Affidavit in Support of a Criminal Complaint Charging Adewumi Abioye, Case 1:20-cr-00052 (Dkt. 1-1, D. Md.)

Summary

An affidavit by James J. Jenkins, a Special Agent with the U.S. Department of State, in support of a criminal complaint charging Adewumi Abioye with conspiracy to commit wire fraud under 18 U.S.C. Section 1349, filed January 29, 2020 as Document 1-1 in Case 1:20-cr-00052-SAG in the U.S. District Court for the District of Maryland. It states that accounts at Bank of America, JPMorgan Chase, Santander and Wells Fargo were opened for Geotric Global LLC under the alias Andrew Ali with a UK passport not issued to that identity. It describes victim payments induced by emails and text messages, and withdrawals by a man the affiant says resembles Abioye in bank surveillance images. It states that more than $500,000 was deposited based on false representations, and that the affiant has no evidence Abioye deceived the victims directly.

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JAN 29 2020

AT BALTIMORE

' CLERK, U.S. DISTRICT COURT
AFFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINT DISTRICT OF "Operon

"I, James J. Jenkins, a Special Agent with the U.S. Department of State, Diplomatic

Security Service in Baltimore, Maryland, being duly sworn, depose and state as follows:

1. INTRODUCTION

1. This affidavit is submitted in support of a criminal complaint charging Adewumi
ABIOYE (“ABIOYE”) with conspiracy to commit wire fraud, in violation of 18 U.S.C. Section
1349. As set forth below, your affiant has probable cause to believe that ABIOYE conspired
with others known and unknown: (1) to open bank accounts using fake identities and recently
formed limited liability companies (“LLCs”); (2) to use bank accounts to receive money
obtained via fraud; and (3) to withdraw and move funds obtained by fraud.
| 2. The conspiracy operated from at least January 2019 to present. Law enforcement
has determined that multiple individuals opened numerous bank accounts using either a fake
name or a recently formed LLC, which had a fake person listed as a registered agent or
authorized member. Many of the accounts were opened using fraudulent United Kingdom
' passports. After the bank accounts were opened, the bank accounts were funded via checks,
wires, and/or ACH transfers — many of which were the result of misrepresentations to the
victims. As discussed in greater detail herein, your affiant and other agents have confirmed that
the transfers were fraudulent through interviews, bank records and/or reports to the government.
3. The Department of State Diplomatic Security Service (“DSS”) and Homeland

Security Investigations (“HSI”) in Baltimore, MD have been working on this investigation since
the summer of 2019. Your affiant and other federal agents have obtained information from
subpoenas, government records, search warrants, a consent search, interviews, surveillance, and

other investigative means.
Case 1:20-cr-00052-SAG Document 1-1 Filed 01/29/20 Page 2 of 20

4. The facts set forth in this affidavit are known to me as a result of my participation
in this investigation, from information provided to me by other law enforcement officers and
government officials, and from records, documents, and other evidence obtained during this
investigation. Since this affidavit is being submitted for the limited purpose of establishing
probable cause for a criminal complaint, I have not included each and every fact known to me
concerning this investigation, but rather those facts that 1 believe are necessary to establish
probable cause that ABIOYE committed the crime referenced above. References to dates, times,
places, and amounts are intended to be approximate. Everything set forth in this Affidavit is true
to the best of my knowledge and belief.

5. I am a Special Agent with the U.S. Department of State, Diplomatic Security
Service, and have been employed by the Department of State since September 2011. [am
currently assigned to HSI’s Document and Benefit Fraud Task Force in Baltimore, MD. This
task force investigates frauds related to documents, identities, and immigration benefits. I am
empowered under 22 U.S.C. § 2709 to obtain and serve federal arrest and search warrants.
Background on Abioye

6. ABIOYE is a Nigerian citizen who entered the U.S. in 2018 as a visitor. He
overstayed his period of admission into the U.S. and is now present in the U.S. as a visa
overstay, although he has a pending petition to adjust his status based on a 2019 marriage to a
U.S. citizen. Until November 2019, it appeared ABIOYE was residing at an address in
Randallstown, MD, but he now has moved to Owings Mills, MD.

