AO 91(Rev.11/11) Criminal Complaint
- Date
- 2025-05-01
Summary
An AO 91 criminal complaint with a supporting affidavit, filed May 1, 2025 as Document 1 in United States v. Steevenson Persona, Case No. 3:25-mj-199, in the U.S. District Court for the Southern District of Ohio. The complainant, a Homeland Security Investigations special agent, charges a violation of 18 U.S.C. § 1343, wire fraud, on or about April 19, 2021 in Clark County. The affidavit describes the Paycheck Protection Program and states that records from Blue Acorn PPP LLC show an application submitted April 19, 2021 and approved by the Small Business Administration on April 29, 2021 for a $20,832 loan claiming $110,000 in 2020 business income. It sets out indicators the affiant reads as fraudulent, state tax records showing a 2020 adjusted gross income of $11,785, and an April 17, 2025 interview. The 11-page filing concludes there is probable cause and asks for an arrest warrant.
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Case: 3:25-cr-00055-MJN Doc #: 1 Filed: 05/01/25 Page: 1 of 11 PAGEID #: 1
AO 91(Rev.11/11) Criminal Complaint
UNITED STATES DISTRICT COURT
for the
Southern District of Ohio
United States of America )
V. )
) Case No. 3:25-mj-199
Steevenson Persona )
)
)
)
Defendant(s)
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of April 19, 2021 in the county of Clark in the
Southern District of Ohio , the defendant(s) violated:
Code Section Offense Description
18 u.s.c. § 1343 Wire Fraud
This criminal complaint is based on these facts:
See Attached Affidavit
Digitally signed by
!Yi Continued on the attached sheet. BRANSON T
BRANSON T YEAKLEY
YEAKLEY Date: 2025.05.01
11:00:42 -04'00'
Complainant's signature
HSI SA Branson Yeakley
Printed name and title
Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1 by
Telephone (reliable electronic means).
Date: May 1, 2025
Caroline H. Gentry
City and state: Dayton, Ohio United States Magistra
Case: 3:25-cr-00055-MJN Doc #: 1 Filed: 05/01/25 Page: 2 of 11 PAGEID #: 2
AFFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINT
I, Branson Yeakley, your Affiant, being duly sworn, depose and state that:
1. This affidavit is submitted in support of an application for an affest warrant for Steevenson
PERSONA for committing wire fraud, in violation of 18 U.S.C. § 1343, on or about April
19, 2021.
2. I have been a Special Agent (SA) for the United States government since September 2019.
I began as a SA with the Air Force Office of Special Investigations (OSI) until transfen'ing
to Homeland Security Investigations (HSI) in December 2023. As pati of my training, I
attended the Federal Law Enforcement Training Center (FLETC) Criminal Investigator
Training Program (CITP), Air Force OSI Basic Special Investigator's Course (BSIC), and
HSI Special Agent Training Program (HSISAT) where I received training in financial
crimes, including but not limited to wire fraud, federal money laundering laws, bank fraud,
and false statements in connection with government programs. I have also received
subsequent training, both formal and informal, on these types of offenses, including those
offenses described in this affidavit.
3. In my role as an OSI SA, I investigated financial crimes, including being assigned to a
government procurement fraud office. I reviewed hundreds of fraudulent Paycheck
Protection Program (PPP) applications,. gaining experience in identifying common
indicators of fraudulent applications.
4. As an HSI SA, I am a federal law enforcement officer, and my duties include the
enforcement of more than 400 federal statutes within the Dayton and Cincinnati, Ohio area.
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I continue to investigate financial crimes and fraud, including identifying fraudulent PPP
applications and presenting cases for prosecution.
5. The information set fmih below is not a complete recitation of all the facts known in this
entire investigation. Rather, it is specific information that I believe suppo1is probable cause
for the issuance of the requested arrest warrant.
