Indictment — United States v. Sinju (District of Utah, July 26, 2023)

Summary

An indictment, Document 1 in United States v. Peter N. Sinju, Case 2:23-cr-00280-HCN, filed 07/26/23, in the U.S. District Court for the District of Utah and running 17 pages. Trina A. Higgins, United States Attorney, and Assistant U.S. Attorney Todd C. Bouton signed for the government. The grand jury charges that Sinju, a Certified Public Accountant and partner at Recon CPA, LLC in Salt Lake City, devised a scheme to defraud the Paycheck Protection Program and the Economic Injury Disaster Loan program using exaggerated and duplicative payroll and revenue information for his clients. It lists Counts 1-4 under 18 U.S.C. § 1014 (false statement to a bank) and Counts 5-9 under 18 U.S.C. § 1343 (wire fraud), and ends with forfeiture allegations and a true bill.

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“Indictment — United States v. Sinju (District of Utah, July 26, 2023).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/1-d9724af8ab/, SHA-256 19eb3b4c36599e248f57a0eadd32c306f7688c9692794db5e7c070c5c367c17c.

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Case 2:23-cr-00280-HCN Document 1 Filed 07/26/23 PageID.1 Page 1 of 17

TRINA A. HIGGINS, United States Attorney (#7349)
TODD C. BOUTON, Assistant United States Attorney (#17800) FILED
Attorneys for the United States of America 2023 JUL 26 PM 1:46
Office of the United States Attorney CLERK
111 South Main Street, Suite 1800 U.S. DISTRICT COURT
Salt Lake City, Utah 84111-2176
Telephone: (801) 524-5682
Email: todd.bouton@usdoj.gov

IN THE UNITED STATES DISTRICT COURT
DISTRICT OF UTAH

UNITED STATES OF AMERICA, INDICTMENT

Plaintiff, VIOLATIONS:

vs. COUNTS 1-4: 18 U.S.C. § 1014,
False Statement to a Bank
PETERN. SINJU,
COUNT 5-9: 18 U.S.C. § 1343,
Defendant. Wire Fraud

Case: 2:23-cr-00280
1

The Grand Jury Charges:
Assigned To : Nielson, Howard C., Jr
I. BACKGROUND Assign. Date: 7/25/2023

