Criminal Information — United States v. McIntyre (D.D.C.)

Record facts

U.S. District Court for the District of Columbia · No. 1:25-cr-00157-RC · Doc. 2 · 2025-05-28 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
 
FOR THE DISTRICT OF COLUMBIA 
 
  
 
UNITED STATES OF AMERICA  
      ) 
CRIMINAL NO.  
 
 
 
 
 
 
      ) 
 
 
 
v. 
 
 
 
      ) 
 
      ) 
VIOLATION: 
JEWRAL MCINTYRE, 
 
 
      ) 
 
 
 
 
 
  
      ) 
Count 1: 18 U.S.C. § 1349 
 
          Defendant                                    ) 
(Conspiracy to Commit Bank Fraud) 
 
 
        
INFORMATION 
 
 
The United States Attorney for the District of Columbia charges that: 
 
Background 
 
 
At all times relevant to this Information, on or about the dates and times stated herein: 
 
 The Co-Conspirators 
 
1. 
Defendant Jewral McIntyre was a resident of the State of Florida and the owner 
and operator of Rat Pack Worldwide Security & Consultant.  
2. 
Kelly Winston was a resident of Maryland and employed as an accountant for 
several businesses under the control of Individual 1 that operated in the District of Columbia.  
3. 
Allieu Kamara was a resident of Maryland and operated several businesses in the 
District of Columbia that provide services to the District.   
Relevant Entities 
4. 
Rat Pack Worldwide Security & Consulting (“Rat Pack”), was a security consulting 
business registered as a corporation in Florida on May 11, 2018.  
5. 
Capital Bank, N.A. (“Capital Bank”) is a financial institution insured by the Federal 
Deposit Insurance Corporation.  
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The Small Business Administration 
6. 
The United States Small Business Administration (“SBA”) was an executive 
branch agency of the United States government that provided support to entrepreneurs and small 
businesses. The mission of the SBA was to maintain and strengthen the nation’s economy by 
enabling the establishment and viability of small businesses and by assisting in the economic 
recovery of communities after disasters.  
The Paycheck Protection Program 
7. 
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 suffering the economic effects caused by the COVID-19 pandemic.  One 
source of relief provided by the CARES Act was the authorization of billions in forgivable loans 
to small businesses for job retention and certain other expenses, through a program referred to as 
the Paycheck Protection Program (“PPP”).   
8. 
In order to obtain a PPP loan, a qualifying business must have submitted a PPP loan 
application, which is signed by an authorized representative of the business.  The applicant of a 
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 were used to calculate the amount of money the small business is 
eligible to receive under the PPP.  In addition, businesses applying for a PPP loan must have 
provided documentation showing their payroll expenses.  To qualify for eligibility, businesses that 
applied for a PPP loan needed to be in operation as of February 15, 2020. 
9. 
A PPP loan application must have been processed by a participating financial 
institution (the lender).  If a PPP loan application was approved, the participating financial 
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institution funds the PPP loan using its own monies, which are 100% guaranteed by the SBA.  Data 
from the 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 must have been used by the business for certain permissible 
expenses—payroll costs, interest on mortgages, rent, and utilities.  The PPP allowed 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.   
11. 
On December 27, 2020, the Economic Aid to Hard-Hit Small Business, Nonprofits 
and Venues Act provided additional funding for the PPP and extended the application deadline to 
March 31, 2021. The act enables 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 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 vandalism 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. 
12. 
On March 25, 2021, the PPP Extension Act of 2021 extended the application 
deadline from March 31, 2021, to May 31, 2021. In addition to extending the PPP application 
filing window by 60 days, the Extension Act provided an extra 30 days for the SBA to finish 
processing applications received by the May 31, 2021, deadline.    
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COUNT 1 
(18 U.S.C. § 1349 – Conspiracy to Commit Bank Fraud) 
13. 
Paragraphs 1 through 12 are hereby realleged. 
14. 
Between on or about January 13, 2021 and on or about August 22, 2022, in the 
District of Columbia and elsewhere, the defendant, 
JEWRAL MCINTYRE, 
 
