Criminal information — U.S. v. Bakare (PPP/EIDL fraud, D. Md.)

Record facts

U.S. District Court, District of Maryland · No. 8:26-cr-00165-TDC · Doc. 1 · 2026-05-08 · Docket on CourtListener

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Case 8:26-cr-00165-TDC Document1 Filed 05/08/26 Pagei1of8

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(_ FILED ENTERED

LOGGED RECEIVED
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MAY -8 2026
IN THE UNITED STATES DISTRICT COURT ne
FOR THE DISTRICT OF MARYLAND CLERK Le DiStIGT COURT
DISTRICT OF MARYLAND oury

UNITED STATES OF AMERICA

CRIMINALNO. [DC Abot+ \Lo S

v.
SIMEON BAKARE, (Wire Fraud, 18 U.S.C. § 1343;
/k/a “SEMIU BAKARE,” Forfeiture, 18 U.S.C. §§ 981(a)(1)(C),
“mm , 982(a)(2); 21 U.S.C. § 853(p); 28 U.S.C.
Defendant. § 2461(c))
ke RK
INFORMATION
COUNT ONE
(Wire Fraud)

The United States Attorney for the District of Maryland charges that:
Introduction

At times relevant to this Information:

1. Defendant SIMEON BAKARE (“BAKARE”) was a resident of Waldorf,
Maryland.

2. From in or about June 2022 to in or about March 2024, BAKARE was an
information technology auditor, who worked in the Office of Inspector General (“OIG”) for the
U.S. Agency for International Development (“USAID”).

3. From in or about 2018 to in or about May 2021, BAKARE served as a civil servant
auditor with the Defense Contract Audit Agency.

4, From in or about June 2021 to in or about June 2022, BAKARE also served as a

U.S. Department of Defense contractor.

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5. BAKARE maintained a personal account at Bank of America, N.A. (“BOA”), a
federally insured financial institution as defined by 18 U.S.C. § 20, with an account number ending
in 8253 (“BOA 8253”). BAKARE was the sole signatory on BOA 8253.

6. BAKARE owned and controlled The Redeemed Christian Church of God Tree of
Life (““RCCG”).

7. BAKARE maintained a business account at Maryland State Employee Credit
Union (“SECU”), a federally insured financial institution as defined by 18 U.S.C. § 20, with an
account number ending in 1046 (“SECU 1046”). SECU 1046 was registered to RCCG.

8. Person A was a family member of BAKARE.

9. Person A maintained a personal account at Maryland State Employee Credit Union
(“SECU”), a federally insured financial institution as defined by 18 U.S.C. § 20, with an account
number ending in 0326 (“SECU 0326”). Person A was the sole signatory on SECU 0326.

10. The United States Small Business Administration (“SBA”) was a federal
government agency.

11. Cross River Bank was a federally insured financial institution, as defined by 18
U.S.C. § 20, headquartered in Fort Lee, New Jersey. Cross River Bank was a United States Small
Business Administration (“SBA”) Preferred Small Business Lender and participated as a lender in
the Paycheck Protection Program (“PPP”).

12. Capital Plus Financial, LLC (“Capital Plus Financial”) was a financial institution
headquartered in Bedford, Texas. Capital Plus Financial was a SBA Preferred Small Business
Lender and participated as a lender in the PPP.

13. Benworth Capital Partners PR LLC (“Benworth Capital”) was a financial
institution headquartered in Coral Gables, Florida. Benworth Capital was an SBA Preferred Small

Business Lender and participated as a lender in the PPP.

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The Paycheck Protection Program

14. | The PPP was a COVID-19 pandemic relief program administered by the SBA that
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-guaranteed PPP loans
to cover payroll, fixed debts, utilities, rent/mortgage, accounts payable and other bills incurred by
qualifying businesses during, and resulting from, the COVID-19 pandemic. PPP loans were fully
guaranteed by the SBA.

15. 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 to be eligible to obtain the PPP loan, 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 and substantiating that the borrowing business was in
operation before or on February 15, 2020, such as filed federal income tax documents.

16. PPP loan applications were electronically submitted or caused to be submitted by
the borrower and received through SBA servers located outside of the District of Maryland. Once
approved, the business received the PPP loan proceeds via an electronic funds transfer from a
third-party lender to a financial account under the control of the business.

17. The proceeds of a PPP loan could be used for certain specified items, such as payroll
costs, costs related to the continuation of group health care benefits, or mortgage interest payments.
The proceeds of a PPP loan were not permitted to be used by the borrowers to purchase consumer

goods, automobiles, personal residences, clothing, jewelry, to pay the borrower's personal federal

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income taxes, or to fund the borrower’s ordinary day-to-day living expenses unrelated to the
specified authorized expenses.

The COVID-19 Economic Disaster Injury Loan Program

18. In response to the COVID-19 outbreak, the government expanded an existing
disaster-related program—the Economic Injury Disaster Loan (“EIDL”)—to provide loan
assistance (including $10,000 advances) for small businesses and other eligible entities for loans
up to $2 million. The EIDL proceeds could be used to pay fixed debts, payroll, accounts payable,
and other bills. The loan proceeds were not intended to replace lost sale or profits, or for the
expansion of a business.