7. Your affiant reviewed ABIOYE?’s visa application and adjudication on file with
the U.S. Department of State. Your affiant found that ABIOYE was interviewed in January

2018 with a woman named Oluwaseun Sokeye. Their visa applications state they were in a civil

2
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union/domestic partnership and the adjudicating officer made a note that they were engaged. As
noted above, ABIOYE caused paperwork to be filed with the government to change his
immigration status based on a May 2019 marriage to a U.S. citizen (not Sokeye). On multiple
occasions following this marriage, your affiant or another agent have observed a man resembling
ABIOYE driving a vehicle registered to Sokeye. As of October 2019, ABIOYE and Sokeye
had the same address on their driver’s licenses: 5 Liberty Place, Apt 10, Windsor Mill, MD.
ABIOYE’s wife, the U.S. Citizen, has a Washington, D.C. identification card and appears to live
in D.C. as your affiant has been unable to find any Maryland identification document issued to
her.
I. Probable Cause

8. Your affiant and other federal agents have evidence that in 2019, multiple
individuals, including but not limited to ABIOYE, opened numerous bank accounts using either
a fake name or the name of a recently formed limited liability company (LLC). The LLCs that
law enforcement has focused on often had a fake person listed as a registered agent or authorized
representative. Many accounts also were opened using fraudulent United Kingdom passports
with alias identities. |

9. After the bank accounts were opened, unknown and unidentified individuals’
convinced victim companies and individuals across the United States to send funds via check,
wire, and/or ACH transfer based on fraudulent misrepresentations. The individual(s) who

deceived the victims into sending money have employed a variety of fraudulent techniques,

' Based on the investigation and evidence reviewed to date, your affiant has no evidence to

suggest that ABIOYE or any others identified thus far were the fraudster directly involved in
deceiving the victims.
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including but not limited to: (a) a similar sounding email address in which the sender pretended
to be an employee of the victim company directing another employee to send money from the
company’s account; (b) a faked email - supposedly from a victim company’s vendor — providing
instructions about where to send the payment of a business expense/debt: (c) text messages sent
to an individual claiming that the victim had inherited money and asking the victim to pay a
processing fee; and (d) an email and text messages sent to a victim individual providing false
information about where to send the victim’s real estate closing payment. Agents have not
interviewed all of the victims — at times your affiant and other federal agents have relied upon
bank records, reports by other members of law enforcement, and/or reports by victims to the
FBI’s Internet Crimes Complaint Center? (“IC3”) to determine that the money sent by the victim
was unauthorized/fraudulent.

10. The victims unknowingly sent their money to accounts used by individuals
currently under investigation, including ABIOYE as well as a co-conspirator identified herein as
Person A. Based on the evidence presented in this affidavit, ABIOYE and others played a
critical role in the overall conspiracy by opening bank accounts into which the fraudulently
obtained funds were initially deposited and/or accounts into which the fraudulently obtained
money was moved. |

1]. Based on the information presented herein, your affiant submits that there is
probable cause to believe that ABIOYE used the alias Andrew Ali and the LLC Geotric Global

LLC (“Geotric”) to access fraudulently obtained funds. Similarly, your affiant has probable

2 - The IC3 is run by the Federal Bureau of Investigation. Complaints are submitted online
with an attestation that the information is true and accurate to the best of the submitter’s
knowledge with a warning regarding false information and 18 U.S.C. § 1001.
cause to believe that Person A used the names Kenneth Boulan and David Bucha and the LLCs
Bouken Services (“Bouken”) and Buchaz Crystal LLC (“Buchaz’”).

