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Home Court filings United States v. Sieff Robert Sargeant Information — United States v. Sargeant

Court filing

Information — United States v. Sargeant

Filed May 23, 2024 in U.S. v. Sargeant; one of 4 filings from this case.

Record facts

CourtU.S. District Court for the District of New Jersey (Camden)
Filed2024-05-23

U.S. District Court for the District of New Jersey (Camden) · No. 1:24-cr-00360-KMW · Doc. 23 · 2024-05-23 · Docket on CourtListener

Full text

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2024R00235/DAF/JMR 
UNITED STATES DISTRICT COURT 
DISTRICT OF NEW JERSEY 
 
 
UNITED STATES OF AMERICA 
: 
Crim. No. 24- 
 
 
 
 
: 
 
v. 
 
 
 
 
:  
18 U.S.C. § 1956(a)(1)(A)(i) 
 
 
 
 
: 
 
SIEFF ROBERT SARGEANT 
 
: 
 
 
 
I N F O R M A T I O N 
 
 
The defendant having waived in open court prosecution by Indictment 
and any objection based on venue, the United States Attorney for the District of 
New Jersey charges: 
1. 
At all times relevant to this Information: 
a. 
The defendant, SIEFF ROBERT SARGEANT, resided in 
Island Park, New York.  Defendant SIEFF ROBERT SARGEANT owned or 
controlled Coach Sargeant Training LLC, a New York business. 
b. 
Lender-1 was a financial institution that participated as 
lender in the Paycheck Protection Program (“PPP”), as described herein.  
Lender-1 was a “financial institution” within the meaning of Title 18, United 
States Code, Section 20. 
c. 
Co-Conspirator-1 (“CC-1”) resided in Delaware. 
d. 
Individual-1 was an associate of defendant SIEFF ROBERT 
SARGEANT. 
360-KMW
Case 1:24-cr-00360-KMW     Document 23     Filed 05/23/24     Page 1 of 7 PageID: 65

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The Payroll Protection Program (“PPP”) 
e. 
The Coronavirus Aid, Relief, and Economic Security 
(“CARES”) Act was a federal law enacted in or about March 2020 and was 
designed to provide emergency financial assistance to millions of Americans 
suffering economic effects caused by the COVID-19 pandemic.  One source of 
relief provided by the CARES Act was the authorization of billions of dollars in 
forgivable loans to small businesses for job retention and certain other 
expenses, through a program referred to as the Paycheck Protection Program 
(“PPP”). 
f. 
To obtain a PPP loan, a business had to submit a PPP loan 
application 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 had to state, among other 
things, its average monthly payroll expenses and number of employees.  These 
figures were used to determine whether the business was eligible for a PPP loan 
and to calculate the amount of money the business was eligible to receive 
under the PPP.  In addition, businesses applying for a PPP loan had to provide 
documentation showing their payroll expenses, such as tax forms and bank 
statements. 
g. 
A PPP loan application had to be processed by a participating 
financial institution (the lender).  If the PPP loan application was approved, the 
lender funded the PPP loan using its own monies, which were 100% 
Case 1:24-cr-00360-KMW     Document 23     Filed 05/23/24     Page 2 of 7 PageID: 66