19.  EIDL funds were issued directly from the United States Treasury. Applicants
applied for EIDL funds directly through the SBA via an online portal and application. The EIDL
application process, which also used certain outside contractors for system support, collected
information concerning the business and the business owner, including information as to the gross
revenues for the 12 months prior to the disaster (January 31, 2020), the cost of goods sold, and
information as to any criminal history of the business owner. Specifically, loans were calculated
based on 6 months of gross revenues minus cost of goods sold. Applicants could also receive a
grant known as an EIDL advance up to $10,000 calculated as a $1,000 grant per employee up to a
maximum of $10,000. Applicants electronically certified that the information provided was true
and accurate and were warned that any false statement or misrepresentation to the SBA, or any
misapplication of the loan proceeds may result in sanctions, including criminal penalties.

20.  EIDL applications were received in and processed using computer servers located
in the states of lowa, Virginia, and Washington. EIDL disbursement payments were initiated by
the SBA using computer servers located in the state of Colorado, which transmitted the payment

information to the Treasury using computer servers located in the state of Virginia.

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THE SCHEME TO DEFRAUD

21. Beginning in or about April 2020 and continuing through in or about November
2021, in the District of Maryland and elsewhere, the defendant,

SIMEON BAKARE,
a/k/a “SEMIU BAKARE,”

did knowingly and willfully devise and intend to devise a scheme and artifice to defraud the SBA
and PPP lenders, including Cross River Bank, Capital Plus Financial, and Benworth Capital, to
obtain money by means of materially false and fraudulent pretenses, representations, and promises,
and for the purpose of executing and attempting to execute the scheme to defraud, did knowingly
and willfully transmit and cause to be transmitted by means of wire communications, in interstate
and foreign commerce, writings, signs, signals, pictures, and sounds, in violation of 18 U.S.C.
§ 1343.

THE OBJECT OF THE SCHEME TO DEFRAUD

22. It was the object of the scheme to defraud for BAKARE to unjustly enrich himself
by unlawfully obtaining PPP and EIDL benefits though materially false and fraudulent pretenses,

representations, and promises.

MANNER AND MEANS OF THE SCHEME TO DEFRAUD

It was part of the scheme to defraud that:

23. BAKARE created and caused to be created materially false, fraudulent, and
fabricated documents to submit in support of his materially fraudulent PPP and EIDL applications.

24. BAKARE submitted and caused the submission of at least five false loan
applications for PPP and EIDL benefits with fraudulent IRS Schedule C Forms and false
attestations regarding the existence of sole proprietorships.

25. | BAKARE had no revenue or income from the businesses claimed on the PPP and

EIDL applications that he caused to be submitted.
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26. BAKARE submitted and caused to be submitted, by interstate wire
communications, materially false, fraudulent, and fabricated documents to the PPP and EIDL
lenders and the SBA to obtain benefits for himself, for Person A, and for RCCG.

27. BAKARE caused the issuance of PPP and EIDL benefits, which were deposited
into bank accounts that BAKARE designated, including BOA 8253, SECU 1046, and SECU
0326, thereby resulting in interstate wire communications that ended in Maryland.

28. It was further part of the scheme to defraud that BAKARE obtained more than
$176,000 through materially false and fraudulent pretenses, representations, and promises.

29. BAKARE unjustly enriched himself by unlawfully obtaining PPP and EIDL
benefits though materially false and fraudulent pretenses, representations, and promises.

THE CHARGE

30.  Onor about July 21, 2020, in the District of Maryland and elsewhere, the defendant,
SIMEON BAKARE,

for the purpose of executing and attempting to execute the scheme and artifice to defraud described

above, did knowingly transmit and cause to be transmitted in interstate commerce by means of a

wire communication, certain signals, signs and sounds, to wit, BAKARE caused the transmission

of $84,900 in EIDL funds to be deposited in SECU 0326, which resulted in an interstate wire from

a location outside of Maryland to Maryland.

18 U.S.C. § 1343

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FORFEITURE ALLEGATION

The U.S. Attorney for the District of Maryland further finds that:

I. Pursuant to Federal Rule of Criminal Procedure 32.2, notice is hereby given to the
defendant that the United States will seek forfeiture as part of any sentence in accordance with 18
U.S.C. §§ 981(a)(1)(C) and 982(a)(2), 21 U.S.C. § 853(p), and 28 U.S.C. § 2461(c), as a result of
the defendant’s conviction under of the offense in Count One of this Information.

Wire Fraud Forfeiture

Ze Upon conviction of any of the alleged offenses set forth in Count One of this
Information, the defendant,

SIMEON BAKARE,
a/k/a “SEMIU BAKARE,”

shall forfeit to the United States, pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c),
and 18 U.S.C. § 982(a)(2), any property, real or personal, which constitutes or is derived from
proceeds traceable to such offenses or any property constituting, or derived from, proceeds
obtained directly or indirectly, as the result of such offenses.
Property Subject to Forfeiture
4, The property to be forfeited includes, but is not limited to, a money judgment in
the total amount of proceeds the defendant obtained as the result of the scheme to defraud and/or

the property involved in the money laundering.

Substitute Assets
5, If any of the property described above, as a result of any act or omission of the
defendants:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
& has been placed beyond the jurisdiction of the court;

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d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be divided
without difficulty,

the United States shall be entitled to forfeiture of substitute property pursuant to 21 U.S.C.
§ 853(p), as incorporated by 18 U.S.C. § 982(b) and 28 U.S.C. § 2461(c).

18 U.S.C. § 981(a)(1)(C)
18 U.S.C. §§ 982(a)(2) and (b)
21 U.S.C. § 853(p)

28 U.S.C. § 2461(c)

Fed. R. Crim. P. 32.2(a)

ally &. HeyorA rm B,

Kelly O. Hayes
United States Attorney

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