Criminal Information — United States v. Hashim Campbell

Record facts

U.S. District Court, Eastern District of New York · No. 1:21-cr-00478-FB · Doc. 6 · 2021-09-23 · Docket on CourtListener

Full text

DCP:JN 
F. #2020R00955
UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF NEW YORK 
- - - - - - - - - - - - - - - - - - - - - - - - - - - X
UNITED STATES OF AMERICA 
- against -
HASHIM CAMPBELL, 
Defendant.
- - - - - - - - - - - - - - - - - - - - - - - - - - - X
I N F O R M A T I O N
Cr. No. 21-CR-478 (FB) 
(T. 18, U.S.C., §§ 982(a)(2), 982(b)(1), 
1349 and 3551 et seq.; T. 21, U.S.C., 
§ 853(p))
THE UNITED STATES CHARGES: 
INTRODUCTION 
At all times relevant to this Information, unless otherwise indicated: 
I.
The Defendant and Relevant Individuals and Entities
1.
The defendant HASHIM CAMPBELL was a resident of New York, New
York. 
2.
In or about and between 2015 and the date of this Information, Expert Tax
Services (“Expert Tax”) was a business in New York, New York, which was owned and operated 
by the defendant HASHIM CAMPBELL and members of his family.  Expert Tax specialized in 
income tax return preparation and filing. 
3.
In or about and between 2016 and the date of this Information, Apex
Accounting & Tax Inc. (“Apex”) was a business owned and operated by the defendant HASHIM 
CAMPBELL in Brooklyn, New York.  Apex specialized in income tax preparation and filing. 
4.
Bank 1, an entity the identity of which is known to the United States, was a
federally insured financial institution with branches across the United States, including in the 
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Eastern District of New York.  Bank 1 operated a branch located in New York, New York (the 
“Bank 1 Branch New York”). 
5. 
Co-Conspirator 1 (“CC-1”), Co-Conspirator 2 (“CC-2”) and Co-Conspirator 
3 (“CC-3”), individuals whose identities are known to the United States, were employees of Bank 
1 and worked at the Bank 1 Branch New York (the “Bank 1 Co-Conspirators”). 
II. 
The Paycheck Protection Program 
 
6. 
The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was a 
federal law enacted in or about March 2020, which was designed to provide emergency financial 
assistance to the millions of Americans who were suffering the economic effects of the COVID-19 
pandemic.  One source of relief provided by the CARES Act was the authorization of up to $349 
billion in forgivable loans to small businesses for job retention and certain other expenses through 
a program referred to as the Paycheck Protection Program (“PPP”).  In or about April 2020, 
Congress authorized over $300 billion in additional PPP funding. 
7. 
To obtain a PPP loan, a qualifying business was required to submit a PPP 
loan application 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 
to make certain affirmative certifications in order to be eligible to obtain the PPP loan.  In the PPP 
loan application, the small business (through its authorized representative) was required to state, 
among other things, its: (a) average monthly payroll expenses, and (b) number of employees.  
These figures were used to calculate the amount of money the small business was eligible to 
receive under the PPP.  In addition, businesses applying for a PPP loan were required to provide 
documentation showing their payroll expenses.  
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8. 
The PPP was overseen by the Small Business Administration (“SBA”), 
which was headquartered in Washington, D.C., and had authority over all PPP loans.  Individual 
PPP loans, however, were issued by approved private lenders such as participating financial 
institutions and credit unions (the “Lenders”).  The Lenders received and processed PPP 
applications and supporting documentation and made loans using the Lenders’ own funds. 
9. 
Upon approval of a PPP loan application, the Lender funded the PPP loan, 
which was 100 percent guaranteed by the SBA.  Data from the PPP loan application, including 
information about the borrower, the total amount of the loan and the listed number of employees, 
was transmitted by the Lender to the SBA in the course of processing the loan.   
10. 
PPP loan proceeds were permitted to be used by a borrower on specified 
expenses, such as payroll costs, interest on mortgages, rent and utilities.  The PPP allowed the 
interest and principal on a PPP loan to be entirely forgiven if the borrower spent the loan proceeds 
on the enumerated expenses within a designated period of time and used a certain amount of the 
PPP loan proceeds on payroll expenses. 
III. 
The Fraudulent Scheme 
 
