Criminal Complaint & Supporting Affidavit — United States v. Ahmed Sary

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FILED __ ENTERED

10:20 am, Apr 29 2022 1:22-mj-01286-JMC/1:22-mj-01291-JMC CHE )
AT BALTIMORE

CLERK, U.S. DISTRICT COURT
DISTRICT OF MARYLAND

BY Deputy AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT AND
ARREST WARRANT AND APPLICATION FOR SEARCH WARRANTS

Your Affiant, Daniel 8. Parker, a Special Agent with the Federal Bureau of Investigation
(“FBI”) being first duly sworn, hereby deposes and states as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of an application for a Criminal Complaint and
Arrest Watrant, charging Ahmed M. Sary (““SARY”) with Wire Fraud (18 U.S.C. § 1343), Wire
Fraud Conspiracy (18 U.S.C. § 1349), and Money Laundering (18 U.S.C. § 1956).

2. I further make this affidavit in support of search warrants for the person of SARY
(further described in Attachment A-1) and the entire premises located at the following locations:
(1) 1600 S. Hanover Street, Baltimore, MD, 21230, further described in Attachment A-2; (2)
1600 S. Hanover Street, Apt. B, Baltimore, MD, 21230, further described in Attachment A-3;
and (3) 5500 Magie Street, Brooklyn, MD, 21225, further described in Attachment A-4; and a
black Range Rover Sport SUV, VIN#: SALWR2WF0EA372763, Maryland tags 23018CK,
registered to Black Diamond Sedan LLC, 1600 S. Hanover Street, Baltimore, MD 21230, further
described in Attachment A-S (collectively, the “TARGET LOCATIONS”).

3. | I have been a Special Agent with the FBI since April 2005. I am currently assigned
to the FBI’s Baltimore Field Office where I conduct complex white-collar crime investigations in
Maryland. I have duties that include investigations of, among other matters, mail fraud, wire fraud,
aggravated identity theft, fraud against the government, public corruption, and money laundering.
Through my 16-plus year career as a Special Agent, I have assisted and participated in the
preparation and execution of multiple search and arrest warrants, including residential search

warrants.
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4, Based on your Affiant’s investigation, and the facts set forth in this affidavit, there
is probable cause to believe that violations of Wire Fraud (18 U.S.C. § 1343), Wire Fraud
Conspiracy (18 U.S.C. § 1349), and Money Laundering (18 U.S.C. § 1956) (collectively the
“TARGET OFFENSES”) have been committed by SARY and that evidence, fruits, and
instrumentalities of the TARGET OFFENSES are located within the TARGET LOCATIONS
described in Attachments A-1 through A-5. There is also probable cause to search the locations
described in Attachments A-I through A-5 for evidence of the TARGET OFFENSES, as further
described in Attachment B.

5. The facts in this affidavit come from my personal observations, my training and
experience, and information obtained from other investigators and witnesses. This affidavit is
intended to show merely that there is sufficient probable cause for the requested complaint and
warrants and does not set forth all my knowledge about this matter.

6. Through my training and experience, I have become familiar with the methods and
techniques used by criminals to commit financial crimes, and how those criminals conceal, and
store information and assets related to and derived from such criminal activity.

7. Based on my training and experience, and participation in other fraud and money
laundering investigations, your Affiant knows that individuals that commit or attempt to commit
fraud schemes, including loan fraud schemes: maintain files and records related to their schemes
and illegal activities; utilize electronic devices and mediums to transmit documents and records in
furtherance of the scheme; and store those same records on electronic devices.

8. Indeed, based on my knowledge, training, and experience, I know that individuals
who create and use fictitious or fraudulent documents such as the ones described here will often

keep the documents utilized in the furtherance of their scheme in close proximity—usually at their
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personal residence or other private area (including office or vehicle) to hide such items from law
enforcement authorities. I further know that individuals involved in fraud schemes often maintain
records, bank statements, receipts, notes, contact lists, money orders, correspondence, credit or
debit cards, and other papers relating to their schemes in their homes.

9, also know that individuals involved in fraud schemes often maintain and possess
documents—in electronic form or otherwise—that contain evidence of their scheme and potential
co-conspirators in their homes and offices, including, financial and banking records, loan records,
tax records, and employment and payroll records. These records are frequently maintained over
an extended period, including time periods long after any particular transaction is completed.

10. Based on my knowledge, training, and experience, I know that individuals carry
their cellular phones with them virtually everywhere they go (including in vehicles when traveling)
and, when not outside of their homes, keep their cellular phones in near proximity in their

residence.

PROBABLE CAUSE

Background Regarding the U.S. Small Business Administration
Paycheck Protection Program

11, | 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
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 billions of
dollars in forgivable loans to small businesses for job retention and certain other expenses, through
a program referred to as the Paycheck Protection Program (“PPP”).

12. In order to obtain a PPP loan, a qualifying business must submit a PPP loan

application, which is signed by an authorized representative of the business. The applicant of a
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PPP loan was required to acknowledge the program rules and make certain affirmative
certifications in order to be eligible to obtain the PPP loan. In the PPP loan application, the
applicant must state, among other things, its: (a) average monthly payroll expenses and (b) number
of employees. These figures are used to calculate the amount of money the small business is
eligible to feceive under the PPP. In addition, businesses applying for a PPP loan must provide
documentation showing their payroll expenses. To qualify for eligibility, businesses applying for
a PPP loan needed to be in operation before or on February 15, 2020.

13. A PPP loan application must be processed by a participating financial institution
(the lender). If a PPP loan application is approved, the participating financial institution funds the
PPP loan using its own monies, which are 100% guaranteed by the United States Small Business
Administration (“SBA”). Data from the application, including information about the borrower, the
total amount of the loan, and the listed number of employees, is transmitted by the lender to the
SBA in the course of processing the loan. |

14, | PPP loan proceeds must be used by the business for certain permissible expenses—
payroll costs, interest on mortgages, rent, and utilities. The PPP allows the interest and principal
on the PPP loan to be entirely forgiven if the business spends the loan proceeds on these expense
items within a designated period of time and uses a certain percentage of the PPP loan proceeds
on payroll expenses.

