Adedayo Ilori; Chris Recamier — Indictment, Southern District of New York

Summary

An indictment in the United States District Court for the Southern District of New York charging Adedayo Ilori and Chris Recamier with six counts over PPP and EIDL loan applications from at least August 2020 through October 2021. The grand jury charges that the defendants sought loans for companies they did not operate, claiming more than 230 employees and $3.2 million in monthly wages, using stolen identities and forged tax filings, obtained more than $1 million and attempted about $6.5 million more. The counts are major fraud against the United States (18 U.S.C. § 1031), conspiracy to commit wire and bank fraud (§ 1349), wire fraud (§ 1343), bank fraud (§ 1344), aggravated identity theft (§ 1028A) and conspiracy to commit money laundering (§ 1956(h)), with forfeiture allegations; it is signed by United States Attorney Damian Williams.
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA

- Ve. 7 ‘ INDICTMENT
ADEDAYO ILORI and 21 Cr.
CHRIS RECAMIER, :

Defendants.
COUNT ONE

(Major Fraud Against the United States)
Overview

The Grand Jury charges:

1. From at least in or about August 2020 through at least
in or about October 2021, ADEDAYO ILORI and CHRIS RECAMIER, the
defendants, and others known and unknown engaged in a scheme to
obtain and attempt to obtain Government, or Government-guaranteed,
loans through loan programs of the United States Small Business
“Administration {the ‘“SBA”) designed to provide relief to small
businesses during the novel coronavirus/COVID-19 pandemic, namely
the Paycheck Protection Program (the “PPP”) and the Economic Injury
Disaster Loan (“ETDL”) Program. In applying for these loans,
ILORI and RECAMIER fraudulently obtained more than $1 million in
PPP and EIDL funds, and they attempted to obtain more than an

additional approximately $6.5 million in PPP and EIDL funds.
2. In the course of the scheme, ADEDAYO ILORI and CHRIS
RECAMIER, the defendants, sought loans for companies purportedly
controlled by ILORI and RECAMIER (the “Companies”). ILORI and
RECAMIER submitted information representing that these Companies
together had more than 230 employees and paid a total of
approximately $3.2 million in wages to those employees on a monthly
basis. In truth and in fact, ILORI and RECAMIER operated no such
companies. In submissions to lenders, among other things, ILORI
and RECAMIER used the stolen identities of unrelated third parties,
and submitted false and forged tax filings, in order to seek the
fraudulent loans.

3. ADEDAYO: ILORI and CHRIS RECAMIER, the defendants, used
the proceeds from their fraud scheme toward among other things:

(a) hundreds of thousands of dollars in cryptocurrency

investments; (b) hundreds of thousands of dollars in stocks; —
(c) cash withdrawals; and (d) personal expenses. TLORI and

RECAMIER utilized the stolen identities of identity theft victims
in order to establish the cryptocurrency and other investment
accounts to which they directed fraud proceeds.

Statutory Allegations

4, From at least in or about August 2020 through at least
in or about October 2021, in the Southern District of New York and
elsewhere, ADEDAYO ILORI and CHRIS RECAMIER, the defendants, and

others known and unknown, willfully and knowingly executed, and
attempted to execute, a scheme and artifice with the intent to
defraud the United States, and to obtain money and property by
means of false and fraudulent pretenses, representations, and
promises, in a grant, contract, subcontract, subsidy, loan,
guarantee, insurance, and other form of Federal assistance,
including through an economic stimulus, recovery and rescue plan
provided by the Government, the value of which was $1,000,000 and
more, to wit, ILORI and RECAMIER engaged in a scheme to obtain, by
means of false and fraudulent pretenses, representations, and
documents, more than $7 million in Government-guaranteed loans for
the Companies, through loan programs of the SBA designed to provide
relief to small businesses during the novel coronavirus/COVID-19
pandemic, namely the PPP and the BIDL Programs.

(Title 18, United States Code, Sections 1031 and 2.)

COUNT TWO
(Conspiracy to Commit Wire and Bank Fraud)

The Grand Jury further. charges:

5. The allegations set forth in paragraphs 1 to 3 are
repeated and realleged, and incorporated by reference as if fully
set forth herein.

