Criminal Complaint — U.S. v. Mohan

Record facts

U.S. District Court, W.D. Wash., Seattle · No. 2:20-mj-00451-BAT · Doc. 1 · 2020-07-21 · Docket on CourtListener

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COMPLAINT/United States v. Mukund Mohan - 1 
UNITED STATES ATTORNEY 
700 STEWART STREET, STE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
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Chief Magistrate Judge Brian A. Tsuchida 
UNITED STATES DISTRICT COURT FOR THE 
WESTERN DISTRICT OF WASHINGTON 
AT SEATTLE 
UNITED STATES OF AMERICA, 
Plaintiff 
v. 
MUKUND MOHAN, 
       Defendant. 
CASE NO. 
COMPLAINT for VIOLATIONS OF 
Title 18, United States Code, Sections 2, 
1343, & 1957(a) 
BEFORE, Chief Magistrate Judge Brian A. Tsuchida, United States Magistrate 
Judge, U. S. Courthouse, Seattle, Washington. 
The undersigned complainant being duly sworn states: 
COUNT ONE 
(Wire Fraud) 
From in or around April 2020 through in or around June 2020, at Seattle, in the 
Western District of Washington and elsewhere, MUKUND MOHAN, the defendant, 
knowingly devised and intended to devise a scheme and artifice to defraud the United 
States, and to obtain money and property by means of false and fraudulent pretenses, 
representations and promises, and attempted to do so. 
A. Manner and Means
1.
It was part of the scheme that MOHAN submitted fraudulent loan
MJ20-451
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COMPLAINT/United States v. Mukund Mohan - 2 
UNITED STATES ATTORNEY 
700 STEWART STREET, STE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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applications to Financial Institutions 1, 2, 3 and 4, seeking millions of dollars in funds 
through the Paycheck Protection Program (“PPP”), on behalf of Zuput Inc. (“Zuput”), 
Zigantic LLC (“Zigantic”), GitGrow Inc. (“GitGrow”), Vangal Inc. (“Vangal”), and Expect 
Success Inc. (“Expect Success”). 
2. 
It was further part of the scheme to defraud that MOHAN submitted a 
fraudulent loan application to Financial Institution 5, seeking approximately $431,250 in 
funds through the PPP on behalf of Mahenjo Inc. (“Mahenjo”). 
3. 
In support of Mahenjo’s fraudulent loan application, MOHAN made 
numerous false and misleading statements, including, but not limited to: 
a. 
That, on February 15, 2020, Mahenjo was in operation and had 
employees for whom it paid salaries and payroll taxes or paid independent contractors; 
b. 
That, in 2019, its payroll expenses were more than $2.3 million; 
c. 
That Mahenjo’s average monthly payroll expenses were at least 
$172,250; and  
d. 
That Mahenjo’s owner, MOHAN, was not the owner of any other 
business and did not manage any other business. 
4. 
In further support of Mahenjo’s fraudulent loan application, MOHAN 
submitted fake and altered documents, including fake federal tax filings and altered 
incorporation documents. 
B. Execution 
On or about June 4, 2020, at Clyde Hill, in the Western District of Washington and 
elsewhere, MOHAN, for the purpose of executing the scheme described above transmitted 
and caused to be transmitted by means of wire, radio, and television communication in 
interstate and foreign commerce, writings, signs, signals, pictures, and sounds for the 
purpose of executing such scheme and artifice, to wit, an interstate wire from the State of 
Washington to the State of California as part of the Fedwire transfer in the amount of 
$431,250 from Financial Institution 5’s bank account to Mahenjo’s JP Morgan Chase 
(“JPMC”) bank account. 
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COMPLAINT/United States v. Mukund Mohan - 3 
UNITED STATES ATTORNEY 
700 STEWART STREET, STE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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All in violation of Title 18, United States Code, Sections 1343 and 2. 
COUNT TWO 
(Money Laundering) 
On or around May 26, 2020, at Clyde Hill, and elsewhere, in the Western District 
of Washington, MOHAN did knowingly cause and engage in, and attempt to cause and 
engage in, the following monetary transaction by, through, and to a financial institution, 
affecting interstate commerce, in criminally derived property of a value greater than 
$10,000, that is, the transfer of $50,000 from Zigantic’s bank account at Azlo Business 
Inc. (“Azlo”) with account number ending in 3419 to MOHAN’s personal brokerage 
account at Robinhood with account number ending in 4609, such property having been 
derived from a specified unlawful activity, namely, wire fraud in violation of Title 18, 
United States Code, Section 1343, and bank fraud in violation of Title 18, United States 
Code, Section 1344(2). 
All in violation of Title 18, United States Code, Sections 1957(a) and 2. 
And the complainant states that this Complaint is based on the following 
information: 
I, JAMES SHIELDS, being first duly sworn on oath, depose and say: 
1. 
I am a Senior Special Agent with the Federal Housing Finance Agency – 
Office of Inspector General (“FHFA-OIG”).  I have been employed as a Senior 
Special Agent of the FHFA-OIG since January 2013.   I have received basic federal law 
enforcement training, including at the Federal Law Enforcement Training Center, as well 
as other specialized federal law enforcement training.  I currently hold Certified Fraud 
Examiner and Accredited Mortgage Professional certifications.  I have investigated 
violations of federal statutes, including wire fraud, mail fraud, bank fraud, money 
laundering, and theft of government and public money.  I have been a sworn law 
enforcement officer during all times herein. 
2. 
The information contained in this Complaint is the result of my own 
investigation as well as information provided to me by others, including other investigators 
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COMPLAINT/United States v. Mukund Mohan - 4 
UNITED STATES ATTORNEY 
700 STEWART STREET, STE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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and law enforcement officers.  In each instance when I recite information from such others, 
I have gained that information either by talking directly to such investigators and law 
enforcement officers or reviewing written reports of their investigation, or both.  This 
Complaint accurately summarizes some of the evidence I discovered during my 
investigation; it does not, however, contain every detail known to me about the 
investigation. 
FACTS ESTABLISHING PROBABLE CAUSE 
The Paycheck Protection Program 
3. 
The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act is 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 up to $349 billion in forgivable loans to small businesses for job retention 
and certain other expenses, through a program referred to as the PPP.  In or around April 
2020, Congress authorized over $300 billion in additional PPP funding. 
4. 
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 PPP loan 
application requires the business (through its authorized representative) 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 small business (through its authorized 
representative) 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 receive under the PPP.  In addition, businesses applying 
for a PPP loan must provide documentation showing their payroll expenses.   
5. 
A PPP loan application must be processed by a participating lender, such 
as a financial institution.  If a PPP loan application is approved, the participating lender 
funds the PPP loan using its own monies, which are 100% guaranteed by Small Business 
Administration (SBA).  Data from the application, including information about the 
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COMPLAINT/United States v. Mukund Mohan - 5 
UNITED STATES ATTORNEY 
700 STEWART STREET, STE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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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.    
6. 
PPP loan proceeds may only be used by the business on 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. 
MUKUND MOHAN 
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MUKUND MOHAN is a United States citizen residing in Clyde Hill, 
Washington.  MOHAN is the Chief Technology Officer at BuildDirect.  Based on his social 
media presence, MOHAN also purports to be a successful serial entrepreneur focused on 
tech startups.  
Fraudulent PPP Loan Applications Submitted  
on Behalf of Zuput, Zigantic, GitGrow, Vangal, and Expect Success 
 