At all times relevant to this Indictment:
1. Defendant PETER N. SINJU ("SINJU") was a resident of Salt Lake City,
Utah in the District of Utah.
2. SINJU was a Certified Public Accountant ("CPA") working in Salt Lake
City, Utah and a partner at Recon CPA, LLC.
3. During the COVID-19 pandemic, SINJU attempted to defraud COVID-19
relief programs in the name of some of his unknowing clients.
4. SINJU specifically devised a scheme to defraud the Paycheck Protection
Program and the Economic Injury Disaster Loan program by submitting fraudulent,
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exaggerated, and duplicative payroll and revenue information to lenders and the SBA on
behalf of his unknowing clients to help them obtain loans they did not qualify for.
SINJU's Relevant Clients
5. Company 1 was a framing company owned by Individual 1 and was a client
ofSINJU.
6. Company 2 was a food-truck business owned by Individual 2 and was a
client of SINJU.
7. Company 3 was an import/export company owned by Individual 3 and was
a client of SINJU.
8. Company 4 was a residential-concrete business owned by Individual 4 and
was a client of SINJU.
9. Company 5 was a hair salon-type business owned by Individual 5 and was
a client of SINJU.
The Small Business Administration
10. The Small Business Administration ("SBA") is an executive branch agency
of the United States government that provides 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.
11. As part of this effort, the SBA enables and provides loans through banks,
credit unions, and other lenders. These loans have government-backed guarantees.
The Paycheck Protection Program
12. On March 27, 2020, the President signed into law the Coronavirus Aid,
Relief, and Economic Security Act ("CARES Act"). This Act was an economic stimulus
bill that, among other things, provided emergency financial assistance to small business
owners, including agricultural businesses, and nonprofit organizations in all U.S. states,
Washington D.C., and territories which were affected by the COVID-19 pandemic. One
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form of assistance 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").
13. As discussed more fully below, the PPP program, which is operated by the
SBA, provided small businesses with funding to meet specific business obligations,
including payroll and rent. The PPP program permitted participating third-party lenders to
approve and disburse SBA-backed PPP Loans to cover payroll, fixed debts, utilities,
rent/mortgage, accounts payable, and other bills incurred by qualifying businesses during,
and resulting from, the COVID-19 pandemic. PPP Loans are fully guaranteed by the SBA.
In the event of default, SBA will fully satisfy the lender for any balance remaining on the
loan. Further, SBA will forgive any loan up to 100 percent if the borrower establishes it
utilized 60 percent of the loan on payroll costs in the 24-week period post-disbursement,
with the remaining 40 percent going toward covered mortgage interest payments, covered
rent payments, covered utilities, covered operations expenditures, covered property
damage costs, covered supplier costs, and covered worker protection expenditures.
Whatever portion is not forgiven is serviced as a loan.
14. The SBA promulgated regulations concerning eligibility for a PPP Loan. To
obtain a PPP Loan, a qualifying business was required to submit a PPP-Loan application,
which was 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 make certain affirmative certifications in order to be eligible to
obtain the PPP Loan, including that the business was in operation on February 15, 2020
and either had employees for whom it paid salaries and payroll taxes or paid independent
contractors, as reported on a "Form 1099-MISC." Specifically, in the PPP-Loan
application (SBA Form 2483), 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.
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15. In addition, a business applying for a PPP Loan was required to provide
documentation showing its payroll expenses. This payroll information was material to the
loan application because, pursuant to statutory requirements and implementing
regulations, the amount of the loan that typically could be approved was a function of the
applicant's historical payroll costs, consisting of compensation to its employees whose
principal place of residence was the United States, subject to certain exclusions. Once
approved for a PPP Loan by a participating third-party lender, small businesses could
receive loans ofup to $10,000,000.
16. Individuals who operated a business under a "sole proprietorship" business
structure were also eligible for a PPP Loan. To qualify for such a PPP Loan, individuals
had to report and document their income and expenses from the sole proprietorship, as
typically reported to the Internal Revenue Service on a "Form 1040, Schedule C," for a
given tax year. As with other PPP Loans, this information and supporting documentation
was used to calculate the amount of money the individual was entitled to receive under the
PPP program. The maximum loan amount for a sole proprietor with no employees was
$20,833.
17. By s1gnmg a PPP-Loan application, each applicant attested that the
information provided in the application and in all supporting documents and forms was
true and accurate, and that the applicant understood that knowingly making a false
statement to obtain a PPP Loan was a crime.
PPP-Loan Application Processing Through Server in Virginia
18. A PPP-Loan application was processed by the third-party participating
lender with whom the application was filed. If a PPP-Loan application was approved, the
participating lender would fund the PPP Loan; in order to encourage PPP Loans to be
issued, the loan was guaranteed by the SBA. Data from the application, including
information from 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.
4
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19. More specifically, up until August 8, 2020, during the first two rounds of
PPP Loans, PPP-Loan applications were received through the SBA E-Tran server which is
located in Sterling, Virginia. After PPP lenders disbursed the PPP-Loan funds to the
borrower, PPP lenders submitted disbursement details into the SBA E-Tran system located
in Sterling, Virginia. The SBA then transmitted the PPP processing fee to the lender
through the Financial Management System ("FMS") to the Treasury. The primary server
for the FMS is also in Sterling, Virginia.
Authorized Use of PPP-Loan Funds and Forgiveness of PPP Loans
20. The proceeds of a PPP Loan could be used only for certain specified items,
such as payroll costs, costs related to the continuation of group health care benefits, or
mortgage interest payments. The proceeds of a PPP loan were not permitted to be used by
the borrowers to purchase consumer goods, automobiles, personal residences, clothing,
jewelry, to pay the borrower's personal federal income taxes, or to fund the borrower's
ordinary day-to-day living expenses unrelated to the specified authorized expenses.
21. If a borrower used PPP-Loan funds for authorized expenses, the borrower
could later apply for forgiveness of all the loan proceeds properly executed.
The EIDL Loan Program
22. Another related response to the COVID-19 outbreak was an expansion of an
existing disaster-related program called the Economic Injury Disaster Loan ("EIDL
Loan"). EIDL Loans provided for loan assistance (including $10,000 advances) for small
businesses and other eligible entities for loans up to certain amounts.
23. In order to obtain an EIDL Loan and advance, a qualifying business was
required to submit an application to the SBA and provide information about its operations,
such as its number of employees, gross revenues for the 12-month period preceding the
disaster, and cost of goods sold in the 12-month period preceding the disaster. In the case
of EIDL Loans for COVID-19 relief, the 12-month period was the period preceding
January 31, 2020. For a business to be eligible for an EIDL Loan, the business must have
5
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been in operation before February 1, 2020. The applicant was also required to certify that
all of the information in the application was true and correct to the best of the applicant's
knowledge.
24. In the required Loan Authorization and Agreement related to each loan
application, applicants were also required to agree to use the EIDL Loan funds solely as
working capital to alleviate economic injury caused by the COVID-19 disaster.
25. In their applications and related loan agreements, applicants were warned
that any false statement or misrepresentation to the SBA, or any misapplication of loan
proceeds might result in sanctions, including criminal penalties.
26. Unlike funds from other types of SBA-guaranteed loans, such as PPP Loans,
EIDL-Loan funds were issued directly from the United States Treasury, and applicants
applied for EIDL-Loan funds directly through the SBA via an online portal and
application. All EIDL-Loan applications were thus submitted online.
EIDL-Loan Application Processing Through Interstate Servers
27. Prior to July 11, 2020, EIDL-Loan applications were submitted through the
SBA's Office of Disaster Assistance Disaster Credit Management System 2.0. During this
time period, all EIDL-Loan applications with a prefix of 33 were processed through a
server located in West Des Moines, Iowa.
28. The approval of both the EIDL-Loan application and the amount of the
related EIDL loan was based, in part, on the information provided in the EIDL-Loan
application about the applicant's number of employees, gross revenue, and cost of goods,
as described above. The SBA required minimal documentation and information from
small businesses to support the information asserted in an EIDL-Loan application before
the SBA would process the EIDL-Loan application for approval.
29. Once an SBA EIDL-Loan application was approved, the SBA's Denver
Finance Center, located in Denver, Colorado, created payment files and authorized
payments of the EIDL-Loan funds based on those applications. For disbursement, EIDL-
6
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Loan funds were first transmitted by the Financial Management System ("FMS") to the
Treasury, and then to the loan recipient's bank account. The primary server for the FMS is
in Sterling, VA. Upon approval of an application for an EIDL Loan or advance, the SBA
would disburse the funds.
Authorized Use of EIDL-Loan Funds
30. EIDL-Loan proceeds were permitted to be used for payroll expenses, sick
leave, production costs, and business obligations, such as debts, rent, and mortgage
payments. However, such loan proceeds were not intended to replace lost sales or profits,
or to be used to expand the applicant business.
Financial Institution and PPP-Loan Lender
31. First Utah Bank was and is a financial institution, the deposits of which are
federally insured by the Federal Deposit Insurance Corporation. While the PPP-Loan
program was in operation, First Utah Bank offered PPP Loans to applicants.
II. THE SCHEME AND ARTIFICE TO DEFRAUD
32. Beginning on or around June 2, 2020, and continuing to and including on or
around July 3, 2020, within the District of Utah and elsewhere, the defendant,
PETER N. SINJU,
knowingly devised and executed a scheme and artifice to defraud and sought to obtain
money and property by means of materially false and fraudulent pretenses, representations
and promises, and omissions of material facts.
33. In executing and attempting to execute the scheme and artifice to defraud,
and in furtherance thereof, SINJU:
a. Knowingly made false statements and caused false statements to be
made to a financial institution, in violation of 18 U.S.C. §1014 (False
Statements to a Bank) by, inter alia, submitting at least four PPP-Loan
applications to First Utah Bank between approximately June 5, 2020 and
June 15, 2020; and
7
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b. Knowingly devised and intended to devise a scheme and artifice to
defraud the SBA and made false and fraudulent pretenses,
representations, and promises to the SBA, in violation of 18 U.S.C. §
1343 (Wire Fraud) by, inter alia, submitting or causing to be submitted
at least five fraudulent EIDL-Loan applications between approximately
June 2, 2020 and July 3, 2020.
III. THE OBJECT OF THE SCHEME AND ARTIFICE TO DEFRAUD
34. It was the object of the scheme and artifice to defraud for SINJU to obtain
money for his unknowing clients from First Utah Bank and the SBA in the form of PPP-
Loan and EIDL-Loan proceeds through false statements, misrepresentation, deception,
and omissions of material facts, and to then take a portion of those loan proceeds as a fee
or commission for obtaining the loans for his clients.
IV. MANNER AND MEANS OF THE SCHEME AND ARTIFICE TO
DEFRAUD
Company l's EIDL-Loan Application:
35. On or about June 2, 2020, on behalf of Company 1, defendant SINJU
completed and submitted an application to the SBA for an EIDL Loan in the amount of
$79,297.50.
36. In execution and furtherance of the scheme and artifice to defraud,
defendant SINJU made, or caused to be made, the following false and fraudulent
representation to the SBA:
a. In 2019, Company 1's gross revenues were $324,006, when in fact, the
company's gross revenues were only approximately $250,000.
Company l's PPP-Loan Application:
37. On or about June 5, 2020, on behalf of Company 1, defendant SINJU
completed and submitted an application to First Utah Bank for a PPP Loan in the amount
of $41,700.
8
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38. In execution and furtherance of the scheme and artifice to defraud,
defendant SINJU made, or caused to be made, one or more of the following false and
fraudulent representations to First Utah Bank:
a. The payroll summary submitted in support of the PPP-Loan application
("Company 1's Payroll Summary") was true and accurate, when in fact, it
was not;
b. The employees listed in Company 1's Payroll Summary were all Company
1 employees, when in fact, some of them were not actually Company 1
employees; and
c. The Company 1 employees listed on Company 1's Payroll Summary were
paid a total of $203,469.97 in 2019, when in fact, Company 1's employees
were not paid more than a total of approximately $56,000.
39. On or around June 8, 2020, First Utah Bank approved and funded a PPP
Loan to Company 1 in the amount of$41,000.
Company 2's EIDL-Loan Application:
40. On or about June 9, 2020, on behalf of Company 2, defendant SINJU
completed and submitted an application to the SBA for an EIDL Loan in the amount of
$50,600.
41. In execution and furtherance of the scheme and artifice to defraud,
defendant SINJU made, or caused to be made, the following false and fraudulent
representation to the SBA:
a. In 2019, Company 2 had $123,369 in gross revenues, when in fact, this
number overstated the company's revenues, which were closer to
approximately $50,000.
42. In response to the EIDL-Loan application, on or about July 1, 2020,
Company 2 received $50,600 in EIDL-Loan proceeds.