6. From at least in or about August 2020 through at least
in or about October 2021, in the Southern District of New York and
elsewhere, ADEDAYO ILORI and CHRIS RECAMIER, the defendants, and
others known and unknown, willfully and knowingly, combined,

conspired, confederated, and agreed together and with each other
to commit: (a) wire fraud, in violation of Title 18, United States
Code, Section 1343; and (b) bank fraud, in violation of Title 18,
United States Code, Section 1344.

7. It was a part and an object of the conspiracy that
ADEDAYO ILORI and CHRIS RECAMIER, the defendants, and others known
and unknown, willfully and knowingly, having devised and intending
to devise a scheme and artifice to defraud and for obtaining money
and property by means of false and fraudulent pretenses,
representations, and promises, would and did transmit and cause to
be transmitted by means of wire, radio, and television
communication in interstate and foreign commerce, writings, signs,
signals, pictures, and sounds for the purpose of executing such
scheme and artifice, in violation of Title 18, United States Code, |
Section 1343, to wit, ILORI, RECAMIER, and others known and
unknown, engaged in a scheme to fraudulently obtain Government-
guaranteed loans for the Companies from the SBA and financial
institutions through the PPP and EIDL Programs, by making false
statements and submitting fraudulent documents in support of loan
applications, including through electronic communications
transmitted into and out of the Southern District of New York.

8. It was further a part and an object of the conspiracy
that ADEDAYO ILORI and CHRIS RECAMIER, the defendants, and others
known and unknown, willfully and knowingly, would and did execute |

and attempt to execute, a scheme and artifice to defraud a
financial institution, the deposits of which were then insured ‘by
the Federal Deposit Insurance Corporation, and to obtain moneys,
funds, credits, assets, securities, and other property owned by,
and under the custody and control of, such financial institution,
by means of false and fraudulent pretenses, representations, and
promises, in violation of Title 18, United States Code, Section
1344, to wit, ILORI, RECAIMER, and others known and unknown,
engaged in a scheme to obtain, by means of false and fraudulent
pretenses, representations, and documents, Government-guaranteed
loans for the Companies through the PPP and EIDL Programs from
banks insured by the Federal Deposit Insurance Corporation
(“FDIC”).
(Title 18, United States Code, Section 1349.)

COUNT THREE
(Wire Fraud)

The Grand Jury further charges:

9, The allegations set forth in paragraphs 1 to 3 are
repeated and realleged, and incorporated by reference as if fully
set forth herein.

10. From at least in or about August 2020 through at least
in or about October 2021, in the Southern District of New York and
elsewhere, ADEDAYO ILORI and CHRIS RECAMIER, the defendants,
having devised and intending to devise a scheme and artifice to
defraud, and for obtaining money and property by means of false

and fraudulent pretenses, representations, and promises, knowingly
transmitted and caused to be transmitted by means of wire, radio,
and television communication in interstate and foreign commerce,
writings, signs, signals, pictures, and sounds, for the purpose of
executing such scheme and artifice, which affected a financial
institution, to wit, ILORI and RECAMIER engaged in a scheme to
fraudulently obtain Government-guaranteed loans for the Companies
from the SBA and financial institutions through the PPP and EIDL
Programs, by making false statements and submitting fraudulent
documents in support of loan applications, including through
electronic communications transmitted into and out of the Southern
District of New York.
(Title 18, United States Code, Sections 1343 and 2.)

COUNT FOUR
(Bank Fraud)

The Grand Jury further charges:

11. The allegations set forth in paragraphs 1 to 3 are
repeated and realleged, and incorporated by reference as if fully
set forth herein.

12. From at least in or about August 2020 through at least
in or about October 2021, in the Southern District of New York and
elsewhere, ADEDAYO ILORI and CHRIS RECAMIER, the defendants,
willfully and knowingly executed, and attempted to execute, a
scheme and artifice to defraud a financial institution, the

deposits. of which were insured by the FDIC, and to obtain moneys,

funds, credits, assets, securities, and other property owned by,
and under the custody and control of, such financial institution,
by means of false and fraudulent pretenses, representations and
promises, to wit, ILORI and RECAMIER engaged in a scheme to obtain,
by means of false and fraudulent pretenses, representations, and
documents, Government-guaranteed loans for the Companies through
the PPP and EBIDL Programs from FDIC-insured banks.

(Title 18, United States Code, Sections 1344 and 2.)

COUNT FIVE
(Aggravated Identity Theft)

The Grand Jury further charges:

13. The allegations set forth in paragraphs 1 to 3 are
repeated and realleged, and incorporated by reference as if fully
set forth herein.