8. 
As described further below, evidence gathered in the investigation 
demonstrates that, from in or around April 2020 through in or around June 2020, MOHAN 
submitted, or caused to be submitted, eight fraudulent loan applications to five different 
financial institutions in order to obtain funds through the PPP.     
9. 
The first seven of the eight fraudulent PPP loan applications are 
summarized in the following chart: 
Applicant 
Amount 
Sought 
Lender 
Approx.        
Date of 
Application 
Status 
Zuput Inc. 
$150,000 
Financial Institution 1 April 26, 2020 
Approved 
Zuput Inc. 
$223,727 
Financial Institution 2 May 1, 2020 
Canceled 
Zigantic LLC $ 304,830 
Financial Institution 2 May 1, 2020 
Approved 
GitGrow Inc. 
$506,277 
Financial Institution 2 May 2, 2020 
Approved 
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COMPLAINT/United States v. Mukund Mohan - 6 
UNITED STATES ATTORNEY 
700 STEWART STREET, STE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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Vangal Inc. 
$1,728,398 Financial Institution 2 May 5, 2020 
Withdrawn 
Expect 
Success Inc. 
$1,794,700 Financial Institution 3 May 5, 2020 
Canceled 
Expect 
Success Inc. 
$394,000 
Financial Institution 4 May 7, 2020 
Approved 
 