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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. 
h. 
PPP loan proceeds could only be used by the business for 
certain permissible expenses, including 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 used the loan proceeds on these expense 
items within a designated period of time after receiving the proceeds and used 
a certain amount of the PPP loan proceeds on payroll expenses. 
i. 
To obtain loan forgiveness of a loan in the amount of 
$150,000 or less, a borrower was required to submit a PPP Loan Forgiveness 
Application Form 3508S.  Form 3508S required the borrower to report the 
amount of loan proceeds spent on payroll costs.  It also required the borrower 
to certify that the information provided in the forgiveness application was true 
and correct. 
2. 
On or about April 27, 2021, $147,000 was deposited into a Lender-
1 bank account that defendant SIEFF ROBERT SARGEANT controlled in the 
name of Coach Sargeant Training LLC.  The $147,000 deposit constituted 
proceeds of a PPP loan obtained as a result of a fraudulent PPP loan 
application. 
3. 
Beginning in or about July 2021, for the purpose of promoting 
bank fraud by making it appear like the Coach Sargeant Training PPP loan 
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proceeds were spent on permissible payroll expenses, SIEFF ROBERT 
SARGEANT paid CC-1 to issue fake payroll checks with the proceeds of the PPP 
loan even though Coach Sargeant Training LLC did not have any actual 
employees. 
4. 
CC-1 printed fake payroll checks made out to Individual-1 in the 
aggregate amount of $8,550 and provided them to defendant SIEFF ROBERT 
SARGEANT to distribute to Individual-1. 
5. 
Individual-1 cashed the fake payroll checks and returned most of 
the cash to defendant SIEFF ROBERT SARGEANT. 
6. 
In or about July 2021 through in or about September 2021, in 
Nassau County, in the Eastern District of New York, and elsewhere, the 
defendant, 
SIEFF ROBERT SARGEANT, 
did knowingly conduct and attempt to conduct financial transactions affecting 
interstate and foreign commerce which involved the proceeds of a specified 
unlawful activity, that is bank fraud, with the intent to promote the carrying on 
of specified unlawful activity, that is bank fraud, and that while conducting 
and attempting to conduct such financial transactions knew that the property 
involved in the financial transaction represented the proceeds of some form of 
unlawful activity. 
In violation of Title 18, United States Code, Section 1956(a)(1)(A)(i). 
 
 
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FORFEITURE ALLEGATION 
1. 
Upon conviction of the money laundering offense in violation of 18 
U.S.C. § 1956 alleged in this Information, defendant SIEFF ROBERT 
SARGEANT shall forfeit to the United States, pursuant to 18 U.S.C. § 982(a)(1), 
all property, real and personal, involved in the money laundering offense, and 
all property traceable to such property. 
2. 
The property to be forfeited includes, but is not limited to, a sum of 
money representing the property involved in the money laundering offense 
charged in this Information; and the following property:  
(a) 
All funds and other property on deposit at Key Bank NA, 
account number ending in 5313, in the name of Coach 
Sargeant Training LLC. 
 
Substitute Assets Provision 
3. 
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, 
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the United States shall be entitled, pursuant to 21 U.S.C. § 853(p), as 
incorporated by 18 U.S.C. § 982(b), to forfeiture of any other property of the 
defendant(s) up to the value of the forfeitable property described above. 
 
 
 
 
 
 
 
 
 
 
 
 
_______________________ 
 
 
 
 
 
PHILIP R. SELLINGER 
United States Attorney 
Case 1:24-cr-00360-KMW     Document 23     Filed 05/23/24     Page 6 of 7 PageID: 70

 
CASE NUMBER:  _____________ 
═════════════════════════════════ 
United States District Court 
District of New Jersey 
═════════════════════════════════ 
UNITED STATES OF AMERICA 
 
v. 
 
SIEFF ROBERT SARGEANT 
 
═════════════════════════════════ 
INFORMATION FOR 
 
18 U.S.C. § 1956(a)(1)(A)(i) 
 
═════════════════════════════════ 
PHILIP R. SELLINGER 
UNITED STATES ATTORNEY  
FOR THE DISTRICT OF NEW JERSEY 
═════════════════════════════════ 
DANIEL A. FRIEDMAN 
JASON M. RICHARDSON 
ASSISTANT U.S. ATTORNEYS 
CAMDEN, NEW JERSEY 
(856) 757-5026 
═════════════════════════════════ 
 
Case 1:24-cr-00360-KMW     Document 23     Filed 05/23/24     Page 7 of 7 PageID: 71

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Part of: United States v. Sieff Robert Sargeant — U.S. District Court, D.N.J. · U.S. District Court for the District of New Jersey · Paycheck Protection Program (PPP) · Criminal prosecutions · Complaints and indictments · 2024 · Court filings

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