FACTS IN SUPPORT OF PROBABLE CAUSE
6. 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 ceiiain other expenses. The PPP permitted
participating third-paiiy lenders to approve and disburse SBA-backed PPP loans to cover
payroll, fixed debts, utilities, rent/mmigage, 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.
7. To obtain a PPP loan, a qualifying business had to submit a PPP loan application, which
was supposed to be 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 ce1iain affirmative ce1iifications 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 or paid independent contractors. A business applying for
a PPP loan was required to provide documentation showing its payroll expenses, such as
filed federal income tax documents.
8. PPP loan applications were electronically submitted or caused to be submitted by the
borrower and received through SBA servers located in Virginia or Oregon. Once approved,
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the business received the PPP loan proceeds via an electronic funds transfer from the third-
party lender to a financial account under the control of the business.
9. The proceeds of a PPP loan could be used for ce1iain specified business related items, such
as payroll costs, costs related to the continuation of group health care benefits, or m01igage
interest payments. The proceeds of a PPP loan were not pe1mitted to be used by the
bon-owers to purchase consumer goods, automobiles, personal residences, clothing,
jewehy, to pay the bon-ower's personal federal income taxes, or to fund the bonower's
ordinaiy day-to-day living expenses umelated to the specified authorized expenses.
10. Blue Acom PPP LLC ("Blue Acom") was a lending service that among other services
worked with companies to assist businesses in accessing the Small Business
Administration's Paycheck Protection Program.
11. Over the past several months, HSI has investigated Steevenson PERSONA ("PERSONA")
for numerous potential violations of federal criminal law, including mairiage fraud, false
statements to purchase a firearm as an illegal alien, money laundering, false statements to
obtain an immigration benefits, and wire fraud.
FRAUDULENT PPP LOAN
12. In October 2024, I conducted open-source research on PERSONA, an individual who
Department of Homeland Security (DHS) records indicated was an alien from Haiti with
no lawful right to remain in the United States, who was living in Springfield, Ohio. This
research disclosed that PERSONA received a PPP loan in April 2021.
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13. On October 31, 2024, I served a customs summons 1 to Blue Acom for records associated
with PERSONA's PPP loan application. On November 4, 2024, Blue Acorn responded to
the summons, which disclosed the following notable info1mation:
a. PERSONA's PPP loan application was created on April 18, 2021, and submitted
on April 19, 2021. The SBA approved this application on April 29, 2021, granting
him a $20,832 PPP loan. 2
b. PERSONA's application listed his personal information as well as contact
information, including his email address, phone number, and home address as:
personasteeve@gmail.com, 937-250-8615, and 433 Neosha Ave, Springfield,
Ohio.
c. PERSONA claimed he was an independent contractor established June 12, 2019,
and he used the NAICS code indicating he claimed to be a "Driver" (Uber, Lyft,
Ride Share, Taxi, Taxicab, Cab etc).
d. PERSONA claimed his business earned $110,000 in 2020 and had $37,000 in
expenses.
e. PERSONA wanted his PPP loan deposited into an account at Fifth Third Bank,
although he provided a PNC Bank statement from January 28, 2020, to Februaiy
24, 2020, as proof of his business.
1. 19 U.S.C. § 1509 provides authority for the issuance of customs summons for ensuring compliance with the laws
of the United States administered by the United States Customs Service (USCS). Subsequent organizational
changes, including section 403(1) of the Homeland Security Act of 2002, dissolved the uses and extended the
authority to issue these custom summonses to HSI.
2. In general, the amount of a PPP loan an independent contractor with no employees was eligible for was based
on the claimed income in 2019 or 2020, up to a maximum of approximately $100,000 in income, which resulted in
a PPP loan of approximately $20,832.
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f. Blue Acom used a service by Onfido3 to verify PERSONA's identity, in which
PERSONA was required to upload a picture of his Ohio ID card and provide a selfie
of himself. I reviewed the identification card and selfie, and based on my
experience with Onfido and Ohio identification, as well as a review of images of
PERSONA, they appeared consistent with PERSONA taking a selfie of himself
and a picture of his ID, and they did not appear to be fake.