9
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Company 2's PPP-Loan Application:
43. On or about June 11, 2020, on behalf of Company 2, defendant SINJU
completed and submitted an application to First Utah Bank for a PPP Loan in the amount
of$20,800.
44. In execution and furtherance of the scheme and artifice to defraud,
defendant SINJU made, or caused to be made, the following false and fraudulent
representation to First Utah Bank:
a. An IRS Form Schedule C for 2019 accurately showed that Company 2 had
gross revenues of $123,369 in 2019, when in fact, the company's 2019
gross revenues were closer to approximately $50,000.
Company 3 's EIDL-Loan Application:
45. On or about June 9, 2020, on behalf of Company 3, defendant SINJU
completed and submitted an application to the SBA for an EIDL Loan in the amount of
$81,000.
46. In execution and furtherance of the scheme and artifice to defraud,
defendant SINJU made, or caused to be made, the following false and fraudulent
representation to the SBA:
a. In 2019, Company 3 had gross revenues of $221,526, when in fact, the
company had gross revenues of only $20,000 to $30,000.
47. On or about June 21, 2020, Company 3's owner received $81,000 in EIDL-
Loan proceeds.
Company 3's PPP-Loan Application:
48. On or about June 15, 2020, on behalf of Company 3, defendant SINJU
completed and submitted an application to First Utah Bank for a PPP Loan in the amount
of $36,100.
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49. In execution and furtherance of the scheme and artifice to defraud,
defendant SINJU made, or caused to be made, one or more of the following false and
fraudulent representations to First Utah Bank:
a. Company 3 had a monthly payroll of $14,441, when in fact, it did not;
b. Company 3 had 5 employees, when in fact, it never had any employees
other than its owner, Individual 3;
c. Company 3 was in operation on February 15, 2020 and had employees for
whom it paid salaries and payroll taxes, when in fact, it only had 1
employee-its owner, Individual 3;
d. The payroll summary submitted with Company 3's PPP-Loan application
("Company 3's Payroll Summary") was true and accurate, when ip. fact, it
was not;
e. As reflected in Company 3's Payroll Summary, in 2019, Company 3 had
paid employee wages totaling $146,177.77, when in fact, it had not;
f. As reflected in Company 3 's Payroll Summary, in 2019, Company 3 had
employed 5 specific employees, when, in fact, the company had never
employed any of those employees;
g. As reflected in the IRS Forms 940 and 941 submitted in support of
Company 3's PPP-Loan application, in 2019, Company 3 had paid a total
of $146,177.77 in employee wages, when in fact, Company 3 had no other
employees other than its owner, Individual 3, and made only $20,000 to
$30,00 in revenues; and
h. As reflected in an IRS Form 941 submitted in support of Company 3's
PPP-Loan Application, from January to March 2020, Company 3 had 4
employees and paid them $38,369, when in fact, none of this was true.