10. 
Based on the investigation, Financial Institutions 1 through 4 are federally 
insured financial institutions, members of the Federal Home Loan Bank System, and have 
participated as lenders in the PPP.    
11. 
According to records obtained from Financial Institutions 1 through 4, 
MOHAN represented that he is the Founder and/or Chief Executive Officer of Zuput, 
GitGrow, Vangal, and Expect Success, and that his wife is the Founder of Zigantic. 
12. 
According to records obtained by Financial Institutions 1 through 4, 
MOHAN also represented that Zuput, Zigantic, and GitGrow had the same business 
address (“Address 1”), and that Vangal and Expect Success had the same business address 
(“Address 2”).  Address 1 and Address 2 are in Clyde Hill, Washington.  Based on records 
obtained from mortgage lenders, records obtained from Financial Institutions 1 through 4, 
open source research, and surveillance conducted by federal agents, Address 1 and Address 
2 are adjacent residential properties, not commercial properties with office space.  In fact, 
MOHAN currently resides at Address 1 with his family.  MOHAN previously resided at 
Address 2. 
13. 
MOHAN represented to Financial Institution 2 that Zuput had filed a Form 
940, Employer’s Annual Federal Unemployment Tax Return, with the Internal Revenue 
Service (“IRS”) in 2019, but MOHAN did not actually submit a copy in support of that 
loan application because it was ultimately canceled.  MOHAN submitted, or caused to be 
submitted, a Form 940 with each of the six other PPP loan applications.  A review of IRS 
records revealed these Forms 940 to be fake:  none of the returns had been filed with the 
IRS and the amounts of tax deposits reported on these Forms 940 were not paid to the IRS. 
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COMPLAINT/United States v. Mukund Mohan - 7 
UNITED STATES ATTORNEY 
700 STEWART STREET, STE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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14. 
These seven PPP loan applications also contained materially false and 
misleading statements, including, but not limited to, that, on February 15, 2020, each 
applicant was in operation and had employees for whom it paid salaries and payroll taxes 
or paid independent contractors:   
a. As explained above, a review of IRS records revealed that these applicants 
did not pay federal payroll taxes as of February 15, 2020.   
b. A review of Washington State Employment Security Department (“ESD”) 
records revealed that there is no record of these applicants having paid any 
employee wages or payroll taxes.         
c. In addition, records obtained from the Washington State Department of 
Revenue (“DoR”) revealed that none of these applicants had registered with 
DoR or applied for a business license, with the exception of Zuput.   
d. In the case of Zuput, MOHAN registered and applied for a business license 
on or about April 26, 2020, which is on or about the same date MOHAN 
submitted Zuput’s PPP loan application to Financial Institution 1.  The 
information MOHAN provided in Zuput’s business license application to 
DoR, however, was inconsistent with that which he provided in Zuput’s 
PPP loan application that same day.  MOHAN told Financial Institution 1 
that Zuput hired its first employee in April 2017 and that, by September 
2019, Zuput had hired 24 additional employees; MOHAN told DoR that 
Zuput hired its first employee in October 2019 and first paid that employee 
wages in November 2019. 
Fraudulent PPP Loan Application Submitted on Behalf of Mahenjo 
15. 
Evidence gathered in the investigation demonstrates that, in addition to the 
seven fraudulent loan applications described above, MOHAN submitted an eighth 
fraudulent PPP loan application. 
16. 
According to an employee of Wyoming Corporate Services, Inc. (“WCS”) 
(“WCS Employee 1”), whom I interviewed in June 2020, WCS was in the business of 
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COMPLAINT/United States v. Mukund Mohan - 8 
UNITED STATES ATTORNEY 
700 STEWART STREET, STE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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incorporating and selling corporate entities.  WCS incorporated corporate entities and then 
placed them on a shelf to “age” because “shelf companies” or “aged corporations” are more 
valuable and WCS can sell them for more money.  Mahenjo was one of these shelf 
companies or aged corporations. 
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According to WCS Employee 1,  and as corroborated by contemporaneous 
records obtained from WCS, on or about December 28, 2017, Harvard Business Services, 
Inc. (“HBS”) incorporated a company named Mahenjo and appointed an individual with 
the initials SKD as Mahenjo’s initial director.   In or about December 2018, SKD sold 
Mahenjo to WCS.  WCS later marketed it for sale on the Internet as an aged company.  On 
or about May 22, 2020, an individual who identified himself as MOHAN, purchased 
Mahenjo from WCS on the Internet.   
18. 
According to WCS Employee 1, Mahenjo was a “shelf company” that did 
not have business activities or employees from December 2018 (when WCS purchased 
Mahenjo from SKD) through at least May 22, 2020 (when MOHAN purchased Mahenjo 
from WCS).   
19. 
According to records obtained from Financial Institution 5, on June 3, 
2020, MOHAN applied to Financial Institution 5 for a PPP loan on behalf of Mahenjo for 
$431,250.   
20. 
Financial Institution 5 is a federally insured financial institution, a member 
of the Federal Home Loan Bank System, and has participated as a lender in the PPP.    
21. 
Based on records obtained from Financial Institution 5, MOHAN 
completed and signed a PPP Borrower Application Form on behalf of Mahenjo.  The PPP 
Borrower Application Form represented that Mahenjo had 24 employees, that its average 
monthly payroll was $172,500, and that the purpose of the PPP loan was to cover its 
payroll.  MOHAN represented that Mahenjo’s offices were located at Address 2.     
22. 
MOHAN made several certifications, including that Mahenjo “was in 
operation on February 15, 2020 and had employees for whom it paid salaries and payroll 