Winston, Kamara, and other did knowingly conspire, combine, confederate, and agree to commit 
bank fraud, by executing and attempting to execute a scheme and artifice to obtain moneys, funds, 
credits, assets, securities, and other property owned by, and under the custody and control of a 
federally insured financial institution, by means of false and fraudulent pretenses, representations, 
and promises. 
Purpose of the Conspiracy 
15. 
It was the purpose of the conspiracy for MCINTYRE, Winston, Kamara and other 
co-conspirators to enrich themselves, and each other, by obtaining PPP loans under false and 
fraudulent pretenses, and to spend the fraudulently obtained money, in part, for their own benefit 
and enjoyment. 
Manner and Means of the Scheme to Defraud 
16. 
It was part of the scheme to defraud that: 
17. 
Kamara contacted business owners, including McIntyre, to inquire about their 
interest in applying for a PPP loan for which Winston would prepare the loan application – 
irrespective of the business’s eligibility and without collecting from the business owners the 
supporting documents or information, such as accurate payroll data, necessary to support their 
applications.   
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18. 
 Kamara directed Winston to prepare PPP loan applications for the business so 
identified, which Winston did for, among others, Rat Pack.   
19. 
As Kamara was aware, Winston intentionally prepared the PPP loan applications 
to seek amounts higher than the loan amounts for which the businesses might have qualified.  To 
do so, Winston included false and misleading information in the applications.  
20. 
Winston prepared phony federal tax forms and payroll records to support the 
fraudulent PPP loan applications. 
21. 
Winston and Kamara provided the fraudulent applications and supporting 
documents to businesses owners, including McIntyre, who each submitted the fraudulent 
applications and supporting documents to a financial institution supporting the PPP loan program.  
As a result, the financial institutions approved and disbursed the requested PPP loans.  
22. 
After fraudulently obtaining the PPP loans, the business owners, including 
McIntyre, kicked back a percentage of the loan proceeds to Kamara, who in-turn split the money 
with Winston.  
23. 
Kamara used the loan proceeds kicked back to him for his own personal 
enrichment.   
24. 
Winston, acting at Kamara’s direction, also prepared PPP loan forgiveness 
applications for the businesses for which she had prepared the fraudulent PPP loan applications.   
25. 
Winston provided the PPP loan forgiveness applications to the business owners, 
including McIntyre, who submitted them to the applicable financial institution to seek and obtain 
loan forgiveness.  
Execution of the Conspiracy with Regard to Rat Pack  
26. 
In January 2021, Kamara approached McIntyre to ask if he wanted to apply, with 
Kamara’s assistance, for a PPP loan in the name of Rat Pack.  
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27. 
 Kamara and McIntyre agreed that Kamara would receive a portion of the PPP 
funds if the loan application was approved and funded.     
28. 
In January 2021, McIntyre provided Kamara with basic information for Rat Pack, 
including its business license, Internal Revenue Service Employer Identification Number, and the 
Articles of Incorporation. At Kamara’s request, Winston then created a PPP loan application for 
Rat Pack containing materially false statements, including that Rat Pack had 18 employees and an 
average monthly payroll of $103,192.35, when in fact it had no W2 employees and payroll that 
was a fraction of the amount claimed.  In addition, Winston created false and fraudulent supporting 
documents to submit with the loan application, including: false financial payroll reports for 2020 
and false Employer’s Quarterly Federal Tax Return (Forms 941), for each quarter of 2020. All of 
these documents were provided through an online portal to Capital Bank.  
29. 
On March 4, 2021, McIntyre e-signed the PPP loan application and it was 
submitted to Capital Bank. The PPP loan application sought a $257,980.87 loan.  McIntyre 
understood that the application and supporting documentation given to him by Kamara had been 
prepared by Winston, even though neither Kamara, nor Winston, requested, or received any payroll 
information that would be necessary to submit a complete and accurate PPP loan application for 
Rat Pack.  
30. 
On March 12, 2021, the SBA and Capital Bank approved McIntyre’s fraudulent 
PPP loan application and funded the loan in amount of $257,980.87. 
31. 
On March 12, 2021, the SBA and Capital Bank deposited $257,980.87 into Rat 
Pack’s Capital Bank account ending in -8196.  
32. 
On March 16, 2021, and March 22, 2021, McIntyre wired from Rat Pack’s Capital 
Bank account ending in -8196 $175,000 and $75,000, respectively, to Rat Pack’s JP Morgan Chase 
Bank (“JPMC”) account ending in -6935. 
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33. 
On March 23, 2021, McIntyre wired $30,000 from Rat Pack’s JPMC account 
ending in -6935 to Kamara’s account at Bank of America, N.A. (“BOA”) ending in -5772. 
34. 
On July 20, 2022, McIntyre forwarded Kamara an email containing a link to 
Capital Bank’s PPP loan forgiveness application for Rat Pack.  
35. 
At the behest of Kamara, Winston prepared a loan forgiveness application for Rat 
Pack. The application falsely claimed that Rat Pack had 18 employees at the time McIntyre 
received the PPP loan. The application also falsely claimed that, for the period of March 12, 2021, 
through May 14, 2021, Rat Pack spent the full amount of the loan, $257,980.87, on payroll costs.  
36. 
On August 8, 2022, McIntyre e-signed and submitted the loan forgiveness 
application.  
37. 
As a result of the false loan forgiveness application, submission and supporting 
documentation, Capital Bank and the SBA forgave Rat Pack’s PPP loan.  
(All in violation of Title 18, United States Code, Section 1349) 
NOTICE OF FORFEITURE 
The allegations contained in Count One of this Information are hereby realleged and 
incorporated by reference for the purpose of alleging forfeitures pursuant to Title 18, United States 
Code, Sections 982(a)(2)(A). 
Upon conviction of the offense of conspiracy to commit bank fraud in violation of Title 
18, United States Code, Section 1349, Defendant, 
JEWRAL MCINTYRE, 
 
shall forfeit to the United States of America, pursuant to Title 18, United States Code, Section 
982(a)(2)(A), any property constituting, or derived from, proceeds obtained, directly or indirectly, 
as a result of such violation.  
 
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MONEY JUDGMENT 
 
In the event of conviction, the United States may seek a money judgment. 
SUBSTITUTE ASSETS 
 
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, 
the United States of America shall be entitled to forfeiture of substitute property pursuant to Title 
21, United States Code, Section 853(p), as incorporated by Title 28, United States Code, Section 
2461(c). 
All pursuant to 18 U.S.C. ' 981(a)(1)(C) and 28 U.S.C. ' 2461(c). 
 
Respectfully submitted, 
 
 
 
 
 
 
 
JEANINE FERRIS PIRRO  
 
 
 
 
 
 
UNITED STATES ATTORNEY 
 
 
 
 
 
 
 
 
 
 
 
 
By: 
_/s/ Joshua Gold_________________ 
 
 
 
 
 
 
Joshua Gold 
 
 
 
 
 
 
Assistant United States Attorney 
 
 
 
 
 
 
Texas Bar No. 24103101 
 
 
 
 
 
 
601 D Street, N.W. 
 
 
 
 
 
 
Washington, D.C. 20530 
 
 
 
 
 
 
(202) 815-8965 
 
 
 
 
 
 
Joshua.Gold@usdoj.gov 
 
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