11
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Company 4 's EIDL-Loan Application:
50. On or about June 10, 2020, on behalf of Company 4, defendant SINJU
completed and submitted an application to the SBA for an EIDL Loan in the amount of
$48,000.
51. In execution and furtherance of the scheme and artifice to defraud,
defendant SINJU made, or caused to be made, the following false and fraudulent
representation to the SBA:
a. In 2019, Company 4 had $258,963 in gross revenues, when m fact,
Company 4 only had $3,000 in gross revenues.
52. In response to the EIDL-Loan application, on or about June 24, 2020,
Company 4 received $48,000 in EIDL-Loan proceeds.
Company 4's PPP-Loan Application:
53. On or about June 15, 2020, on behalf of Company 4, defendant SINJU
completed and submitted an application to First Utah Bank for a PPP Loan in the amount
of$36,400.
54. In execution and furtherance of the scheme and artifice to defraud,
defendant SINJU made, or caused to be made, one or more of the following false and
fraudulent representations to First Utah Bank:
a. Company 4 had an average monthly payroll of $14,632.25, when in fact,
the actual amount was $0;
b. Company 4 had 8 employees, when in fact, it only had 1 (its owner,
Individual 4);
c. Company 4 was in operation on February 15, 2020, when in fact, it had not
conducted any business in 2020 and had no employees;
d. Company 4 had employees for whom it paid salaries and payroll, when in
fact, it only had 1 employee-its owner, Individual 4;