A. 
Overview 
 
11. 
Following the enactment of the CARES Act, the defendant HASHIM 
CAMPBELL and the Bank 1 Co-Conspirators, together with others, orchestrated a scheme to 
submit fraudulent PPP loan applications on behalf of Bank 1 customers who did not legitimately 
qualify for loans under the PPP program in exchange for “commissions” taken from the loan 
proceeds.  
12. 
The defendant HASHIM CAMPBELL and the Bank 1 Co-Conspirators, 
together with others, submitted and caused to be submitted to Bank 1 on behalf of borrowers 
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numerous PPP loan applications that contained materially false representations.  CAMPBELL and 
the Bank 1 Co-Conspirators also obtained falsified tax documents, which were provided as support 
for the fraudulent PPP loan applications.  Some of the PPP applicants resided in Brooklyn, New 
York and withdrew their fraudulent PPP loan proceeds at ATM locations in the Eastern District of 
New York.  In addition, CAMPBELL and the Bank 1 Co-Conspirators obtained fraudulent PPP 
loans for CAMPBELL’s family members and friends.  
B. 
The Fraudulent PPP Loans 
13. 
The Bank 1 Co-Conspirators worked with a network of recruiters to identify 
borrowers to fraudulently apply for PPP loans.  The borrowers identified by the recruiters were 
either existing Bank 1 customers or became Bank 1 customers after they were recruited.  In 
exchange for their assistance, the Bank 1 Co-Conspirators gave the recruiters “commissions” from 
the PPP loan proceeds.  The Bank 1 Co-Conspirators enlisted two tax preparers, including the 
defendant HASHIM CAMPBELL, to aid applicants and the Bank 1 Co-Conspirators in the 
preparation of the fraudulent PPP loan applications and to falsify tax documents submitted with 
those applications.   
14. 
Under PPP loan program rules, borrowers generally were eligible to receive 
loans of up to 2.5 times their businesses’ average monthly payroll.  The defendant HASHIM 
CAMPBELL worked with the Bank 1 Co-Conspirators to maximize the loan amount for each 
borrower whose business loan documents he helped prepare, including by providing false 
documents in support of the PPP applications.  CAMPBELL provided borrowers with false 
Internal Revenue Service (“IRS”) Form W-2s (reporting wages paid to employees) prepared by his 
tax preparation businesses, Expert Tax and Apex, to support the fraudulent PPP loan applications.  
CAMPBELL also helped borrowers inflate financial figures in the PPP loan applications.  In 
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exchange for helping applicants submit the fraudulent PPP loan applications, CAMPBELL 
charged his customers a ten percent fee from the loan proceeds.     
15. 
For example, in or about and between March 2020 and August 2020, the 
defendant HASHIM CAMPBELL assisted Individual-1, an individual whose identity is known to 
the United States, and other borrowers Individual-1 referred to CAMPBELL, in submitting 
fraudulent applications for PPP loans.  Specifically, CAMPBELL created fraudulent income tax 
returns for Individual-1 and the referred borrowers.  Individual-1 and the referred borrowers 
submitted the fraudulent tax documents along with their PPP applications and obtained PPP loans 
to which they were not entitled.   
16. 
In or about and between March 2020 and August 2020, the defendant 
HASHIM CAMPBELL assisted several family members and friends in submitting fraudulent 
applications for PPP loans.  CAMPBELL also created fraudulent income tax returns for his family 
members and friends, which they submitted with their PPP applications to obtain fraudulent loans.  
With CAMPBELL’s assistance, his family and friends obtain approximately $200,000 in 
fraudulent PPP loans.    
17. 
In total, in or about and between March 2020 and August 2020, the 
defendant HASHIM CAMPBELL, together with others, fraudulently obtained PPP loans for New 
York-based businesses in an amount exceeding one million dollars.  These loans were fully 
funded based on fraudulent information provided in the PPP loan applications.  CAMPBELL 
personally obtained nearly $100,000 in “commissions” from the PPP loan proceeds.  CAMPBELL 
was ineligible to receive any commissions from the PPP loan proceeds per the terms of the 
program.  
 
