Criminal Information — United States v. Raekwon T. Randle

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IN THE UNITED STATES DISTRICT COURT 
 FOR THE CENTRAL DISTRICT OF ILLINOIS 
SPRINGFIELD DIVISION 
 
UNITED STATES OF AMERICA, 
 
 
 
 
Plaintiff, 
 
 
v. 
 
RAEKWON T. RANDLE, 
 
 
 
 
Defendant. 
 
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Case No. 25-CR- 
18 U.S.C. § 1343 
 
 
 
 
 
 
INFORMATION 
 
The United States Attorney Charges: 
 
COUNTS ONE-THREE 
(Wire Fraud) 
 
At all times material: 
 
1. 
Defendant, RAEKWON T. RANDLE (RANDLE), was a resident 
of Springfield, Illinois within the Central District of Illinois.   
The Small Business Administration and the CARES Act 
2. 
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 empowering the 
establishment and viability of small businesses and by stimulating the 
economic recovery of communities after disasters. 
E-FILED
 Tuesday, 16 September, 2025  02:47:17 PM 
 Clerk, U.S. District Court, ILCD
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3. 
As part of this effort, the SBA enabled and provided for loans 
through banks, credit unions, and other lenders that had government-
backed guarantees. The SBA also provided direct loans. 
4. 
In or around March 2020, the Coronavirus Aid, Relief, and 
Economic Security (“CARES”) Act was enacted to provide emergency 
financial assistance to the millions of Americans suffering adverse 
economic effects caused by the COVID-19 pandemic. The CARES Act 
established several new temporary programs and provided for expansion 
of others, including programs created and/or administered by the SBA. 
The Paycheck Protection Program 
5. 
One source of relief provided by the CARES Act was the 
authorization of United States taxpayer funds in forgivable loans to small 
businesses for job retention and certain other expenses, through a 
program referred to as the Paycheck Protection Program (“PPP”). PPP loan 
proceeds were required to be used by the business to pay certain 
permissible expenses: payroll costs, interest on mortgages, rent, and 
utilities. 
6. 
 In order 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 
applicant business (through its authorized representative) to acknowledge 
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the program rules and make certain affirmative certifications in order to 
be eligible to obtain the PPP loan. Such certifications required the 
applicant to affirm that “The [PPP loan] funds will be used to retain workers 
and maintain payroll or make mortgage interest payments, lease 
payments, and utility payments,” and that the “loan proceeds will be used 
only for business-related purposes as specified in the loan application” 
and consistent with the PPP rules. The authorized representative of the 
applicant was also required to certify that “the information provided in this 
application and the information provided in all supporting documents and 
forms is true and accurate in material respects,” and “I understand that if 
the funds are knowingly used for unauthorized purposes, the federal 
government may hold me legally liable, such as for charges of fraud.” 
7. 
In the PPP loan application, the applicant was required to state, 
among other things, the business’s: (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, the applicant was required to provide documentation showing 
its payroll expenses, including federal tax filings and bank account 
records. 
8. 
A small business’s PPP loan application would be received and 
processed by a participating lender approved by the SBA. If a PPP loan 
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application was approved, the participating lender would fund the PPP 
loan using its own monies, which were guaranteed by the SBA. For each 
funded application lenders received a processing fee from the SBA in a 
percentage of the loan or an amount not less than $2,500.00. 
9. 
Womply, a Deleware corporation, was a software-as-a-service 
(SaaS) provider to small businesses acting as both a referral agent sending 
businesses to lenders but also a technology service provider. Womply 
created an application to process PPP loan applications called “PPP Fast 
Lane.” The software was internet based and users would interact with 
Womply’s system over the internet. Most, if not all, phases of the loan 
process were completed in Fast Lane, including filling out the application 
and signing of the loan documents. 
10. 
Harvest Small Business Finance, LLC (“Harvest”) was a 
financial institution, headquartered in Laguna Hills, CA. Harvest was 
licensed by the Small Business Administration (“SBA”) and authorized to 
directly originate, fund, and service SBA loans, with backing by the SBA 
guaranty. 
11. 
The Bancorp, Inc., headquartered in Wilmington, Delaware, 
was a payment services provider and specialized lender within the U.S. 
through its subsidiary, The Bancorp Bank, N.A. (headquartered in Sioux 