Andrew ALI / Geotric Global LLC

12. | Maryland state records show that Geotric Global LLC (“Geotric”’) was created on
March 25, 2019. Andrew Ali is the listed resident agent at 7203 Bogley Road, Unit 303,
Windsor Mill, MD 21244. - 7

13. Investigators located bank accounts for Geotric at four banks: Bank of America,
JPMorgan Chase, Santander, and Wells Fargo. Andrew Ali is the registered account holder on
the signature cards for all four accounts.

14. At Santander Bank, the Geotric account ended in 1107 (“SB 1107”). The
Santander Bank records for SB 1107 included an image of a United Kingdom of Great Britain
and Northern Ireland (“UK” +) passport purportedly issued to Andrew Ali and bearing passport
number 523865740. An investigator working at the U.S. Embassy in London verified that no
UK passport had been issued to Andrew Ali with the date of birth listed on the passport. The
number on the passport was issued to a different identity.

15. Your affiant included a copy of the image below from the passport along with
ABIOYE’s Maryland driver’s license photograph.* To your affiant, the outline of the person
depicted on the passport appears similar to ABIOYE. Your affiant also notes later in this

affidavit multiple instances in which an individual resembling ABIOYE provided what based on

3 Some banks reference a passport as “GB.” Herein those are also referred to as “UK.”
4 Your affiant is aware that ABIOYE has a newer driver’s license photograph, but I have
used this photograph throughout the affidavit because in the new license photograph ABIOYE is
not wearing eyeglasses and the glasses are distinctive and seen in bank surveillance images.

5
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your affiant’s experience’ resembles a UK passport to bank tellers. Based on bank tellers
presumably being able to view the image on the passport and the person standing before them,

your affiant suspects that the image resembles ABIOYE.

#1 #2

Wells Fargo

16. On or about April 1, 2019, a Wells Fargo Account ending in 7022 (“WF 7022”)
was opened at the Greenspring (Maryland) Branch.® Wells Fargo records show that WF 7022 is
registered to Geotric at 7203 Bogley Road Unit 303, Windsor Mill, MD. WF 7022 did not
contain an image of the Ali passport, but does list UK passport number 523865740 — the same
passport number that was used at Santander for SB 1107.

17. On May 30, 2019, WF 7022 received a $49,250 wire from a business in Atlanta,
(hereinafter “Business QY”). Your affiant has interviewed a representative of Business QY,

which also filed a complaint with the Atlanta Police. Business QY was fooled by a similar

5 Your affiant previously worked in the consular section at the U.S. Embassy in London

and thus encountered UK passports with some regularity and recognizes the cover of the

passports.
6 According to the Wells Fargo website, the Greenspring Branch is located at 2847 Smith
Avenue, Baltimore, MD. Based on your affiant’s review of a map on the Baltimore City website,

it appears to your affiant that this address is in Baltimore County.

6
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sounding email address, fraudulently inducing Business QY into sending a vendor payment to an
incorrect bank account. | |

18. Also on May 30, 2019, $9,800 was withdrawn from WF 7022. Based on Wells
Fargo surveillance images showing a man resembling ABIOYE, your affiant submits there is
probable cause to believe that ABIOYE withdrew $9,800 from WF 7022. This withdrawal
occurred at the Greenspring (Maryland) branch. On May 31, 2019, $9,900 was withdrawn from
WF 7022 and a cashier’s check payable to Buchaz Crystal LLC’ for $24,625.20 was purchased
from WF 7022. Based on Wells Fargo surveillance images showing a man resembling
ABIOYE, your affiant submits there is probable cause to believe that ABIOYE conducted these
transactions.* Your affiant has listed below (from left to right) a known image of ABIOYE (#1),
a Wells Fargo surveillance image from May 30, 2019 (#2), and a Wells Fargo surveillance
image” from May 31, 2019 (#3). Your affiant submits that this is strong evidence that ABIOYE

conducted these transactions.