15. In or around December 27, 2020, the Economic Aid to Hard-Hit Small Business,
Nonprofits and Venues Act provided additional funding for the PPP program and extended the
application deadline to March 31, 2021. The Act enabled borrowers to take a second draw PPP
loan under the same general terms as their first PPP loan up to a maximum loan amount of $2

million. The Act reopened the program to borrowers who did not previously receive a first draw
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PPP loan. To be eligible for a second draw, borrowers must employ no more than 300 employees,
demonstrate a 25% reduction in gross receipts during a calendar quarter in 2020, and have
_ expended the full amount of their initial PPP loan. Allowable expenses were expanded to include
worker protection costs related to COVID-19, uninsured property damage costs caused by looting
or vandalisen during 2020, and certain supplier costs and expenses for operations. The expansion

applies retroactively to first draw PPP loans that have not been forgiven by the SBA.

Background Regarding the U.S. Small Business Administration.
Economic Injury Disaster Loan Program

16. AnEconomic Injury Disaster Loan (“EIDL”) is an SBA administered loan designed
_ to provide assistance to small businesses that suffer substantial economic injury as a result of a
declared disaster. An EIDL helps a business meet necessary financial obligations that could have
been met had the disaster not occurred. It provides relief from economic injury that the disaster
caused and permits a business to maintain a reasonable working capital position during the period
that the disaster affected.

17. Additionally, the SBA offers'an EIDL advance that is designed to provide
emergency economic relief to businesses that are currently experiencing a temporary loss of
revenue. This advance does not have to be repaid, and small businesses may receive an advance,
even if they are not approved for an EIDL loan. The maximum advance amount is $10,000.00.
The amount of the loan offered as well as the advance amount are determined by the SBA based .
on the information provided on the loan application.

18. EIDL funds are issued directly from the United States Treasury and applicants
apply through the SBA via an online portal. The EIDL application process, which also uses certain
outside contractors for system support, collects information concerning the business and the

_ business owner, including information as to the gross revenues for the 12 months prior to the
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disaster, the cost of goods sold, and information as to any criminal history of the business owner.
Applicants electronically certify that the information provided is accurate and are warned that any
false statement or misrepresentation to the SBA or any misapplication of loan proceeds may result
in sanctions, including criminal penalties.

19. In March 2020, due to the COVID-19 pandemic, the SBA issued an EIDL
declaration. The declaration made EIDL loans available nationwide to small businesses to help
alleviate economic injury that COVID-19 caused. EIDL loans are usually limited to a maximum
amount of $2 million, however, during the COVID-19 pandemic, EIDL loans were limited, for a
period of time, to $150,000.00 per loan.

SBA Loans Obtained Directly by SARY

20. In September 2020, a Baltimore County Police Department (“BCPD”) detective
identified fraudulent PPP loan applications and loans associated with the targets of a criminal
investigation being conducted by that agency. The targets of the BCPD investigation submitted
loan applications on behalf of businesses that did not exist in any legitimate capacity. The loan
applications contained false statements concerning the number of employees employed by the
businesses, the financial earnings and payroll expenses of the businesses, and income taxes
withheld by the businesses. Further, the loan applications were supported by false documents
supplied by the applicants, which included purported Internal Revenue Service (“IRS”) Form W-
3 Transmittal of Wage and Tax Statements that were not consistent with IRS records.

21. A review of financial records, communications, and other information obtained by
the BCPD detective led to the identification of several other individuals who also applied for and

received SBA PPP loans and EIDLs in a similar manner, including SARY.
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22. [have reviewed SBA records and identified several PPP and EIDL loans obtained
by SARY for businesses that he owns and/or controls, as well as PPP and EIDL loans submitted
for businesses and purported businesses owned by co-conspirators.

23. The PPP and EIDL applications submitted by SARY were found to contain false
statements and misrepresentations regarding SARY and his respective businesses. Many of the
applications were submitted on behalf of businesses that either did not exist in any legitimate
capacity, and/or businesses that grossly over-represented their financial conditions and number of
employees. Further, the wages and financial conditions represented in the loan applications were
not consistent with IRS records. Likewise, the spending of the SBA loan proceeds was often
inconsistent with typical payroll and other business expenses allowable under the SBA loan -
program parameters. |

24, All the loan applications and supporting documents were submitted by SARY to
the SBA (or through SBA authorized lenders) electronically via the internet, and loan proceeds
were often! disbursed via ACH transfers, causing interstate wire communications to be sent in
furtherance of the scheme to defraud.

25. Your Affiant has identified nine (9) potentially fraudulent loan applications,

totaling $949,559.00, submitted by SARY. Each of the PPP loans and EIDLs associated with

SARY are summarized in the table and more fully discussed below.

Am Halal Meat Inc PPP $119,311.00 06/19/2020 8576977906
Am Halal Meat Inc EIDL $40,000.00 6/24/2020 2738168009
Am Halal Meat Inc _ PPP $119,310.00 2/20/2021 2051408503
AMEX Financial Group Inc_| EIDL $145,000.00 6/11/2020 2309567910
AMT Pizza Inc EIDL $65,000.00 6/24/2020 2737238004
AMT Pizza Inc PPP $139,938.00 6/30/2020 5473368007
Sary Stars Inc PPP $102,000.00 5/27/2020 | 2128967804
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Sary Stars Inc EIDL $117,000.00 6/24/2020 2805928008
Sary Stars Inc PPP $102,000.00 2/24/2021 8680618409

Am Halal Meat Inc EIDL and PPP Loans

26. Information obtained from the SBA indicated that a first draw PPP loan (#
8576977906) was submitted on behalf of the business Am Halal Meat Inc. According to the loan
information, the address listed for the PPP loan application was 1600 S. Hanover Street,
Baltimore, MD, 21230, known to be associated with SARY and discussed further below. The
email address associated with the loan was am.halal@yahoo.com and the associated telephone
number was 202-255-6007, also known to be used by SARY and discussed further below.