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Falls, South Dakota). The Bancorp Bank, N.A., was insured by the Federal 
Deposit Insurance Corporation.  
12. 
Varo Bank, based in Draper, Utah, was a financial institution 
insured by the Federal Deposit Insurance Corporation (FDIC).  
13. 
Benworth 
Capital 
(Benworth), 
was 
an 
approved 
SBA 
participating lender based in Florida. 
The Scheme to Defraud 
14. 
Beginning in or about April 2021, and continuing until at least 
June 2021, in the Central District of Illinois, and elsewhere, the defendant, 
RAEKWON T. RANDLE, 
knowingly devised and participated with others in a scheme to defraud the 
SBA, Harvest, and their related entities and others, to obtain money by 
means of materially false and fraudulent pretenses, representations, and 
promises, all affecting financial institutions as defined under 18 U.S.C. § 
20. It was a part of the scheme and artifice to defraud that: 
15. 
As part of the scheme, Defendant RANDLE recruited and 
assisted others to apply for PPP loans using fraudulent tax documents, 
which falsely represented that the borrowers operated a profitable beauty 
salon, hair stylist, auto repair, and other business that the borrowers did 
not own and operate. Approximately $208,330 of fraudulent loans were 
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funded as a result of this scheme by RANDLE. Neither RANDLE nor these 
individuals were lawfully entitled to these proceeds. 
16. 
As part of the scheme, Defendant RANDLE received a fee or 
kickback of approximately $2,000 to his Varo bank account for each 
borrower he recruited or assisted. RANDLE received in total approximately 
$16,000.  
17. 
One of these people, Individual A obtained $20,833 from 
Benworth Capital for a PPP loan for a beauty/ cosmetology business they 
did not have. RANDLE assisted Individual A in applying for the loan. 
RANDLE was subsequently paid $2,000 after that loan was funded.  
18. 
On or around April 14, 2021, and again on April 16, 2021, 
RANDLE completed and submitted PPP loan applications to Harvest that 
were subsequently approved and funded. In order to qualify for the loans, 
RANDLE submitted materially false information, stating he was the 100% 
owner of a sole proprietorship business engaged in business consulting 
that the business was started in 2019, that it had gross profits totaling 
$106,600.00 for the year 2019, that the net profit was $94,250 and 
$115,700 respectively, and that the business had one employee. 
Submitted with the loan applications were false and fraudulent supporting 
documentation, including fraudulent tax documents. RANDLE falsely 
certified and caused to be certified that all loan proceeds would be used 
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only for business-related purposes. The applications were submitted to 
Harvest using an internet-based platform, Womply. 
19. 
In reliance on RANDLE’s materially false and fraudulent 
statements and his concealment of material facts, Harvest approved and 
funded the PPP Loan Applications, and thereafter on April 26, 2021, 
transferred approximately $20,833.00 in proceeds by interstate wire into 
a Bankcorp bank account that RANDLE controlled and again on again on 
May 26, 2021 transferred approximately $20,833.00 in proceeds into a 
Bankcorp bank account that RANDLE controlled, for a total of 
approximately $41,666.00. 
20. 
RANDLE used the fraudulently obtained PPP loan proceeds for 
his own personal benefit, including for expenses prohibited under the 
requirements of the PPP program. 
21. 
In reliance on RANDLE’s materially false and fraudulent 
statements and his concealment of material facts, Individual A obtained 
a $20,833 PPP loan from Benworth Capital for a beauty/ cosmetology 
business Individual A did not have. RANDLE assisted Individual A in 
applying for the loan. Individual A used the PPP loan proceeds for 
Individual A’s personal benefit, including for expenses prohibited under 
the requirements of the program. After receipt of that PPP loan, 
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Individual A then transferred $2,000 to RANDLE via his Varo bank 
account.  
Executions of the Scheme 
22. 
On or about the dates listed below, for each count, and for the 
purpose of executing the above-described scheme to defraud and to obtain 
money and property, the defendant, 
RAEKWON T. RANDLE, 
caused to be transmitted the following interstate wire communications: 
COUNTS 
       DATE 
NATURE OF TRANSMISSION 
1 
April 14, 2021 
Loan application from RANDLE to Harvest 
of California using Womply’s “Fast Lane” 
software program. 
2 
May 13, 2021 
Transfer of $2,000 from Individual A to 
RANDLE’s Varo back account 
3 
June 1, 2021  
 
Harvest transfer of $20,833.00 into 
RANDLE’S bank account at Bankcorp 
Bank 
 
 
All in violation of Title 18, United State Code, Section 1343.  
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT FOUR 
(Wire Fraud) 
 
Introduction 
 
At all times material: 
 