7 Your affiant is familiar with Buchaz Crystal (a New Jersey LLC) and believes that it was
opened for the purpose of engaging in fraud by another member of the conspiracy, Person A. Your
affiant has evidence that a fake identity and fraudulent passport were-used in opening at least one
bank account for Buchaz Crystal. Your affiant also obtained toll records for a phone number
associated with ABIOYE (443-431-9092) and found tolls with 862-872-8946, a number listed for
Person A on immigration paperwork. These tolls were from July 5 to September 10, 2019.

8 Your affiant requested surveillance footage of both the check purchase and the cash
withdrawal on May 31, 2019. Wells Fargo provided images from what appears to be one visit to
the bank, however they did not label the transaction. Your affiant assumes that both the check
purchase and cash withdrawal were conducted at the same time.

19 Throughout this affidavit, your affiant includes a number of images from either bank
video surveillance or bank photo surveillance. In all instances, the images included here have
been cropped from the surveillance provided by the bank.

‘ 7
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#1 #2 #3

19. On June 11, 2019, WF 7022 received a transfer in excess of $300,000 from a
company in California (hereinafter “Business QI”). Your affiant reviewed a complaint filed by
Business QI with the IC3, which stated that Business QI incorrectly sent funds after receiving
what it thought was a genuine email from a vendor. Business QI later learned the vendor email
was fraudulent.

20. On June 11, 2019, according to Wells Fargo records and surveillance images that
your affiant has reviewed, a person resembling ABIOYE purchased multiple checks using funds
from WF 7022. One cashier’s check was made payable to “Buc haz [sic] Crystal LLC” for
$96,300.12 and another was payable to Bouken Services LLC”? for $89,700.20. Both were

purchased at the Greenspring branch. A comparison of ABIOYE?’s known facia] image from his

10 Your affiant is familiar with Bouken Services, a New Jersey registered LLC, and believes
that it was opened for the purpose of ehgaging in fraud by another member of the conspiracy.
Your affiant has evidence that a fake identity and fraudulent passport were used in opening at
least one bank account for Bouken Services. Your affiant also obtained toll records for a phone
number associated with ABIOYE (443-431-9092) and found more than 40 tolls with 862-872-
8946, a number listed for Peron A on U.S. immigration paperwork. A toll may include a call,

portion of a call, an attempted call, or SMS/MMS message. These tolls were from July 5 to
September 10, 2019.
Case 1:20-cr-00052-SAG Document 1-1 Filed 01/29/20 Page 9 of 20

Maryland driver’s license (#1) and the WF 7022 surveillance images from June 11, 2019 is

shown below (#2 and #3)!':

#1 #2 #3
Bank of America
21. A Bank of America account in the name of Geotric was opened on April 2, 2019.

The last four digits of the account are 8006 (“BOA 8006”). The account was opened at the
Garrison Forest financial center. The Bank of America website lists the address as 10315
Reisterstown Road, Owings Mills, MD.

22. On April 15, 2019, BOA 8006 received a $51,800 wire from a person with the
initials R.D. Your affiant obtained an incident report from the Bay County Sheriffs Office in
Florida. The reporting officer spoke to R.D. who told the officer that he received a message that
he was the beneficiary in a will and was entitled to $4 million. R.D. was told he needed to pay a
processing fee. R.D. said that he was sent a check for $62,712, which he deposited. R.D. was

subsequently instructed to wire $51,800 to Geotric’s BOA 8006, which he did. A bank employee

a WF 7022 records show that the checks were purchased about 10:11 am and 11:55 am so
your affiant includes a photo from both of those times.

? 9

| S
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told the reporting officer that she contacted the bank on the $62,712 check and was told it was
fraudulent. ! |

23. On April 15 and April 16, 2019, more than $38,000 was withdrawn or transferred
from BOA 8006. This included three cash withdrawals totaling $10,200 and a $28,000 wire to
an account at Citi Bank, which is the corresponding bank account for the United Bank of Africa,
Nigeria. Bank of America provided surveillance images from April 15 and 16, 2019. The man
conducting the transactions strongly resembles ABIOYE. A comparison of ABIOYE’s known
image (#1) and Bank of America surveillance from April 15 and April 16, 2019 (#2, #3, and #4)

is presented below.