14. From at least in or about August 2020 through at least
in or about October 2021, ADEDAYO ILORI and CHRIS RECAMIER, the
defendants, knowingly did transfer, possess, and use, without
lawful authority, a means of identification of another person,
during and in relation toa felony violation enumerated in Title
18, United States Code, Section 1028A(c), “to wit, ILORI and
RECAMIER used the names and identities of multiple real people in
connection with the submission of fraudulent loan applications and
supporting documentation to multiple financial institutions during

and in relation to the fraud offenses charged in Counts One through
Four of this Indictment.

(Title 18, United States Code, Sections 1028A(a) (1), (b) &
(c) (4)-(5), and 2.)

COUNT SIX
(Conspiracy to Commit Money Laundering)

The Grand Jury further charges:

15. The allegations set forth in paragraphs 1 to 3 are
repeated and realleged, and incorporate by reference as if fully
set forth herein.

16. From at least in or about August 2020, through at least
“in or about October 2021, ADEDAYO ILORI and CHRIS RECAMIER, the
defendants, and others known and unknown, intentionally and
knowingly combined, conspired, confederated and agreed together
and with each other to commit money laundering, in violation of
Title 18, United States Code, Section 1956 (a) (1) (B) (i).

17. It was a part and an object of the conspiracy that
ADEDAYO ILORI and CHRIS RECAMIER, the defendants, and others known
and unknown, knowing that the property involved in certain
financial transactions represented the proceeds of some form of
unlawful activity, would and did conduct and attempt to conduct
such financial transactions, which in fact involved the proceeds
of specified unlawful activity, to wit, the wire and bank fraud
offenses charged in Counts and Two through Four of this Indictment,
knowing that the transactions were designed in whole or in part to

conceal and disguise the nature, the location, the source, the
ownership, and the control of.the proceeds of specified unlawful
activity, in violation of Title 18, United States Code, Section
1956(a) (1) (B) (i).

(Title 18, United States Code, Section 1956(h).)

FORFEITURE ALLEGATIONS

18. As the result of committing the offenses charged in
Counts Two through Four of this Indictment, ADEDAYO ILORI and
CHRIS RECAMIER, the defendants, shall forfeit to the United
States, pursuant to Title 18, United States Code, Section
982(a) (2) (A), any and all property constituting, or derived
from, proceeds obtained directly or indirectly, as a result of
the commission of said offenses, including but not limited to a
sum of money in United States currency representing the amount
of proceeds traceable to the commission of said offenses and the
following specific property: |

a. The Coinbase Account associated with User ID
5££910782e96e80ef6E7c88c (the “Coinbase Account”);

b. The Robinhood Markets Inc. account 698867512 (the
“Robinhood Account”); and

on the Charles Schwab One account 8743-4844 (the
“Schwab Account”).

19. As a result of committing the offense alleged in Count
‘Six of this Indictment, ADEDAYO* TLORI and CHRIS RECAMIER, the

defendants, shall forfeit to the United States, pursuant to Title
18, United States Code, Section 982(a) (1), any and all property,
real and personal, involved in said offense, or any property
traceable to such property, including but not limited to a sum of
money in United States currency representing the amount of property

involved in said offense and the following specific property:

a. The Coinbase Account;
b. The Robinhood Account; and
on The Schwab Account.

Substitute Assets Provision

20. If any of the above-described forfeitable property, as
a result of any act or omission of the defendants:.
a. cannot be located upon the exercise of due
diligence;
b. has been transferred or sold to, or deposited with,

a third person;

om 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 subdivided without difficulty;

10
it is the intent of the United States, pursuant to Title 21, United
States Code, Section 853(p), and Title 28, United States Code,
Section 2461, to seek forfeiture of any other property of the
defendants up to the value of the forfeitable property described

above.

(Title 18, United States Code, Section 982;
Title 21, United States Code, Section 853; and
Title 28, United States Code, Section 2461.)

FOREPERSON DAMIAN WILLIAMS
United States Attorney

11
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA
Vv.

ADEDAYO ILORI and
CHRIS RECAMIER,

Defendants.

INDICTMENT
21 Cr.

(18 U.S.C. §§ 1028A, 1031, 1343, 1344, 1349,
and 1956.)

DAMTAN WILLIAMS

United States Attorney

Foreperson
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