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CONSPIRACY TO COMMIT WIRE FRAUD AND BANK FRAUD 
18. 
The allegations contained in paragraphs one through 17 are realleged and 
incorporated as if fully set forth in this paragraph.  
19. 
In or about and between March 2020 and August 2020, both dates being 
approximate and inclusive, within the Eastern District of New York and elsewhere, the defendant 
HASHIM CAMPBELL, together with others, did knowingly and intentionally conspire to execute 
a scheme and artifice, to wit: 
(a) 
to defraud and to obtain money and property from Bank 1 and the 
SBA by means of one or more materially false and fraudulent pretenses, representations and 
promises, and to transmit and cause to be transmitted by means of wire communications in 
interstate commerce, writings, signs, signals, pictures and sounds, for the purpose of executing the 
scheme to defraud, contrary to Title 18, United States Code, Section 1343; and 
(b) 
to defraud Bank 1, a financial institution, and to obtain money, 
funds, credits and other property owned by and under the custody and control of Bank 1, by means 
of one or more materially false and fraudulent pretenses, representations and promises, contrary to 
Title 18, United States Code, Section 1344. 
(Title 18, United States Code, Sections 1349 and 3551 et seq.) 
CRIMINAL FORFEITURE ALLEGATION 
 
20. 
The United States hereby gives notice to the defendant that, upon his 
conviction of the offense charged herein, the government will seek forfeiture in accordance with 
Title 18, United States Code, Section 982(a)(2), which requires any person convicted of such 
offense to forfeit any property constituting, or derived from, proceeds obtained directly or 
indirectly as a result of such offense.  
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21. 
If any of the above-described forfeitable property, 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; 
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), as 
incorporated by Title 18, United States Code, Section 982(b)(1), to seek forfeiture of any other 
property of the defendant up to the value of the forfeitable property described in this forfeiture 
allegation. 
(Title 18, United States Code, Sections 982(a)(2) and 982(b)(1); Title 21, United 
States Code, Section 853(p)) 
 
 
 
__________________________________ 
JACQUELYN M. KASULIS 
ACTING UNITED STATES ATTORNEY 
EASTERN DISTRICT OF NEW YORK 
 
 
 
 
 
____________________________________ 
JOSEPH S. BEEMSTERBOER  
ACTING CHIEF 
CRIMINAL DIVISION, FRAUD SECTION 
U.S. DEPARTMENT OF JUSTICE 
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F.#: 2020R00955 
FORM DBD-34 
No.  
JUN. 85                        
UNITED STATES DISTRICT COURT 
 
EASTERN District of NEW YORK 
 
CRIMINAL DIVISION 
 
THE UNITED STATES OF AMERICA 
 
vs. 
 
HASHIM CAMPBEEL, 
 
 
Defendant. 
INFORMATION 
(T. 18, U.S.C., §§ 982(a)(2), 982(b)(1), 1349 and 3551 et seq.; T. 21, U.S.C., § 
853(p)) 
A true bill.  
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 
 
Foreperson 
 
 
Filed in open court this _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ day, 
 
of  _ _ _ _ _ _ _ _ _ _ _ _  A.D. 20 _ _ _ _ _  
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _  
 
Clerk 
 
 
Bail, $ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _  
 
Julia Nestor and Chand Edwards-Balfour, Assistant U.S. Attorneys 
(718) 254-6297/6238 
Michael McCarthy, Trial Attorney (202) 305-3995 
Case 1:21-cr-00478-FB     Document 6     Filed 09/23/21     Page 8 of 8 PageID #: 25

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