14. As paii of his application, PERSONA was required to digitally sign a document (SBA
Form 2483-C) which stated, "I further ce1iify that the information provided in this
application and the information provided in all supp01iing documents and forms is true and
accurate in all material respects. I understand that knowingly making a false statement to
obtain a guaranteed loan from SBA is punishable under the law, including under 18 U.S.C.
1001 and 3571 by imprisonment of not more than five years and/or a fine ofupto $250,000;
under 15 U.S.C. 645 by imprisonment of not more than two years and/or a fine of not more
than $5,000; and, if submitted to a federally insured institution, under 18 U.S.C. 1014 by
imprisonment of not more than thirty years and/or a fine of not more than $1,000,000." As
a part of this fo1m, PERSONA certified:
a. The Applicant was in operation on February 15, 2020, has not permanently closed,
and was either an eligible self-employed individual, independent contractor, or sole
proprietorship with no employees, or had employees for whom it paid salaries and
payroll taxes or paid independent contractors, as rep01ied on Form(s) 1099-MISC.
3. Onfido is a technology company that helps businesses verify people's identities using a photo-based identity
document, a selfie, and artificial intelligence algorithms.
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b. The funds will be used to retain workers and maintain payroll; or make payments
for mmigage interest, rent, utilities, covered operations expenditures, covered
prope1iy damage costs, covered supplier costs, and covered worker protection
expenditures as specified under the Paycheck Protection Program Rules; 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.
c. In 2020, PERSONA earned a gross income of $110,000 from his business.
15. Based on my training and experience, PERSONA's loan had several indicators that it was
fraudulent on its face, including but not necessarily limited to:
a. The uploaded PNC Bank statement had minimal transactions and did not appear to
be consistent with a driving business in operation since 2019.
b. Blue Acorn PPP used a service from Plaid to receive the balance of two of
PERSONA's accounts, which were $44.05 and $0.46. This low balance is not
consistent with a business earning $110,000 in revenue a year.
c. The revenue of $110,000 was likely chosen in pmi to maximize the loan
amount. This revenue amount is extremely unlikely for a ride share or taxi driver,
especially in Springfield, Ohio, where the per capita income for this time frame was
well under $40,000.
d. If a person did in fact make $110,000 in revenue as a ride share driver in
Springfield, Ohio (such as by working 10+ hours all 365 days), they would almost
ce1iainly have much more than $27,000 in vehicle expenses.
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16. On or about March 19, 2025, the Ohio Department of Taxation responded to a grand jury
subpoena for records associated with PERSONA, which disclosed the following notable
inf01mation:
a. PERSONA did not file an Ohio individual state tax return for 2019.
b. PERSONA's 2020 return was filed listing himself as a single resident of Ohio, with
a home address located at 433 Neosha Ave, Springfield, Ohio. He claimed a federal
adjusted gross income (AGI) of $11,785, coming from W-2's from Amazon.com
Services LLC and Employbridge LLC. He had no deductions from his federal AGI
for state tax purposes. 4
c. His 2020 state refund was sent to the same Fifth Third Bank account that his PPP
loan was sent to. 5
17. On April 17, 2025, I interviewed PERSONA in a non-custodial setting. He provided the
following statements:
a. PERSONA worked as a taxi driver for "just a couple months" in 2020 or 2021. He
stated he could not recall the amount he earned over the couple of months, but that
it was not a lot of money.
b. PERSONA confirmed he received a PPP loan for $20,832.
c. PERSONA confirmed he remembered applying for this loan.
4. In Ohio, it is common for small businesses to be able to deduct some or all business income from state tax. The
lack of a deduction indicated that he likely did not have business income.