27. | SBA PPP loan # 8576977906 was issued to Am Halal Meat Inc in the amount of
$119,311.00. On June 19, 2020, the loan proceeds were credited to a TD Bank account ending in
20371 and controlled by SARY.

28.! SBA records also indicated that SARY applied for an EIDL on behalf of Am Halal
Meat Inc on June 18, 2020. The SBA records identified SARY as the user submitting the
application and included SARY’s correct social security number (“SSN”) and other personally
identifiable information (“PII”),

29. The email address associated with the EIDL application was am.halal@yahoo.com.
The business address was listed as 1600 S. Hanover Street, Baltimore, MD, 21230. SARY’s
residential address of 5500 Magie Street, Brooklyn Park, MD, 21225, was also listed on the loan
application. The telephone number listed on the application was 202-255-6007, the same phone
number referenced above.

30. The EIDL application information indicated that Am Halal Meat Inc had ten (10)

employeesiand gross revenue of $750,000.00 for the twelve months prior to January 31, 2020.
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31 On June 24, 2020, SBA EIDL # 2738168009 was issued to Am Halal Meat-Inc in
the amount of $40,000.00. The loan proceeds were disbursed via ACH transfer to the same TD
Bank account ending in 20371 and controlled by SARY. SARY also received an additional
payment of $10,000.00, possibly an EIDL advance payment, on June 23, 2020.

32. Information obtained from TD Bank indicated that SARY also applied for a second
draw PPP loan on behalf of the business Am Halal Meat Inc on January 29, 2021. The loan
application identified SARY as the business owner and included his correct SSN and other PII.

33. The business address was listed as 1600 S. Hanover Street, Baltimore, MD,
21230, the same address referenced above. SARY’S residential address of 5500 Magie Street,
Brooklyn Park, MD, 21225, was also listed on the loan application. Telephone number 202-384-
0110 was listed for both the business and SARY. |

34. In the SBA second draw PPP loan application information provided by TD Bank,
~ SARY indlcated that Am Halal Meat Inc had seven (7) employees and paid over $570,000.00 in

wages. The loan application also contained a certification that the business “was in operation on

. _ February 15, 2020...or had employees for whom it paid salaries and payroll taxes or paid:

independent contractors” which was acknowledged affirmatively by SARY.

35. Additional TD Bank records concerning the loan application indicated that the
business had a gross annual revenue of $1,347,302.00 as of December 2019. The records also
indicated the business had filed business taxes within the last 18 months. |

36. On February 20, 2021, SBA PPP loan # 2051408503 was issued to Am Halal Meat
Inc in the amount of $119,310.00. On February 24, 2021, the loan proceeds were credited to the ~
same TD Bank account ending in 20371 and controlled by SARY. |

37. Maryland State Department of Assessments & Taxation (“Maryland SDAT”)
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records indicated that Articles of Incorporation for Am Halal Meat Inc were filed on August 16,
2016. The(document identified SARY as the resident agent of the business and listed the business
address of 1600 S. Hanover Street, Baltimore, MD, 21230. The document identified the purpose
of the corporation as “wholesale and retial [sic] halal meat”. |

38. | The TD Bank account number ending in 20371 was opened on January 30, 2018,
for the business Am Halal Meat Inc. SARY is the sole individual listed on the account opening
documents. The business address is listed as 1600 S. Hanover Street, Baltimore, MD, 21230.
The bank account opening documents listed the principal line of business as “Meat and meat
product merchant wholesalers ".

39, The proceeds of the Am Halal Meat Inc first and second draw PPP loans and EIDL
were all deposited into the TD Bank account ending in 20371. Bank account records for the
account showed transactional activity inconsistent with the purported business revenue, employee
wages, and other information supplied on the SBA loan applications.

40. In addition to the banking activity being inconsistent with the business’s financial
activity represented on the loan applications, bank records indicated several payments to other
individuals and transfers to other accounts controlled by SARY were made from the account
following the deposits of the loan proceeds.

41. Surveillance was conducted at 1600 S. Hanover Street, Baltimore, MD, 21230 on
multiple occasions. Based on your Affiant’s training and experience, the property was not
consistent with the type of location used for the retail and/or wholesale processing or sale of meat
products. The property is described as a mixed use residential/commercial property located in a
primarily residential neighborhood in Baltimore City, Maryland. The property consists ofa street

level commercial style storefront with an attached apartment unit accessed via a side entrance.
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During surveillance, there were no observations made by investigators that indicated the property
was being used for a meat product business. There were no company signs, no employees or
customers were seen coming or going, and there were no other indications that the business was
operating at the location. Additional surveillance observations of the location are described further
below.

42. Open-source investigation of Am Halal Meat Inc revealed no online business
presence consistent with an active business. Investigators were unable to identify a business
website, customer reviews, advertisements, telephone listing, social media presence, or other open-
source information commonly found for retail and wholesale food product businesses,

43. IRS records also indicated that there was no record of IRS Form 1120 US
Corporation Income Tax Return filings for Am Halal Meat Inc for the tax years 2019 or 2020.

AMEX Financial Group Inc EIDL

44. . SBA records indicated that SARY applied for an EIDL on behalf of AMEX
Financial Group Inc on April-4, 2020. The SBA records identified SARY as the user submitting
the application and included SARY’s correct SSN and other PII as well as an uploaded image of
his genuine Maryland Driver's License. | |

45. | The email address dssociated with the EIDL application was
amexgroup2@gmail.com. The business address was listed as 1600 S. Hanover Street,
Baltimore, MD, 21230, the same address referenced above and known to be associated with
SARY. SARY’s residential address of 5500 Magie Street, Brooklyn Park, MD, 21225, was also
listed on the loan application.

46.{ The EIDL application indicated that AMEX Financial Group Inc had five (5)

employees and gross revenue of $500,000.00 for the 12 months prior to January 31, 2020. The
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applicatiort listed a business category of “Tax Return Preparation Services.”

