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Superseding Information — United States v. Nii A. Tei (Southern District of Ohio)

Summary

A Superseding Information filed April 11, 2024 as Doc #: 54 in United States of America versus Nii A. Tei, Case No. 1:22-CR-00078, in the United States District Court for the Southern District of Ohio, Western Division. Count 1 charges structuring transactions to evade reporting requirements under 31 U.S.C. § 5324(a)(3). It states that between on or about August 17, 2020 and August 27, 2020, Tei structured cash deposits at PNC Bank in Cincinnati, Ohio, each listed as Paycheck Protection Program proceeds, in amounts of $5,000, $3,000 and $2,600. The forfeiture allegation seeks proceeds under 31 U.S.C. § 5317 and substitute assets under 21 U.S.C. § 853(p).

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“Superseding Information — United States v. Nii A. Tei (Southern District of Ohio).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/54-superseding-information-as-to-nii-a-tei-1-count-s-1s-and-for-b16ba8aa72/, SHA-256 a2b6b7049254e4230de56006ca59aeee2fac383392878f0bdaad7f993e9b532e.

Full text

     Case: 1:22-cr-00078-SJD Doc #: 54 Filed: 04/11/24 Page: 1 of 2 PAGEID #: 156


                              UNITED STATES DISTRICT COURT
                               SOUTHERN DISTRICT OF OHIO
                                   WESTERN DIVISION

 UNITED STATES OF AMERICA,
                                                        CASE NO. 1:22-CR-00078
                 Plaintiff,
                                                        JUDGE DLOTT
        v.
                                                        SUPERSEDING INFORMATION
 NII A. TEI,
                                                        31 U. S. C. § 5324(a)(3)
                 Defendant.

THE UNITED STATES ATTORNEY CHARGES:

                                           COUNT 1
                  (Structuring Transactions to Evade Reporting Requirements)

       Between on or about August 17, 2020 and August 27, 2020, in the Southern District of Ohio

and elsewhere, the defendant, NII A. TEI, knowingly and for the purpose of evading the reporting

requirements imposed upon domestic financial institutions, did structure, attempt to structure, and

assist in structuring the following U.S. currency transactions at PNC Bank in Cincinnati, Ohio:

       Date          Transaction        Amount           Nature of Transaction

       8/17/20       Cash Deposit            $5,000       Paycheck Protection Program proceeds

       8/18/20       Cash Deposit            $5,000       Paycheck Protection Program proceeds

       8/20/20       Cash Deposit            $3,000       Paycheck Protection Program proceeds

       8/24/20       Cash Deposit            $2,600       Paycheck Protection Program proceeds

       8/25/20       Cash Deposit            $5,000       Paycheck Protection Program proceeds

       8/27/20       Cash Deposit            $5,000       Paycheck Protection Program proceeds

       All in violation of 31 U.S.C. § 5324(a)(3).
     Case: 1:22-cr-00078-SJD Doc #: 54 Filed: 04/11/24 Page: 2 of 2 PAGEID #: 157


                                  FORFEITURE ALLEGATION

       Upon conviction of the offense set forth in Count 1 of this Superseding Information, the

defendant, NII A. TEI, shall forfeit to the United States, pursuant to 31 U.S.C. § 5317, any property

constituting, or derived from, proceeds obtained directly or indirectly, as a result of such violation.


                                       SUBSTITUTE ASSETS

       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,

it is the intent of the United States, pursuant to 21 U.S.C. § 853(p), as incorporated by 31 U.S.C.

§ 5317(c) and 28 U.S.C. § 2461(c), to seek forfeiture of any other property of the defendant, up to the

value of the property described above.



                                               KENNETH L. PARKER
                                               UNITED STATES ATTORNEY



                                               EBUNOLUWA A. TAIWO
                                               Assistant United States Attorney




                                                  2

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