taxes or paid independent contractors.”  
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COMPLAINT/United States v. Mukund Mohan - 9 
UNITED STATES ATTORNEY 
700 STEWART STREET, STE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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MOHAN was also asked, “Is the Applicant or any owner of the Applicant 
an owner of any other business, or have common management with, any other business? If 
yes, list all such businesses and describe the relationship on a separate sheet identified as 
addendum A.”  MOHAN responded “No.” 
24. 
Based on records obtained from Financial Institution 5, MOHAN submitted 
several documents in support of Mahenjo’s PPP loan application, including:   
a. IRS Form 940 for 2019, in which he represented that Mahenjo had paid 
$2,376,500 to its employees in 2019.  MOHAN signed the form and dated 
his signature March 29, 2020 (which is nearly two months before MOHAN 
purchased Mahenjo from WCS). 
b. Two payroll reports for the date range February 1, 2020 through February 
29, 2020, in which he represented that Mahenjo had 24 employees and that 
its annual payroll expense was $188,291.67.  The payroll reports were 
purportedly created on March 12, 2020 (which is over two months before 
MOHAN purchased Mahenjo from WCS). 
c. A copy of Mahenjo’s purported incorporation documents. The version 
MOHAN submitted to Financial Institution 5 stated that Mahenjo was 
incorporated on December 28, 2017 and that, at the time it was incorporated, 
HBS appointed MOHAN as Mahenjo’s initial director. 
d. A letter from HBS to MOHAN purporting to notify MOHAN of Mahenjo’s 
EIN.  The letter is dated February 12, 2018 (which is over two years before 
he purchased Mahenjo from WCS). 
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MOHAN falsely certified that Mahenjo “was in operation on February 15, 
2020 and had employees for whom it paid salaries and payroll taxes or paid independent 
contractors.”  As explained above, Mahenjo was a “shelf company” and did not have 
business activities or employees from at least December 2018 (when WCS purchased the 
company from SKD) through at least May 22, 2020 (when MOHAN purchased the 
company online from WCS).   
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COMPLAINT/United States v. Mukund Mohan - 10 
UNITED STATES ATTORNEY 
700 STEWART STREET, STE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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26. 
MOHAN’s statements that: (i) in 2019, Mahenjo’s payroll expenses were 
more than $2.3 million, and (ii) Mahenjo’s average monthly payroll expenses were at least 
$172,250, were also materially false and misleading.  Records obtained from WCS and 
ESD reveal that, in 2019 and 2020, Mahenjo did not have employees and did not pay 
employee wages or payroll taxes.   
27. 
MOHAN’s representation that he was not the owner of any other business 
and did not manage any other business, was also false and misleading.  In truth, MOHAN 
owned at least three other businesses, namely Zuput, GitGrow, and Expect Success.  
MOHAN’s false and misleading representation had the effect of concealing his ownership 
of companies that had already applied for and received over $1 million in PPP loans. 
28. 
A review of IRS records revealed the Form 940 that MOHAN submitted to 
Financial Institution 5 to be fake: the return had not been filed with the IRS and the amounts 
of tax deposits reported on the Form 940 were not paid to the IRS.  Moreover, as explained 
above, MOHAN purported to sign Mahenjo’s Form 940 for 2019, approximately two 
months before he purchased Mahenjo. 
29. 
Evidence gathered in the investigation demonstrates that MOHAN falsified 
another document that he submitted in support of Mahenjo’s PPP loan application: the 
letter from HBS to MOHAN purporting to provide information about Mahenjo’s EIN.  The 
letter is dated February 12, 2018, which is over two years before MOHAN purchased 
Mahenjo from WCS.  The falsified letter was misleading in that it indicated that MOHAN 
owned and controlled Mahenjo in 2018 when, in truth, he did not. 
30. 
Based on a comparison of records obtained from WCS and Financial 
Institution 5, the incorporation documents MOHAN submitted to Financial Institution 5 
were materially altered.  The original incorporation documents obtained from WCS show 
that, on December 28, 2017, HBS appointed SKD as Mahenjo’s initial director.  The altered 
version of the incorporation documents obtained from Financial Institution 5 falsely state 
that on December 28, 2017, HBS appointed MOHAN as Mahenjo’s initial director.  The 
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COMPLAINT/United States v. Mukund Mohan - 11 
UNITED STATES ATTORNEY 
700 STEWART STREET, STE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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altered incorporation documents were misleading in that they indicated that MOHAN 
owned and controlled Mahenjo in 2017 when, in truth, he did not. 
31. 
Based on records obtained from JPMC, on June 2, 2020, MOHAN opened 
a bank account at JPMC in the name of Mahenjo (account number ending 9159).  In the 
account opening application, which MOHAN signed, MOHAN used Address 1 and 
Telephone Number 1, which, based on records obtained from T-Mobile, belonged to 
MOHAN.  MOHAN also submitted the same altered incorporation documents that he 
submitted in support of Mahenjo’s PPP loan application.     
32. 
Based on records obtained from Financial Institution 5, Mahenjo’s PPP 
loan application was approved on June 3, 2020.  MOHAN digitally signed the PPP loan 
documents using an IP address which, based on records obtained from CenturyLink, was 
associated with Address 1 (which is MOHAN’s residence). 
33. 
Based on records obtained from JPMC and Financial Institution 5, on June 
4, 2020, Financial Institution 5 transferred $431,250 in PPP loan proceeds via an interstate 
FedWire from its account in the Western District of Washington to Mahenjo’s bank 
account with JPMC (account number ending 9159).   
Monetary Transactions in Criminally Derived Property of a Value Greater Than 
$10,000 
 