41. On June 11, 2020, SBA: EIDL # 2309567910 was issued to AMEX Financial Group
Inc in the amount of $145,000.00. The loan proceeds were disbursed via ACH transfer to a Bank
of America bank account ending in 77096 and controlled by SARY.

48. Maryland SDAT records indicated that Articles of Incorporation for AMEX
F inancial Group Inc were filed on April 7, 2014. The document identified SARY as the resident
agent of the business. On November 10, 2015, a corporate resolution changing the business
address to 1600 S. Hanover Street, Baltimore, MD, 21230 was filed with Maryland SDAT.

49, The Bank of America account number ending in 77096 was originally opened on
April 7, 2014, for the business AMEX Financial Group Inc. SARY is the sole individual listed on

the account opening documents.

50. The Bank of America account records for account ending in 77096 showed

transactional activity inconsistent with the purported business revenue, employee wages, and other
information supplied by SARY on the SBA loan applications. Further, bank records indicated
payments to individuals associated with SARY and transfers to other accounts controlled by
SARY were made from the account following the deposit of the loan proceeds.

51. Surveillance was conducted at 1600 S. Hanover Street, Baltimore, MD, 21230,
as previously referenced. Based on your Affiant’s training and experience, the property was not
consistent with an operating tax preparation or financial services business. During surveillance,
there were no observations made by investigators that indicated the property was being used for a
tax preparation or financial services business. There were no company signs, no employees or

customers were seen coming or going, and there were no other indications that the business was
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operating at the location. Additional surveillance observations of the location ate described further
below.

52. Open-source investigation of AMEX Financial Group Inc revealed minimal
available information, none of which appeared consistent with an operating business. Investigators
were able to locate a company website that represented the business provided various financial
and tax services, but did not list an address, phone number, email address, or other means of contact
for the business,

33. IRS records also indicated that there was no record of IRS Form 1120 U.S.
Corporation Income Tax Return filings for AMEX Financial Group Inc for the tax years 2019 or
2020.

AMT Pizza Inc EIDL and PPP Loan

54. SBA records indicated that SARY applied for an EIDL on behalf of AMT Pizza
Inc, trade name Full House Pizza, on June 18, 2020. The SBA records identified SARY as the
user submitting the application and included SARY’s correct SSN and other PI.

55. The business address associated with the application was listed as 81 Shipping
Place, Dundalk, MD, 21222. SARY’s residential address of 5500 Magie Street, Brooklyn Park,
MD, 21225, was also listed on the loan application.

56. The EIDL application information indicated that AMT Pizza Inc had fifteen (15)
employees and gross revenue of $600,000.00 for the twelve months prior to January 31, 2020. The
application listed a business category of “Restaurant — Fast Food & Carry Out.”

57.{ On June 24, 2020, SBA EIDL # 2737238004. was issued to AMT Pizza Inc in the
amount of $65,000.00. The loan proceeds were disbursed on June 26, 2020, via ACH transfer to

an M&T Bank account ending in 88242 and controlled by SARY.
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58. Maryland SDAT records indicated that Articles of Incorporation for AMT Pizza
Inc were filed on March 28, 2017. The document identified SARY as the resident agent of the
business and listed his residential address. Articles of Amendment for the corporation and a
| Corporate Resolution regarding change of address of the resident agent were filed with Maryland
SDAT on February 1, 2019. The documents identified Rehab Saad (“Saad”) as the company
director and indicated a change of address from SARY’s residential address to 1600 S. Hanover
Street, Baltimore, MD, 21230.
59. | The M&T Bank account number ending in 88242 was opened on June 18, 2020, —
for the business AMT Pizza Inc. Saad is the signatory on the account opening documents. The
business address is listed as 81 Shipping Place, Baltimore, MD, 21230. Saad’s address is listed as
1600 S. Hanover Street, Apt. B, Baltimore, MD, 21230, the same address referenced above, and
known to be associated with SARY. |
60. On August 18, 2020, approximately two months after the proceeds of the AMT
. Pizza Inc EIDL were deposited into the M&T Bank account ending in 88242, the funds were
reversed out of the account and retumed to the SBA from the bank. Notes in the SBA loan records
indicate that was possibly due to an inability to verify that the bank account was associated with
the business. The loan was later declined, and the loan proceeds were never accessed.

61. IRS records indicated that there was no record of business tax filings for AMT Pizza
Inc for the tax yeats 2019 or 2020. |

62. Records from Kabbage, Inc. (“Kabbage”), an SBA approved lender, indicate that
SARY applied for a first draw PPP loan on behalf of AMT Pizza Inc on June 30, 2020. The
application, signed by SARY, noted that the business had six (6) employees and an average

monthly payroll of $55,976.00.
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63. | The requested PPP loan (SBA loan # 5473368007) in the amount of $139,938.00
ultimately did not close, however, as W-2 tax forms for all of AMT Pizza Inc’s purported
employees that were requested by Kabbage to substantiate the content of the application were

never provided.
Sary Stars Inc EIDL and PPP Loans

64, Information obtained from the SBA indicated that a first -draw PPP loan (#
2128967804) was submitted on behalf of the business Sary Stars Inc. The business address
associated with the loan was listed as 1600 S. Hanover Street, Baltimore, MD, 21230, the same
address referenced above and known to be associated with SARY. Telephone number 202-352-
2924, subscribed to by AMEX Financial Group Inc, an entity controlled by SARY, was listed on
the SBA loan records.

65, On May 27, 2020, SBA PPP loan # 2128967804 was issued to Sary Stars Inc in the
amount of $102,000.00. On May 27, 2020, the loan proceeds were credited to an M&T Bank
account ending in 99296 and controlled by SARY.

66. SBA records also indicated that SARY applied for an EIDL on behalf of Sary Stars
Inc on June 18, 2020. The SBA records identified SARY as the user submitting the application
and included SARY’s correct SSN and other PII.

67. The business address associated with the loan application was listed as 1600 S.
Hanover Street, Baltimore, MD, 21230, the same address referenced above and known to be
associated \vith SARY. SARY’s residential address of 5500 Magie Street, Brooklyn Park, MD,
21225, was also listed on the loan application.