5. This confirmed that this Fifth Third Bank account did in fact belong to PERSONA, and the loan was not the result
of identity theft.
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d. PERSONA confirmed it was his information in the loan application, including
email address, phone number, and address.
e. Somebody helped PERSONA with his PPP loan application, but this person was in
Florida and PERSONA could not remember his name.
f. When asked if he earned $110,000 in 2020 from being a taxi driver, PERSONA
replied, "I am not sure it was that much." I then asked PERSONA to estimate his
taxi earnings for 2020, and PERSONA stated he was working a job at the time too,
and if you added them together with his taxi income, it "should be" $110,000, and
then stated it "might be" that amount.
18. At this point in the interview, I reminded PERSONA that it was a voluntary interview that
he could terminate at any time. I also provided an admonishment to PERSONA that 18
U.S. Code § 1001 made it a federal offense to lie to a federal agent. I again asked him
questions regarding his PPP application. When asked if PERSONA earned $110,000 in
2020 from being a taxi driver, PERSONA stated he did not earn that amount as a taxi
driver, but that it might be what he earned "in general." I then asked PERSONA to confirm
statements, and he made affirmative sounds or head nods that: PERSONA applied for a
PPP loan through Blue Acorn, he told Blue Acom that he had a taxi-cab business, and he
told Blue Acorn this business had $110,000 in revenue in 2020. PERSONA then tried to
claim that these were tlue statements, but he stated the person who helped him with the
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application asked for his W2' s and how much he made on his taxis and added them together
to equal that. 6
19. Based on my training and experience, including previous investigation of PPP loan fraud
involving Blue Acorn, as well as the facts learned in this investigation, in the process of
obtaining this money (the $20,832 PPP loan) by means of false or fraudulent pretenses,
representations, or promises, there is probable cause PERSONA transmitted or caused to
be transmitted by means of wire or radio communication in interstate or foreign commerce
writings, signs, signals, pictures, and/or sounds, including but not necessarily limited to:
a. Blue Acorn utilized computer servers / data centers in the state of Virginia, as part
of conducting nationwide business operations. When signing into the PPP loan
application, PERSONA (or the person assisting him with the loan application)
would have sent wire communications back and forth between the Blue Acorn
servers in Virginia and PERSONA in Ohio and/or his helper in Florida.
b. Fmiher, although Blue Acom assisted in processing for this loan, the actual lender
was Capital Plus Financial, which is located in Texas. PERSONA would have
caused wires to be sent in communication to and from Blue Acom in Virginia and
Capital Plus Financial in Texas.
c. When a person uses Blue Acorn to apply for a PPP loan, Blue Acom sends emails
and text messages to the accounts listed on the application, including status updates
on the account. PERSONA confirmed these were his accounts, so they would have
6. As shown above from the Ohio Department of Taxation, PERSONA's W2 income in 2020 was negligible
compared to the claimed income. This is especially not plausible when combined with PERSONA's statement that
he worked as a taxi driver for "just a couple months."
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been received on his device(s) located in Ohio, and these wires would have been
sent in interstate commerce from Blue Acorns servers outside of Ohio, through
Google's servers located in various states, to atTive at his device(s) in Ohio.
CONCLUSION
20. Based on the foregoing, there is probable cause to believe that PERSONA has committed
a violation of 18 U.S.C. § 1343, Wire Fraud, and I request that an arrest wairnnt be issued
to bring PERSONA before this Court based on the allegations contained herein.
I declare under penalty and pe1jury that the foregoing is true and conect to the best of my
lmowledge. Digitally signed by
BRANSON T BRANSON T YEAKLEY
Date: 2025.05.01 11:00:16
YEAKLEY -04'00'
Branson Trey Yeakley, Special Agent,
Homeland Security Investigations
Subscribed and Sworn to me via reliable electronic means (telephone) on this _ _ day of
1st
May, 2025.
Caroline H. Gentry
United States Magistra
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