12
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e. The payroll summary submitted in support of Company 4's PPP-Loan
application ("Company 4' s Payroll Summary") was true and accurate, when
in fact, it was not;
f. As reflected in Company 4's Payroll Summary, in 2019, Company 4 had
paid total wages of $175,381.75, when in fact, Company 4 had only
completed one job in 2019 for $3,000 and had not paid such wages;
g. As reflected in Company 4's Payroll Summary, in 2019, employee M.W.
had been paid $30,168.76 in wages, when in fact, he had only worked for
Company 4 a single week and was not paid that amount in wages; and
h. As reflected in the IRS Form 940 and 941s submitted in support of
Company 4's PPP-Loan application, in 2019, Company 4 had paid
$175,587 in salaries to employees, when in fact, it had not.
Company S's EIDL-Loan Application:
55. On or about July 3, 2020, on behalf of Company 5, defendant SINJU
completed and submitted an application to the SBA for an EIDL Loan in the amount of
$67,200.
56. In execution and furtherance of the scheme and artifice to defraud,
defendant SINJU made, or caused to be made, the following false and fraudulent
representation to the SBA:
a. In 2019, Company 5 had gross receipts (revenues) of $168,362, when in
fact, the company's revenues did not exceed $14,000.
57. All of the above-referenced EIDL-Loan applications which were submitted
on behalf of Company 1, Company 2, Company 3, Company 4, and Company 5 were
submitted through a server located in West Des Moines, Iowa.
Ill
I II

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COUNTS 1-4
18 u.s.c. § 1014)
(False Statement to a Bank)
58. The allegations set forth above are incorporated herein by reference and
realleged as though fully set forth in these Counts.
59. Beginning around June 5, 2020 and continuing in and through at least June
15, 2020, in the District of Utah and elsewhere, the defendant,
PETER N. SINJU,

knowingly made, and caused to be made, false statements listed above for the purpose of

influencing the action of First Utah Bank, a bank the deposits of which were insured by

the Federal Deposit Insurance Corporation, in connection with four separate PPP-Loan

applications for a total of approximately $135,000, in that defendant SINJU made and

caused to be made false statements in the following PPP-Loan applications:

COUNT DATE PPP-LOAN APPLICATIONS WITH FALSE
(on or about) STATEMENTS IN THEM

1 615120 PPP-Loan Application No. -7800 submitted to First Utah
Bank on behalf of Company 1 (for approximately $41,700).
2 6/11/20 PPP-Loan Application (Number not assigned) submitted to
First Utah Bank on behalf of Company 2 (for approximately
$20,800).
3 6/15120 PPP-Loan Application No. -7027 submitted to First Utah
Bank on behalf of Company 3 ( for approximately $36,100)
4 6/15120 PPP-Loan Application No. (Not Assigned) submitted to
First Utah Bank on behalf of Company 4 (for approximately
$36,400)

All in violation of 18 U.S.C. § 1014.