68. The EIDL application information indicated that Sary Stars Inc had eight (8)

employees and gross revenue of $750,000.00 for the twelve months prior to January 31,2020. The
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application listed a business category of “Entertainment Services” and “Event Planning.”

69. On June 24, 2020, SBA EIDL # 2805928008 was issued to Sary Stars Inc in the
amount of $117,000.00. The loan proceeds were disbursed via ACH transfer to the same M&T
Bank account ending in 99296 and controlled by SARY’s wife, Izabela Sary.

70. Information obtained from the SBA indicated that a second draw PPP loan (#
8680618409) was also submitted on behalf of the business Sary Stars Inc. According to the SBA
records, the business address was listed as 1600 S. Hanover Street, Baltimore, MD, 21230, the
same address referenced above, and known to be associated with SARY. .

74 On February 24, 2021, SBA PPP loan # 8680618409 was issued to Sary Stars Inc
in the amount of $102,000.00. On February 24, 2021, the loan proceeds were credited to the same
M&T Bank account ending in 99296 and controlled by SARY’s wife, Izabela Sary.

72. Maryland SDAT records indicated that Articles of Incorporation for Sary Stars Inc
were filed on July 25, 2011. The document identified SARY as the resident agent of the business.
Articles of Revival were filed with Maryland SDAT on August 16, 2016, and listed the principal
address of 1600 S. Hanover Street, Baltimore, MD, 21230. The records also reflect SARY’s
residential address of 5500 Magie Street, Brooklyn Park, MD, 21225. |

73. The M&T Bank account number ending in 99296 was originally opened on May 2,
2019, for the business Sary Stars Inc. SARY’s wife, Izabela Sary, is listed on the account’s
opening documents.

74. The proceeds of the Sary Stars Inc first and second draw PPP loans and EIDL were
deposited into the M&T Bank account ending in 99296, controlled by SARY’s wife. Bank account
records for the account showed minimal banking activity between the opening of the account in

May 2019 and the deposit of the first draw PPP loan in May 2020. The records did not show any
Case {:23-cr-00344-RDB Document1-1 Filed 04/29/22 Page 17 of 30

payroll activity or other transactional activity consistent with the business revenue and employee
wages represented on the loan applications.

75. In addition to the banking activity being inconsistent with the business financial
activity represented on the loan applications, bank records indicated several payments were made
directly from the account to SARY and his wife following the deposit of the loan proceeds. The
payments from the account directly to SARY totaled more than $48,000.00 and the payments from
the account directly to Izabela Sary totaled more than $50,000.00

76. Surveillance was conducted at 1600 S. Hanover Street, Baltimore, MD, 21230,
as previously referenced. Based on your Affiant’s training and experience, the property was not
consistent with an operating event planning business. During surveillance, there were no
observations made by investigators that indicated the property was being used for an event
planning business. There were no company signs, no employees or customers were seen coming
or going, and there were no other indications that the business was operating at the location.
Additional surveillance observations of the location are described further below in the SBA Loan |
Fraud Kickback Scheme section.

77. — IRS records also indicated that there was no record of business tax filings for Sary
Stars Inc for the tax year 2019.

SBA Loan Fraud Kickback Scheme

78.{ In addition to the SBA loans obtained directly by SARY for entities he controlled,
there is probable cause to believe SARY and others engaged in a scheme to recruit and assist
business owners with the submission of fraudulent PPP and EIDL loan applications in exchange

for a portion of the loan proceeds. SARY represented to business owners that he could assist in
Case 1:23-cr-00344-RDB Document1-1 Filed 04/29/22 . Page 18 of 30
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the preparation of documents and the submission of loan applications to the SBA in order to secure
loans for the business loan applicants.

79, Law enforcement has identified numerous relevant EIDL and PPP loans disbursed
to businesses located throughout the United States that resulted in apparent kickback payments to
SARY and his associates or entities they controlled. The loans were disbursed based on loan
applications and supporting documents submitted to SBA approved PPP lenders, and EIDL 4
applications and supporting documents submitted directly to the SBA. Individual principals
associated pith each of the businesses were listed on the loan applications (“loan applicants”).
The approved loans were disbursed to bank accounts associated with each of the businesses or loan
applicants.

80. The PPP loan and EIDL applications associated with the businesses and loan
applicants receiving the loans contained false statements and misrepresentations regarding the
individuals and their respective businesses. The applications frequently misrepresented the
number of employees employed by the businesses, payroll expenses of the businesses, or were
submitted on behalf of businesses that either did not exist in any legitimate capacity, and/or
businesses that grossly over-represented their financial conditions and gross revenue. Further, the
loan applications were frequently supported by altered or forged bank statements and tax related
documents that were not consistent with IRS records. Likewise, the spending of the SBA loan
proceeds was often inconsistent with typical payroll and other expenses allowable under the SBA
Joan program parameters. 7
81. All the loan applications and supporting documents were submitted by, or on behalf

of, the loan applicants to the SBA (or through SBA authorized lenders) electronically via the
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internet, and loan proceeds were often disbursed via ACH transfers, causing interstate wire
communications to be sent in furtherance of the scheme to defraud.

82. Shortly after the SBA loans were disbursed, the loan applicants used a portion of
the loan proceeds to make kickback payments to SARY, his co-conspirators, or entities they
‘controlled. The payments originated from accounts controlled by the businesses receiving the loan
proceeds or the individual loan applicants, and were funded by the recently disbursed SBA loan
funds.

33,! The kickback payments were frequently structured or made in a manner to conceal
the nature and total amount of the payments and created the appearance that the payments were
for legitimate business purposes. This included: memos indicating the payments were for business
related purposes, loan applicants structuring multiple payments to different entities controlled by
SARY and his associates, and the use of different banking institutions to reduce the possibility of
alerts of suspicion.

84, Your Affiant has identified more than 40 potentially fraudulent SBA loans, totaling
at least $10 million that resulted in kickback payments of more than $2.5 million to SARY and his
associates.

