington 98101-1271 
Phone: 206-553-7970 
Fax: 206-553-0582 
Email: Cindy.Chang@usdoj.gov 
 
Case 3:23-cr-05034-TMC     Document 70     Filed 01/21/25     Page 12 of 12

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