Ill

I II

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COUNTS 5-9
18 u.s.c. § 1343)
(Wire Fraud)
60. The allegations set forth above are incorporated herein by reference and
realleged as though fully set forth in these Counts.
61. Beginning around June 2, 2020 and continuing in and through at least July
3, 2020, in the District of Utah and.elsewhere, the defendant,
PETERN. SINJU,

having devised and intended to devise a scheme and artifice to defraud, and for obtaining

money and property from the SBA, by means of false and fraudulent pretenses,

representations, promises, and omissions of material facts, for the purpose of executing

said scheme and artifice to defraud, caused the following representative items to be

transmitted by means of wire communication in interstate commerce described below for

each count, each transmission constituting a separate count:

COUNT DATE INTERSTATE WIRE COMMUNICATIONS
(on or about)
5 6/2/20 Purportedly on behalf of a Utah business (Company 1),
SINJU caused to be submitted EIDL-Loan Application No.
33xxxx2407 (for an approximately $79,297.50 EIDL Loan)
through a server located in West Des Moines, Iowa.
6 6/9/20 Purportedly on behalf of a Utah business (Company 2),
SINJU caused to be submitted EIDL-Loan Application No.
33xxxx5357 (for an approximately $50,600 EIDL Loan)
through a server located in West Des Moines, Iowa. The
EIDL-Loan payment for this loan was then initiated and
processed through servers in Colorado and Virginia.
7 6/9/20 Purportedly on behalf of a Utah business (Company 3),
SINJU caused to be submitted EIDL-Loan Application No.
33xxxx6260 (for an approximately $81,000 EIDL Loan)
through a server located in West Des Moines, Iowa. The
EIDL-Loan payment for this loan was then initiated and
processed through servers in Colorado and Virginia.

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8 6/10/20 Purportedly on behalf of a Utah business (Company 4),
SINJU caused to be submitted EIDL-Loan Application No.
33xxxx8124 (for an approximately $48,000 EIDL Loan)
through a server located in West Des Moines, Iowa. The
EIDL-Loan payment for this loan was then initiated and
processed through servers in Colorado and Virginia.
9 7/3/20 Purportedly on behalf of a Utah business (Company 5),
SINJU caused to be submitted EIDL-Loan Application No.
33xxxx6373 (for an approximately $67,200 EIDL Loan)
through a server located in West Des Moines, Iowa.

All in violation of 18 U.S.C. § 1343.

NOTICE OF INTENT TO SEEK FORFEITURE

Pursuant to 18 U.S.C. § 981(a)(l)(C) and 28 U.S.C. § 2461(c), upon conviction of

any offense violating 18 U.S.C. § 1014, the defendant(s) shall forfeit to the United States

of America any property, real or personal, that constitutes or is derived from proceeds

traceable to the scheme to defraud. The property to be forfeited includes, but is not

limited to:

■ A money judgment equal to the value of any property not available for

forfeiture as a result of any act or omission of the defendant(s) for one or more

of the reasons listed in 21 U.S.C. § 853(p).

■ Substitute property as allowed by 28 U.S.C. § 2461(c) and 21 U.S.C. § 853(p).

Pursuant to 18 U.S.C. § 98l(a)(l)(C) and 28 U.S.C. § 2461(c), upon conviction of

any offense violating 18 U.S.C. § 1343, the defendant(s) shall forfeit to the United States

of America any property, real or personal, that constitutes or is derived from proceeds

traceable to the scheme to defraud. The property to be forfeited includes, but is not

limited to:

16
Case 2:23-cr-00280-HCN Document 1 Filed 07/26/23 PageID.17 Page 17 of 17

■ A money judgment equal to the value of any property not available for

forfeiture as a result of any act or omission of the defendant(s) for one or more

of the reasons listed in 21 U.S.C. § 853(p).

• Substitute property as allowed by 28 U.S.C. § 246l(c) and 21 U.S.C. § 853(p).

A TRUE BILL:

FOREPERSON OF GRAND JURY

TRINA A. HIGGINS
United States Attorney

-~--
TODD ciiouTON
Assistant United States Attorney

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