34. 
Based on records obtained from Azlo, a financial institution that provides 
online business banking services, on April 10, 2020, an individual purporting to be 
MOHAN’s wife submitted an online application to open a bank account in Zigantic’s 
name.  Zigantic’s Azlo account (number ending 3419) was opened with a zero balance. 
35. 
As described above in paragraphs 8 through 14, on May 1, 2020, MOHAN 
submitted a fraudulent application to Financial Institution 2 for a PPP loan on behalf of 
Zigantic for $304,830. 
36. 
Based on records obtained from Financial Institution 2, on May 2, 2020, an 
employee from Financial Institution 2 sent an email to MOHAN informing him that 
Zigantic’s application had been approved and MOHAN responded with an email providing 
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COMPLAINT/United States v. Mukund Mohan - 12 
UNITED STATES ATTORNEY 
700 STEWART STREET, STE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
 
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wire transfer instructions so that Financial Institution 2 could wire the fraudulently 
obtained PPP loan proceeds to Zigantic’s Azlo account:  
Hi …. 
Our bank details are below: 
Routing number: 062001186 
Account number: XXXXXX3419 
Zigantic LLC 
Azlo Bank. 
Business Address: [Address 1] 
37. 
Based on records obtained from Azlo, on May 14, 2020, Financial 
Institution 2 wired the fraudulently obtained PPP loan proceeds to Zigantic’s Azlo account.  
At the time Financial Institution 2 wired the PPP loan proceeds to Zigantic’s Azlo account, 
that account only had a balance $1,641.89.   
38. 
Based on records obtained from JPMC, on May 6, 2020, MOHAN opened 
a bank account at JPMC in the name of Expect Success (number ending 8877), which 
MOHAN controls. 
39. 
Based on records obtained from Azlo, on May 18, 2020, an ACH transfer 
in the amount of $221,471 was made from Zigantic’s Azlo account to Expect Success’s 
JPMC account.  The $221,471 ACH transfer, however, failed due to a processing error on 
Azlo’s part and the money was returned to Zigantic’s Azlo account. 
40. 
Based on records obtained from Azlo, between May 20, 2020 and May 28, 
2020, five ACH transfers – totaling $231,471 – were made from Zigantic’s Azlo account 
to a brokerage account at Robinhood (number ending 4609).  Robinhood is 
financial services company that provides a mobile app and website that offer people the 
ability to invest in securities.  Based on records obtained from Robinhood, the brokerage 
account belongs to MOHAN.  The five ACH transfers from Zigantic’s Azlo account to 
MOHAN’s Robinhood account are detailed below: 
 
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UNITED STATES ATTORNEY 
700 STEWART STREET, STE 5220 
SEATTLE, WASHINGTON 98101 
(206) 553-7970 
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hereby finds that there is probable cause to believe the Defendant committed the offenses 
set forth in the Complaint. 
Dated this 21st day of July, 2020. 
BRIAN A. TSUCHIDA  
Chief United States Magistrate Judge 
Case 2:20-mj-00451-BAT   Document 1   Filed 07/21/20   Page 14 of 14

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