Court filing
Bill of Information — United States of America v. Keerria Anderson, Case 3:26-cr-00025-BAJ-EWD (Dkt. 1, M.D. La.)
Summary
Bill of Information for Wire Fraud and Notice of Forfeiture, Document 1 filed March 18, 2026, Case No. 3:26-cr-00025-BAJ-EWD, in the United States District Court for the Middle District of Louisiana. It alleges that Anderson, a full-time United States Postal Service employee, devised a scheme beginning in or around July 2020 and continuing until at least October 2021 to defraud the United States by filing false and fraudulent PPP and EIDL applications, and gained control of approximately $50,962 in pandemic relief proceeds. Count 1 charges wire fraud under 18 U.S.C. § 1343 and cites an electronic transfer of $20,481 on May 3, 2021. The notice of forfeiture seeks property derived from proceeds traceable to the offense. The signature block names Kurt Wall, Acting United States Attorney.
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Record facts
| Court | U.S. District Court for the Middle District of Louisiana |
|---|---|
| Filed | 2026-03-18 |
Cite this document
“Bill of Information — United States of America v. Keerria Anderson, Case 3:26-cr-00025-BAJ-EWD (Dkt. 1).”
U.S. District Court for the Middle District of Louisiana, No. 3:26-cr-00025, Doc. 1, filed 2026-03-18. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/lamd-3-26-cr-00025/2026-03-18-bill-of-information/
, SHA-256 1e5444926122fbfb14c0a5f2f2e9958165604f083add6de4c5cd67f2d22a8c4d.Full text
Case 3:26-cr-00025-BAJ-EWD Document 1 03/18/26 Page 1 of 8
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF LOUISIANA
BILL OF INFORMATION FOR WIR^ FRAUD
AND NOTICE OF FORFEITURE
UNITED STATES OF AMERICA CRIMINAL NO. 26- C^- Q^- PylJ :
^•^0
18U.S.C.§ 1343
versus 18U.S.C.§981(a)(l)(C)
21 U.S.C § 853(p)
28 U.S.C.§ 2461(0
KEERRIA ANDERSON
THE_UNJTED STATES ATTORNEY CHARGES:
At all times relevant to this Bill of Information:
1. Defendant, KEERJRIA ANDERSON, was a resident of Baton Rouge,
Louisiana within the Middle District of Louisiana.
2. ANDERSON was a full-time United States Postal Service employee.
3. Financial Lender 1 was an SBA-approved lender based in Laguna Hills,
California.
4. Financial Lender 2 was an SBA-approved lender based in Bedford, Texas.
5. Bank 1 was a financial institution domiciled in Baton Rouge, Louisiana.
ANDERSON maintained an account ending in x7583 (Acct. x7583) at Bank 1.
COVID-19 Disaster-Relief Programs
6. The Coronavims Aid, Relief, and Economic Security ("CARES") Act was a
federal law enacted in or around March of 2020 and designed to provide emergency financial
assistance to millions of Americans who were suffering the economic effects of the COVID-
Case 3:26-cr-00025-BAJ-EWD Document 1 03/18/26 Page 2 of 8
19 pandemic. The CARES Act provided relief to small businesses through the Paycheck
Protection Program ("PPP") and the expansion of the Economic Injury Disaster Loan
("EIDL") Program.
Paycheck Protection Program
7. The PPP was administered by the Small Business Administration ("SBA") and
provided forgivable loans to small businesses for job retention and certain other expenses. The
PPP permitted participating third-party lenders to approve and disburse SBA-backed PPP
loans to cover payroll and other expenses incurred by qualifying businesses during, and
resulting from, the COVID-19 pandemic. PPP loans were fully guaranteed by the SBA.
8. To obtain a PPP loan, a qualifying business had 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, including that the business was in
operation and either had employees for whom it paid salaries and payroll taxes or paid
independent contractors. A business applying for a PPP loan was required to provide
documentation showing its payroll expenses, such as filed federal income tax documents.
