Information — United States v. Yani Stancioff (District of Maine)

Summary

A criminal information filed December 3, 2024 in United States v. Yani Stancioff, Case 2:24-cr-00138-LEW, in the U.S. District Court for the District of Maine. It alleges that from about June 23, 2020 to about September 10, 2021 Stancioff caused false EIDL advance and PPP applications to be submitted, claiming an agriculture business and gross income from a sole proprietorship, and later false loan forgiveness applications. The information lists an EIDL advance of $10,000 and PPP applications of $20,833 on April 18, 2021 and May 28, 2021, and states Stancioff received approximately $51,666. Count One charges wire fraud under Title 18, United States Code, Sections 1343 and 2, and the forfeiture notice seeks a money judgment in the amount of the proceeds.

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“Information — United States v. Yani Stancioff (District of Maine).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/1-information-as-to-yani-stancioff-1-count-s-1-clp-modified-on-10a982aebf/, SHA-256 b0f1d7c87d446fe51a582a153646766d48422d94e9a1331d2b90f68e7ccc5bc2.

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Case 2:24-cr-00138-LEW Document 1 Filed 12/03/24 Page 1 of 7 PageID #: 1

UNITED STATES DISTRICT COURT
DISTRICT OF MAINE

UNITED STATES OF AMERICA

v. No. 2:24-

YANI STANCIOFF

INFORMATION

The United States Attorney charges:

General Allegations

At times relevant to this Information:

1. The defendant resided in Portland, Maine, in the District of Maine.

2. The Paycheck Protection Program (“PPP”) was a COVID-19

pandemic relief program administered by the Small Business Administration

(“SBA”) that provided forgivable loans to small businesses for job retention and

certain other expenses. The PPP 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 were

fully guaranteed by the SBA.

3. To obtain a PPP loan, a qualifying business had 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 to be eligible to obtain the PPP loan, including that the business was

in operation and either had employees for whom it paid salaries and payroll taxes
Case 2:24-cr-00138-LEW Document 1 Filed 12/03/24 Page 2 of 7 PageID #: 2

or paid independent contractors. A business applying for a PPP loan was required

to provide documentation showing its payroll expenses.

4. The proceeds of a PPP loan could be used 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 pay personal expenses unrelated to the

specified authorized expenses.

5. The Economic Injury Disaster Loan (“EIDL”) program was an SBA

program providing low-interest financing to small businesses, renters, and

homeowners affected by declared disasters. The Coronavirus Aid, Relief, and

Economic Security Act (“CARES Act”) authorized the SBA to provide EIDLs of up

to $2 million to eligible small businesses experiencing substantial financial

disruptions due to the COVID-19 pandemic. In addition, the CARES Act and

subsequent legislation authorized the SBA to issue advances of up to $10,000 to

small businesses within three days of applying for an EIDL.

6. In order to obtain an EIDL and advance, a qualifying business was

required to submit an application to the SBA and provide information about its

operations, such as the number of employees, gross revenue 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 EIDLs for COVID-19 relief, the 12-month

period was the period preceding January 31, 2020. For a business to be eligible

for an EIDL, the business must have been in operation before February 1, 2020.

2
Case 2:24-cr-00138-LEW Document 1 Filed 12/03/24 Page 3 of 7 PageID #: 3

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.

7. All EIDL applications were submitted online. Upon approval of an

application for an EIDL or advance, SBA would disburse the funds.

The Scheme and Artifice

8. Beginning on about June 23, 2020, and continuing to about

September 10, 2021, in the District of Maine and elsewhere, the Defendant,

YANI STANCIOFF,

knowingly and willfully devised and intended to devise a scheme and artifice to

defraud, and to obtain money and property by means of materially false and

fraudulent pretense, representations and promises.