85, | Many of the SBA loan applications originated from IP addresses associated with
SARY’s plirported business, AMEX Financial Group Inc. For example, according to records
provided by Comcast, IP address 69.140.17.191 was assigned to the subscriber AMEX Financial
Group Ine from January 25, 2021 to March 16, 2021. Both the service and billing address for the

account was 1600 S, Hanover St, Baltimore, MD 21230, an address associated with SARY.
Case 1:23-cr-00344-RDB Document1-1 Filed 04/29/22 Page 20 of 30
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86. Records obtained from Cross River Bank indicate that IP address 69.140.17.191
was used to submit applications for eighteen (18) PPP loans during the period of March and April
2021.

87. Moreover, records from the SBA indicate that IPv6 address 2603:3003:1366:2000
was used to submit applications for fifty-four (54) EIDL loans during the period of June 2020 to
December 2021. This IPv6 address was assigned to the subscriber AMEX Financial Group Inc
from July 73, 2021 to January 3, 2022. Both the service and billing address for the account was
1600 S. Hanover St, Baltimore, MD 21230, an address associated with SARY. Comcast had no
subscriber information for the period prior to July 23, 2021; however, EIDL applications submitted
in June 2020 for Sary Stars, Inc and AMT Pizza Inc—both associated with SARY (as discussed

above)—were submitted using IPv6 address 2603:3003:1366:2000.
| 88. Additionally, records from SBA indicate that IP address 151.196.245.252 was used
to submit applications for two (2) EIDLs on April 6, 2020, including one for AMEX Financial
Group Inc. Records provided by Verizon Internet Services indicate that IP address
151.196.245.252 was subscribed to SARY From January 23, 2020 to December 1, 2020. The
account address was 5500 Magie St., Brooklyn, MD 21225, SARY’s home address.

89. . An example of one of the identified loans and payments in connection with the
fraud and kickback scheme is discussed in further detail below. The misrepresentations on the
loan application, misuse of the loan proceeds, and use of a portion of the loan proceeds to make
kickback payments is consistent with other loans identified during the investigation but not

specifically described below.
Case 1:23-cr-00344-RDB Documenti1-1 Filed 04/29/22 Page 21 of 30
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Applicant 1’s PPP Loan, Loan Spending, and Kickback Payments

90. Information obtained from Cross River Bank, an authorized SBA lender, indicated
that a PPP loan application was submitted for the business of Applicant 1 on March 24, 2021. The
loan application identified Applicant 1 as the business owner and included the applicant’s correct

SSN and other PII as well as an image ofa genuine Maryland Driver’s License issued to Applicant

1.

|

91. On the loan application, the following items were selected under the loan purpose
section: Payroll, Rent/Mortgage Interest, Utilities, and Covered Operations Expenditures.

92. The business address listed on the PPP loan application was the address of a United
States Post Office in Baltimore, Maryland.

93. The PPP loan application information indicated that Applicant 1’s business was
established in April 2012, had thirteen (13) employees, and an average monthly payroll of
$104,900.87 (equivalent to more than $1,250,00.00 annually). The loan application also contained
a certification that the business “was in operation on February 15, 2020...or had employees for
whom it paid salaries and payroll taxes or paid independent contractors’ which was
acknowledged affirmatively.

94,| Supporting documents submitted along with the loan records from Cross River
Bank included an image of a cancelled check from a JPMorgan Chase Bank account ending in

“00052 with a payor of Applicant 1’s business, digital PDF files of a purported February 2020
statement for the JPMorgan Chase Bank account ending 00052, and a purported IRS Form 940 for
2019: Employer’s Annual Federal Unemployment Tax Return.

95. The JPMorgan Chase Bank statement contained a number of alterations including -

mismatched sizing and fonts, spacing errors, and incorrect formatting. Moreover, I have reviewed
Case 1:23-cr-00344-RDB Document1-1 Filed 04/29/22 Page 22 of 30
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records from JPMorgan Chase Bank for the account ending in 00052 which reflect that the account
- was not opened by Applicant 1 until March 6, 202 1—just weeks before the PPP loan application
was submitted, and well after the date of the purported February 2020 statement. The document
properties associated with the falsified digital PDF file also indicated it was created in Microsoft
Word on January 22, 2016, and last modified on March 19, 2021 (just five days before the PPP
loan application for the business was submitted).

96. The purported IRS Form 940 for 2019 indicated that Applicant 1’s business paid
$1,25 8,810.53 in employee wages in 2019, But records provided by the IRS indicated that there
was no record of any business tax filings for the business for the tax years 2019 or 2020.

97. On March 26, 2021, SBA PPP loan # 6451248609 was issued to Applicant 1’s
business in the amount of $262,252.00. The loan proceeds were disbursed on March 26, 2020, via
ACH transfer to the JPMorgan Chase Bank ending in 00052 and controlled by Applicant 1.

98. From the opening of the JPMorgan Chase Bank account on March 6, 2021, until
the deposit of the PPP loan on March 26, 2021, there was no banking activity associated with the
account ending in 00052. There were no payroll expenses debited from the account or other
activity consistent with the employee wages represented on the PPP loan application. The first
activity in the account was the deposit of the PPP loan proceeds.

99. Within one week of the date the PPP loan funds were credited to the JPMorgan
Chase Bank ending in 00052, kickback payments totaling $78,000.00 were made to entities
controlled by SARY and one of his associates. More specifically, check # 2351, dated March 31,
2021, and payable to the business “Am Halal Meat” for the amount of $40,000.00, was drawn on
Applicant 1’s JPMorgan Chase Bank account ending in 00052 and deposited into an Am Halal

Meat Inc account at TD Bank, controlled by SARY. Also, a check for $38,000.00, was drawn on
Case 1:23-cr-00344-RDB Document1-1 Filed 04/29/22 Page 23 of 30
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‘the JPMorgan Chase Bank account ending in 00052 and deposited into an account associated with
one of SARY’s associates.