9. PPP loan applications were electronically submitted by the borrower to a third-
party SBA-approved lender, like Financial Lenders 1 and 2. Once approved, the business
received the PPP loan proceeds via an electronic funds transfer from the third-party lender to
a financial account provided by the business in its PPP application documents.
10. The proceeds of a PPP loan were to be used for certain specified items, such as
payroll costs, and were not permitted to be used by the borrower for personal expenses.
Case 3:26-cr-00025-BAJ-EWD Document 1 03/18/26 Page 3 of 8
Economic Injury Disaster Loan Program
11. The CARES Act expanded an existing disaster-related program, the EIDL
program, to provide loan assistance for small businesses and other eligible entities. EIDL
proceeds could be used to pay fixed debts, payroll, accounts payable, and other necessary
financial obligations that could not be met as a direct result of the disaster. Eligible applicants
could also request and receive immediate advances of up to $10,000, which did not have to be
repaid.
12. EIDL funds were issued directly from the United States Treasury, and applicants
could apply through the SBA via an online portal and application. The loan application
required the applicant to acknowledge the program rules and make certain affirmative
certifications in order to be eligible to obtain funds. The application required the applicant to
provide information about the business, such as the number of its employees and its gross
revenues for the 12-month period prior to the date of the disaster. Applicants were required to
certify that the information provided in their applications was true and accurate, and applicants
were warned that any false statement or misrepresentation to the SBA may result in sanctions,
including criminal penalties.
The Scheme to Defraud
13. Beginning in or around July 2020, and continuing until at least October 2021,
in the Middle District of Louisiana and elsewhere, the defendant, KEERRIA ANDERSON,
devised and intended to devise, a scheme and artifice to defraud the United States, through the
SBA, Financial Lender 1, and Financial Lender 2, by filing false and fraudulent applications
for pandemic-related funds.
Case 3:26-cr-00025-BAJ-EWD Document 1 03/18/26 Page 4 of 8
Purpose of the Scheme
14. The purpose of the scheme was for the defendant to unjustly enrich herself by
obtaining pandemic-related funds by means of materially false and fraudulent pretenses,
representations and promises.
Manner and Means
15. In furtherance of the scheme, ANDERSON filed false and fraudulent PPP and
EIDL applications. In her applications, she made false representations and submitted
fraudulent and misleading documents intended to bolster her applications.
16. Specifically, ANDERSON filed the following PPP and EIDL applications,
which contained the false representations described below, among others:
Date Application Applicant Name Example of False Statements
That ANDERSON owned an agricultural
July 5,2020 EIDL Keerria Anderson business with 10 employees and gross
revenues of $99,000 for the tax year 2019.
That ANDERSON's business had a gross
March 31,2021 ppp Keerria Anderson
income of $98,312 for the tax year 2020
That ANDERSON's business had a gross
May 12,2021 ppp Keerria Anderson
income of $98,312 for the tax year 2020
17. In support of her fraudulent PPP applications, ANDERSON submitted
fraudulent and misleading documents, including a fictious 2020 Schedule C 1040 Tax Form,
which falsely represented that her business had more than $98,312 in gross receipts and sales
for the year and the company had more than $49,100 in expenses. As ANDERSON knew at
the time, those representations were not true, because she was employed full-time at the U8PS.
Case 3:26-cr-00025-BAJ-EWD Document 1 03/18/26 Page 5 of 8
18. Based on ANDERSON's false representations, ANDERSON successfully
gained control of approximately $50,962 in pandemic relief proceeds to which she was not
entitled, including the following:
a. EIDL Advance, in the amount of $10,000, disbursed by the SBA to
ANDERSON's Acct. x7583 at Bank 1;
b. A PPP loan, in the amount of $20,481, wired from Financial Lender 1 to
ANDERSON's Acct. x7583 at Bank 1; and
c. A PPP loan, in the mount of $20,481, wire from Financial Lender 2 to
ANDERSON's Acct. x7583 at Bank 1.