1. 
Defendant, RAEKWON T. RANDLE (RANDLE), was a resident 
of Springfield, Illinois within the Central District of Illinois.   
2. 
Defendant maintained control of a bank account in his name 
at Bankcorp Bank, a financial institution insured by the Federal Deposit 
Insurance Corporation (FDIC), based in Sioux Falls, South Dakota. 
3. 
Defendant maintained control of a bank account in his name 
at Varo Bank, a financial institution insured by the Federal Deposit 
Insurance Corporation (FDIC), based in Draper, Utah.  
4. 
Unemployment Insurance (UI) was a joint state and federal 
program that provided monetary benefits to eligible beneficiaries. UI 
payments were intended to provide temporary financial assistance to 
lawful workers who were unemployed through no fault of their own.  
Beginning in or around March 2020, in response to the COVID-19 
pandemic, several federal programs expanded UI eligibility and increased 
UI benefits, including the Pandemic Unemployment Assistance Program 
(PUA), Federal Pandemic Unemployment Compensation (FPUC), and the 
Lost Wages Assistance Program (LWAP).  
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5. 
In the State of Indiana, the Indiana Department of Workforce 
Development (IN-DWD) based in Indianapolis, Indiana, administered the 
UI program. Those seeking UI benefits submitted online applications. 
Applicants had to answer specific questions to establish eligibility to 
receive UI benefits, including their name, Social Security Number (SSN), 
and mailing address, among other things.  Applicants also had to self-
certify that they met a COVID-19-related reason for being unemployed, 
partially employed, or unable to work. The IN-DWD relied upon the 
information in the application to determine UI benefits eligibility. Once an 
application was approved, one of the ways IN-DWD provided benefits was 
by direct deposit to the applicant’s bank account.  
6. 
In the State of Nevada, the Department of Employment, 
Training & Rehabilitation (NV-DETR) with offices in Carson City and Las 
Vegas, Nevada, administered the UI program. Those seeking UI benefits 
submitted online applications. Applicants had to answer specific questions 
to establish eligibility to receive UI benefits, including their name, Social 
Security Number (SSN), and mailing address, among other things.  
Applicants also had to self-certify that they met a COVID-19-related reason 
for being unemployed, partially employed, or unable to work. The NV-
DETR relied upon the information in the application to determine UI 
benefits eligibility. Once an application was approved, one of the ways NV-
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DETR provided benefits was by direct deposit to the applicant’s bank 
account.   
7. 
In the State of Illinois, the Illinois Department of Economic 
Security (IDES) administered the UI program. Those seeking UI benefits 
submitted online applications. Applicants had to answer specific questions 
to establish eligibility to receive UI benefits, including their name, Social 
Security Number (SSN), and mailing address, among other things.  
Applicants also had to self-certify that they met a COVID-19-related reason 
for being unemployed, partially employed, or unable to work. The IDES 
relied upon the information in the application to determine UI benefits 
eligibility. Once an application was approved, one of the ways IDES 
provided benefits was by direct deposit to the applicant’s bank account.   
 
 
The Scheme to Defraud 
8. 
Beginning in or about March 2020, and continuing until at 
least June 2021, in the Central District of Illinois, and elsewhere, the 
defendant, 
RAEKWON T. RANDLE, 
knowingly devised and participated with others in a scheme to 
defraud the SBA, Harvest, and their related entities and others, to obtain 
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money by means of materially false and fraudulent pretenses, 
representations, and promises, all affecting financial institutions as 
defined under 18 U.S.C. § 20. It was a part of the scheme and artifice to 
defraud that: 
10.  On or about November 6, 2020, RANDLE submitted a false and 
fraudulent application using IN-DWD online portal for unemployment 
insurance. The application used the same address and phone number as 
the IDES claim and a separate claim to NV-DETR. RANDLE falsely claimed 
he was employed by a business based in Plainfield, Indiana between March 
14, 2020 and November 7, 2020, when in fact, RANDLE had never worked 
for the Indiana based business. RANDLE further falsely claimed in 
connection with this application that he had not received unemployment 
from any other state and that he lived in Indiana.  
11.  The application included a false certification that all 
information contained in the application was true and complete. The 
certification required the applicant to acknowledge that a false statement 
would subject the person to criminal penalties.  
12.  As the result of his false and fraudulent application, RANDLE 
received $15,415 in total via direct deposits to his PNC Bank account from 
IN-DWD. 
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13.    On or about the date listed below and for the purpose of 
executing the above-described scheme to defraud and to obtain money and 
property, RANDLE transmitted and caused to be transmitted the following 
interstate wire communications: 
COUNT 
DATE 
NATURE OF COMMUNICATION 
4 
November 6, 
2020 
Unemployment insurance application 
from RANDLE in Illinois to the State of 
Indiana. 
 
 
________ 
GREGORY M. GILMORE 
ACTING UNITED STATES ATTORNEY     
SES 
for
s/ Sarah E Seberger
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