#1 #2 #3 #4

24. In June 2019, BOA 8006 received three wires from a company in Florida
(hereinafter “Company EA”). On June 7, 2019, BOA 8006 received a $50,000 wire from
| Company EA. On June 10, 2019, BOA 8006 received a wire for $17,398 from Company EA.
On June 11, 2019, BOA 8006 received another wire from Company EA, this time for $46,287.
Your affiant spoke to a representative of Company EA and obtained records from Company EA

and Company EA’s bank. From them, your affiant learned that Company EA was the victim of a

R R.D. also told the officer that he sent money using his account at another bank, but. he did
not want to report the loss of that money.

10
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fraud in which an email address closely resembling a correct email address was used to direct

another Company EA employee to initiate these wire transfers. Company EA’s bank records

also show that on June 13, 2019 there was a failed $49,982.21 wire from Company EA’s account

to an account for Bouken Services LLC -- one of the New Jersey LLCs to which checks from

Geotric were made out.

25. From June 7 to June 13, 2019, over $100,000 was withdrawn or transferred out of

BOA 8006. A number of the transactions occurred in Baltimore County. Your affiant obtained

surveillance images/videos from Bank of America for a number of these transactions and lists

some of the larger transactions here.

Date Transaction type Amount Surveillance

June 7, 2019 Cash withdrawal $9,500) Yes

June 7, 2019 Cashier’s check to $24,313.15'3 Yes
Buchaz Crystal

June 10, 2019 Cash withdrawal $9,600 Not provided

June 10, 2019 Wire to Insurance $8,650 Not provided
Auto Auctions

June 10, 2019 Cash withdrawal $5,300 Yes

June 12,.2019 Wire to Insurance $23,057.30 Not provided
Auto Auctions

June 12, 2019 Cash withdrawal $9,000!7 Yes

June 13, 2019 Cash withdrawal $9,600 Yes'4

based on your affiant’s experience resembles a UK passport.

During this transaction, the man who resembles ABIOYE gave the teller a document that

Your affiant reviewed surveillance provided by both the legal order processing

department as well as from an investigator at Bank of America related to June 13, 2019. The
legal order processing provided surveillance for this transaction that does not appear to be
ABIOYE; however, the image provided from the investigator does resemble ABIOYE. Your
~ affiant noted that the surveillance provided was from the same date at approximately the same
time (11:53 a.m. and 11:54 a.m.) but different bank branches. Your affiant suspects that legal

11:
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24. Your affiant includes below a known picture of ABIOYE from his Maryland

driver’s license on the left (#1) followed by photos from Bank of America surveillance on June 7

(#2), June 10 (#3), June 12 (#4), and June 13, 2019 (#5).

#1 #2 #3 #4 | #5

25. On June 19, 2019, BOA 8006 received a $20,850 wire from a woman with the
initials S.M. Your affiant reviewed an IC3 complaint filed by S.M. S.M. wrote that while
“stationed” in Germany (presumably as a part of the military or U.S. government given her
reference to being stationed), S.M. was purchasing a house in anticipation of moving back to the
U.S. An email account mirroring her title company’s email address was used to request
additional closing costs, and fraudulently deceive her into sending funds.

26. On June 19 and June 20, 2019, over $20,000 was withdrawn from BOA 8006.
Among the withdrawals was a $9,500 teller cash withdrawal on June 19, 2019 and a $9,300 teller
cash withdrawal on June 20, 2019. Your affiant reviewed images from Bank of America for

these dates and found that both showed a man resembling ABIOYE. The known image of

order processing provided surveillance footage from the wrong branch location. The image

resembling ABIOYE is provided herein.
S

12:
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ABIOYE is shown below on the left (#1), compared with images from Bank of America on June

19" (#2) and June 20 (#3).