19. In October 202 1, ANDERSON submitted applications for PPP loan forgiveness
to Financial Lender 1 and Financial Lender 2. In those applications, ANDERSON certified
that the PPP funds were used for eligible business expenses, such as to maintain payroll.
However, as ANDERSON well knew at the time, the funds were used for personal expenses
unrelated to any business operations.
COUNT 1
Wire Fraud
(18 U.S.C. §1343)
20. The allegations contained in Paragraphs 1-19 are incorporated by reference
herein as factual allegations.
21. On or about the dates set forth below, in the Middle District of Louisiana and
elsewhere, for the purpose of executing the aforementioned scheme and artifice to defraud,
KEEIRRA ANDERSON, the defendant herein, did cause to be transmitted in interstate
commerce the following wire communications, among others:
Case 3:26-cr-00025-BAJ-EWD Document 1 03/18/26 Page 6 of 8
Electronic transfer of $20,481 in PPP fund proceeds
from Financial Lender 1's servers outside of the State
May 3, 2021
of Louisiana to Bank 1 's servers located in the Middle
District of Louisiana.
The above is a violation of Title 18, United States Code, Section 1343.
NOTICE OF FORFEITURE
22. The allegations contained in Paragraphs 1-21 of this Bill of Information are
hereby re-alleged and incorporated by reference for the purpose of alleging forfeitures
pursuant to Title 18, United States Code, Sections 981(a)(l)(C) and 982(a)(l), and Title 28,
United States Code, Section 246 l(c).
23. Upon conviction of Count 1 in this Bill of Information, KEERRIA
ANDERSON, defendant herein, shall forfeit to the United States pursuant to Title 18, United
States Code, Section 981(a)(l)(C), and Title 28, United States Code, Section 2461(c), all
property, real or personal that constitutes or is derived from proceeds traceable to the offense,
including but not limited to a sum of money equal to the amount of the proceeds of the offense.
24. 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 difficulty,
Case 3:26-cr-00025-BAJ-EWD Document 1 03/18/26 Page 7 of 8
it is the intent of the United States, pursuant 21 U.S.C. § 853(p) as incorporated by 28 U.S.C.
§ 246 l(c), to seek forfeiture of any other property of the defendant up to the value of the
forfeitable property described above.
UNITED STATES OF AMERICA, BY
DATE4 ^1X v^ ^
/\ v^-.. ---
KURT WALL
ACTING UNITED STATES ATTORNEY
MIDDLE DISTRICT OF LOUISIANA
\^\<\u^ CA^-^
KRISTEN LUNDIN CRAIG
ASSISTANT UNITED STATES ATTORNEY
Case 3:26-cr-00025-BAJ-EWD Document 1 03/18/26 Page 8 of 8
Criminal Cover Sheet U.S. District Court
Place of Offense: Matter to be sealed: Yes z No
<jtv. Baton Rouge Related Case Information:
County/Parish:. EBR BOI / Docket Number
Same Defendant New Defendant /
investigating Agency: USPS-OIG Magistrate Case Number:
Search Warrant Case No.:
*Agent: Amanda Smith R 20, R 40 from District of:
Any Other Related Cases:
Defendant Information:
Defendant Name: Keerria Andersen
Alias:
Address:
DOB: SS/Alien#: Sex: Race: Nationality:
U.S. Attorney Information:
AUSA: Kristen L. Craig Bar #:LBN 32565
Interpreter: Yes / No List language and/or dialect:
Location Status:
Arrest Date:
Already in Federal Custody as of
Already in State Custody
On Pretrial Release
U.S.C. Citations: Mandatory Minimum Charged?
Total # of Counts: 1 Yes /; No
Petty/
Code Description ofPffense C^ Count(s) Misdemeanor/
Feloin
18U.S.C.§1343 Wire Fraud 1 F
(May be continued on second sheet)
Digitally signed by KRISTEN CRAIG
Date: 2026.03.18 13:46:09 -05'00'
Date: Signature of AUSA:
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