100. Bank records provided by JPMorgan Chase Bank and payroll records provided by
“Payroll Processor 1”—a payroll processor—identified ten (10) purported employees of Applicant
1’s business. A review of wage records provided by the State of Maryland Department of Labor, |
Licensing Lind Regulation (“Maryland DLLR”) revealed that only one of the ten purported

| employees received wages in Maryland from the business. Records from Payroll Processor 1
further reflect that it started payroll processing for the business on or about April 9, 2021, Its
records reflect that a services agreement was signed by Applicant 1 on March 30, 2021—four days
after Applicant | received the PPP loan funds. According to records provided by Maryland DLLR,
Applicant I has never received wages from his business.

101. Furthermore, according to records provided by Mercedes-Benz Financial, on
January 19, 2021, Applicant 1 purchased a Mercedes-Benz $550V4 luxury automobile—making
a $1,400.00 deposit and financing the balance of $76,690.65.

102. Law enforcement likewise learned that on April 25, 2021, Applicant 1 signed a
lease to rerit an apartment at a luxury high rise in downtown Baltimore. Lease records indicated
that the security deposit was $1,845.00 and the monthly rent payments owed were $1,845.00. The
initial lease term was from May 1, 2021 through April 30, 2022.

103. According to information provided by the property manager, Applicant 1’s lease
was extended until May 2023. In addition, Applicant 1 made several large payments which appear
to be advance payments for future months’ rent. On July 19, 2021, the apartment building posted

_ acashier’s check in the amount of $20,200.00 from Applicant 1 from a Wells Fargo Bank account.

However, this cashier’s check was returned on August 12, 2021. On August 27, 2021, another
Case 1:23-cr-00344-RDB Documenti1-1_ Filed 04/29/22 Page 24 of 30

cashier’s check in the amount of $18,333.94 from Applicant 1, drawn on a Wells Fargo Bank
account, was posted to Applicant 1’s account at the building. As of March 2, 2022, there was a
positive balance on the account in the amount of $8,788.33. This amount would cover more than
the next four rent payments of $1,845.00, which would run through July 31, 2022.

104. On April 26, 2022, law enforcement executed a search and seizure warrant at
Applicant .1’s residence in Baltimore, Maryland and seized multiple electronic devices, as well as
approximately $30,000.00 .in U.S. currency. After voluntarily waiving his Miranda rights,
Applicant | agreed to speak with law enforcement. Applicant 1 stated, among other things, that
(1) someone known as “Adam” whose office was on Hanover Street in Baltimore, Maryland
submitted the PPP loan application on Applicant 1°s behalf: (2) Applicant 1 had never seen the
IRS Form 940 (Employer’s Annual Federal Unemployment Tax Return) or February 2020 bank
statement that were submitted in connection with the PPP application for Applicant 1’s business,
and that neither the tax form nor the bank statement were accurate; (3) Applicant I had never seen -
the PPP loan application itself; and (4) “Adam” assisted Applicant 1 with setting up payroll
services with Payroll Processor 1,

105. I further know, from my review of call records, that a phone number associated

Applicant 1 contacted SARY the same day the warrant was executed at Applicant 1’s residence,

Search Warrant for Electronic Accounts Associated With SARY
106. On March 9, 2022, the Honorable Matthew J. Maddox, United States Magistrate
Judge authorized a warrant for, among other things, various electronic account information
associated with SARY, including the Google LLC accounts amexgroup2@gmail.com and
mynucredit@gmail.com.

107, A review of the returns for the search warrant revealed the existence of more than _
Case 1:23-cr-00344-RDB Document1-1 Filed 04/29/22 Page 25 of 30
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30 emails attaching a document titled “PPP Submission” form—all of which were filled out. To
date, I have located completed PPP Submission forms for 26 businesses. The form included fields
for “Borrower Information” such as first name, last name, social security number, address, email
address, date of birth, phone number, and email address. It also included fields for “Business
Information” such as business name, address, phone, business start date, EIN, as well as bank
account and routing information.

108. The “PPP Submission” form contained no fields associated with the businesses’
financial condition, such as, business payroll or number of employees.

109. A review of the returns for the search warrant also revealed the existence of multiple
emails between amexgroup2@gmail.com and Payroll Processor 1 concerning 35 businesses across
the United States—all of which received PPP loans—and for which AMEX Group Financial Inc
served as Payroll Processor 1’s “Affiliate Partner.” One of those emails included a Microsoft
Excel spreadsheet titled “Amex Financial Group Account List 2” that listed 35 businesses that had
received payroll services from Payroll Processor 1. AMEX Financial Group is listed in the column
for “A ffilidte Name” in the row for each business. Applicant 1’s business is among the entities on
the list.

110. As noted above, Applicant 1 noted that someone known as “Adam” submitted the
PPP loan application on Applicant 1’s behalf. My review of the returns for the search warrant
revealed emails to the amexgroup2@gmail.com in which SARY is referred to as “Adam Sary.”
For example, in an email dated July 29, 2021, an employee of Payroll Processor | emailed another
employee, copying amexgroup2@gmail.com, and noted “I received this text from Adam Sary. He
wants to Terminate these employees from the following companies, I do not know who the Payroll

Specialists are for these companies.” The email attaches a photograph of a phone displaying a text
Case 1:23-cr-00344-RDB Document1-1 Filed-04/29/22 Page 26 of 30
1:22-mj-01286-JMC/1:22-mj-01291-JMC

sent by a contact listed as “Adam” or “AS” that attaches a driver’s license of two individuals and
which notes, “Can you please take both of them off of the payroll Sary stars / Amex / am halal.”
Later emails in the email thread sent by an employee of Payroll Processor 1 to
amexgroup2@gmail.com address SARY as “Ahmed” and “Sary.”

111. Search history for the amexgroup2@gmail.com account revealed multiple searches
and visits to websites discussing PPP fraud and PPP fraud enforcement, including searches for
“state union PPP,” “ppp fraud arrests 2021,” and “sba fraud arrests” and a visit to a Department of
Justice’s website linking to an indictment charging two individuals in the Western District of North
Carolina with Wire Fraud and Wire Fraud Conspiracy based on their submission of allegedly
fraudulent PPP loans.