Manner and Means

9. The manner and means by which the defendant sought to

accomplish the scheme and artifice included, among others, the following:

a. The defendant caused to be prepared and submitted PPP loan

applications and an EIDL advance application that included

materially false and fraudulent representations and pretenses,

such as:

i. False statements on an EIDL advance application that

the defendant owned a business in the agriculture

industry and that the supposed business employed 12

3
Case 2:24-cr-00138-LEW Document 1 Filed 12/03/24 Page 4 of 7 PageID #: 4

people;

ii. False statements on an EIDL advance application about

his supposed business’s gross revenue;

iii. False statements on the PPP application about the

defendant’s gross income from a supposed sole

proprietorship;

iv. False statements that the PPP loan proceeds were

necessary to support payroll and other specified items

approved under the PPP;

v. Affirming under penalty of perjury that the statements

in the applications were true and correct.

b. The defendant caused to be prepared and submitted false and

fraudulent IRS documents in support of the PPP applications;

c. The defendant caused to be prepared and submitted false loan

forgiveness applications for his PPP loans.

10. As part of the scheme, the defendant caused to be filed the following

EIDL and PPP loan applications:

APPROXIMATE APPLICATION APPROXIMATE
DATE TYPE APPLICATION
AMOUNT
June 23, 2020 EIDL $10,000
ADVANCE
April 18, 2021 PPP $20,833

4
Case 2:24-cr-00138-LEW Document 1 Filed 12/03/24 Page 5 of 7 PageID #: 5

May 28, 2021 PPP $20,833

11. Stancioff received approximately $51,666 as a result of the above

referenced applications. The funds were deposited electronically into bank

accounts Stancioff controlled.

COUNT ONE
Wire Fraud

12. Paragraphs 1 – 11 and all subparts are incorporated herein.

13. On about the dates specified below, in the District of Maine and

elsewhere, the defendant,

YANI STANCIOFF

having devised and intending to devise a scheme to defraud, and to obtain money

and property by means of materially false and fraudulent pretenses,

representations, and promises, did transmit and cause to be transmitted by

means of wire communications in interstate commerce, writings, signs, signals,

pictures, and sounds for the purpose of executing the scheme to defraud, as set

forth below:

DATE DESCRIPTION

June 29, 2020 Electronic fund transfer of $10,000 from the SBA into a bank
account held by Yani Stancioff.
May 5, 2021 Electronic fund transfer of $20,833 of PPP funds into a bank
account controlled by Yani Stancioff.
June 25, 2021 Electronic fund transfer of $20,833 of PPP funds into a bank
account controlled by Yani Stancioff.

5
Case 2:24-cr-00138-LEW Document 1 Filed 12/03/24 Page 6 of 7 PageID #: 6

Thus, the Defendant violated Title 18, United States Code, Sections 1343

and 2.

FORFEITURE NOTICE

1. Upon conviction of the offense alleged in Count One of this

Information, charging a violation of 18 U.S.C. § 1343, the defendant shall forfeit

to the United States, pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c),

any property, real or personal, constituting or derived from proceeds traceable to

the offense and, pursuant to 18 U.S.C. § 982(a)(2), any property constituting, or

derived from, proceeds obtained directly or indirectly as the result of the offense.

The property to be forfeited includes, but is not limited to, a money judgment in

the amount of those proceeds and property derived from those proceeds.

2. If any of the property described in Paragraph 1, above, as being

forfeitable pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c), and

pursuant to 18 U.S.C. § 982(a)(2), 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;

it is the intention of the United States, pursuant to 28 U.S.C. § 2461(c) and 18

6
Case 2:24-cr-00138-LEW Document 1 Filed 12/03/24 Page 7 of 7 PageID #: 7

U.S.C. § 982(b)(1), incorporating 21 U.S.C. § 853(p), to seek forfeiture of any

other property of the defendant up to the value of the property described in

paragraph 1 above.

All pursuant to Title 18, United States Code, Section 981(a)(1)(C), and

Title 28, United States Code, Section 2461(c), and Title 18, United States Code,

Section 982(a)(2).

Dated this 3rd day of December, 2024, in Portland, Maine.

Respectfully submitted

Darcie N. McElwee
United State Attorney

_______________
Sean M. Green
Assistant United States Attorney

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