Surveillance

112. I understand that the building located at 1600 S. Hanover Street, Baltimore, MD,
21230 has an office accessed from the front of the property, and an apartment in the t rear of the
property. The apartment is accessible by a separate door on the side of the building accessed along .
West Randall Street. While there are second and third floors of the property visible from the
exterior, I understand that there is no access to the upper floors from the office or the apartment,
On December 30, 2021, investigators conducted surveillance and observed SARY open the door
on the side of the building, which had a mailbox marked “Apt. B” next to it (as further described
in Attachment A-3), and entered the apartment. - )

113. On April 27, 2022, investigators conducted surveillance at 1600 S. Hanover Street,
Baltimore, MD, 21230 and 5500 Magie Street, Brooklyn, MD, 21225. At approximately 5:00
p.m., law enforcement observed SARY leave his home at 5500 Magie Street, Brooklyn, MD,

21225 and travel to 1600 S. Hanover Street, Baltimore, MD, 21230 and enter the building.

|
Case 1:23-cr-00344-RDB Document 1-1 Filed 04/29/22 Page 27 of 30
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SARY was observed at the office location until approximately 8:30 PM. SARY drove from 5500
Magie Street, Brooklyn, MD, 21225 to 1600 S. Hanover Street, Baltimore, MD, 21230 in a
Range Rover Sport SUV, VIN: SALWR2WF0EA372763, Maryland ‘tags 23018CK.
According Lo Maryland Motor Vehicle Administration (MVA) records, the vehicle with Maryland
tags 23018CK was registered to Black Diamond Sedan LLC, 1600 South Hanover Street,
Baltimore, MD, 21230. Articles of Organization filed in the State of Maryland by Black Diamond
Sedan LLC on February 20, 2015 reflect SARY’s signature as an authorized person; as well as the
signature of others. Further, a Certificate of Reinstatement filed by the business on December 22,

2020 names SARY as the resident agent of the business.

FORENSIC EVIDENCE

| 114, This application seeks permission to locate not only electronic and computer files

that might serve as direct evidence of the crimes described on the warrant, but also for forensic

electronic evidence that establishes how computers and devices containing the files were used, the

purpose of net use, who used them and when. There is probable cause to believe that this forensic

electronic evidence will be on any storage medium found in the TARGET LOCATIONS
described in Attachments A-] through A-5 because:

a. Data on the storage medium can provide evidence of a file that was once on

the storage medium but has since been deleted or edited or of a deleted portion of

a file (such as a paragraph that has been deleted from a word processing file).

Virtual memory paging systems can leave traces of information on the storage

medium that show what tasks and processes were recently active. Web browsers,

e-mail programs, and chat programs store configuration information on the storage

medium that can reveal information such as online nicknames and passwords.
Case 1:23-cr-00344-RDB Document1-1 Filed 04/29/22 Page 28 of 30
1:22-mj-01286-JMC/1:22-mj-01291-JMC

Operating systems can record additional information, such as the attachment of
peripherals, the attachment of USB flash storage devices or other external storage

{ media, and the times the computer was in use. Computer file systems can record
information about the dates files were created and the sequence in which they were
created, although this information can later be falsified.

b. Forensic evidence on a computer or storage medium can also indicate who has used
or controlled the computer or storage medium. This “user attribution” evidence is
analogous to the search for “indicia of occupancy” while executing a search warrant
at a residence. For example, registry information, configuration files, user profiles,
e-mails, e-mail address books, “chat,” instant messaging logs, photographs, the
presence or absence of malware, and correspondence (and the data associated with
the foregoing, such as file creation and last-accessed dates) may be evidence of who

used or controlled the computer or storage medium at a relevant time.

c. A person with appropriate familiarity with how a computer works can, after
examining this forensic evidence in its proper context, draw conclusions about how
computers were used, the purpose of their use, who used them, and when.

d. The process of identifying the exact files, blocks, registry entries, logs, or other
forms of forensic evidence on a storage medium that are necessary to draw an
accurate conclusion is a dynamic process, While it is possible to specify in advance
the records to be sought, computer evidence is not always data that can be merely
reviewed by a review team and passed along to investigators. Whether data stored
on a computer is evidence may depend on other information stored on the computer

and the application of knowledge about how a computer behaves. Therefore,
Case 1:23-cr-00344-RDB Document1-1 Filed 04/29/22 Page 29 of 30

contextual information necessary to understand other evidence also falls within the
scope of the warrant.

e. Further, in finding evidence of how a computer was used, the purpose of its use,

- who used it, and when, sometimes it is necessary to establish that a particular thing

is not present on a storage medium. For example, the presence or absence of

counter-forensic programs or anti-virus programs (and associated data) may be

relevant to establishing the user’s intent.

CONCLUSION

115. Based on your Affiant’s investigation to date, there is probable cause to believe that
evidence, fruits, and instrumentalities of the TARGET OFFENSES are located within the
TARGET LOCATIONS described in Attachments A-1 through A-4. Accordingly, I respectfully
request thdt the Court issue the arrest warrant and warrants to search the locations listed in
Attachments A-1 through A-5 and to seize any items located pursuant to the search as described

in Attachment B
Case 1:23-cr-00344-RDB Documenti-1 Filed 04/29/22 Page 30 of 30

|

116. Further, based on the infonriation in this affidavit, there is probable cause to believe
thift SARY has committed Wire Fraud, in violation of 18 U.S.C. § 1343; Wire Fraud Conspiracy,
in violation of 18 U.S.C. § 1349; arid Money Laundering,in violation of 18 U.S.C. § 1956, between
in or about June 2020 to in or about December 2021 in the District of Maryland. Accordingly, I

respectfully request the Court authorize a Criminal Complaint and Arrest Warrant for SARY.

Respectfully submitted,

Special Agent Daniel S. Parker
' Federal Bureau of Investigation

Affidavit # bmitted by email and attested to me as true and accurate by telephone consistent with
Fed. R. Crim. P, 41 and 41(d)(3) this 28th - of April 2022.

fH CA J. MARK COULSON
UNIIBD STATES MAGISTRATE JUDGE

30.


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