#1 #2 #3

Santander Bank

27, On May 30, 2019, a cashier’s check for $89,450 was deposited into the Geotric
account at Santander (“SB 1107”). The check came from a church in Nevada. Based on records
your affiant obtained from the church’s bank, your affiant knows that the bank received an email
requesting the $89,450 cashier’s check from the church’s bank account. The email purportedly
came from an employee of the church, but the church employee’s email had been compromised.
To verify the request, the bank employee called the phone number listed on the check request
and not the number for the church in the bank’s records. As a result, the bank employee spoke
with a fraudster who authorized sending the check. |

28. On June 3 and June 4, 2019, more than $89,000 was removed from the account
via purchases, wires, checks, and withdrawals.

29. On June 3, 2019, $45,500 was wired to the United Bank of Africa, Nigeria
corresponding bank account at Citi Bank. On June 4, 2019, another $19,000 was wired to the
United Bank of Africa, Nigeria corresponding bank account at Citi Bank.

30. On J une 3, 2019, $9,800 was withdrawn in cash at a branch in Hanover, PA.

\ SN
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31. On June 4, 2019, $6,000 was withdrawn in cash and a $5,000 cashier’s check
made payable to Geotric Global LLC was purchased in Hanover, PA. Also, on June 4, 2019,
$1,000 was withdrawn via an ATM transaction in Hanover, PA.

32. | Santander only provided surveillance of the June 4, 2019 ATM transaction. Your
affiant compared the image to a known image of ABIOYE and believes the person conducting
the transaction resembles ABIOYE. Your affiant included below a known image of ABIOYE

on the left and two images from the ATM surveillance (#2 and #3).

#1 #2 #3

33. In the June 4" video, the man resembling ABIOYE exited a vehicle your affiant
recognizes as a white Volkswagen sedan. ABIOYE had a white Volkswagen Jetta registered to
him and your affiant has observed ABIOYE driving a white Volkswagen CC (sedan).

34. Your affiant also obtained the Wells Fargo surveillance image from June 4, 2019,
the same day, when $5,000 in checks were deposited into WF 7022 (Geotric). Your affiant
suspects this was the $5,000 check from SB 1107, but Wells Fargo did not produce the deposited
check(s). The man conducting the deposit resembles ABIOYE. A known image of ABIOYE is

included below (#1) along with the Wells Fargo surveillance image from June 4, 2019 (#2).

14
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#1 #2

Chase Bank
35. | There were two accounts opened in the name of Geotric at Chase Bank. An

account ending 3222 was opened on April 18, 2019 (“CB 3222”) and an account ending 3972
was opened on May 22, 2019 (“CB 3972”)

| 36, On May 18, 2019,'° a check for $35,000 was deposited into the Geotric account,
CB 3222. The remitter on the check was B.D. Your affiant obtained a police report from the Salt
River Police Department in Arizona. According to the report, B.D.’s year of birth is 1947. The
reporting officer met with B.D. and her daughter. The daughter told the officer that B.D.
accepted approximately $74,000 from someone B.D. knew as J erry Smith. B.D. then distributed
the money in various ways including cashier’s checks. The daughter further advised that they
had spoken to a Wells Fargo employee, who advised that the $74,000 was stolen. B.D. told the
officer that she met a man who she knew as Jerry Smith on Facebook, and that they were in a
romantic relationship. Jerry Smith told B.D. that he was from the U.S., but was currently

working in Nigeria. B.D. provided the officer with a copy of the deposit receipt into the Chase

13 The bank statement says May 20, 2019 but the deposit slip says May 18, 2019.

15
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account. Your affiant believes that B.D. was the victim of a romance scam in which her account
was used to receive and disburse fraudulent funds.

37. On May 22, 2019, $9,650 was withdrawn from CB 3222. Surveillance provided
by Chase for May 22, 2019 resembles ABIOYE.

38. On May 22, 2019, $24,935.54 was transferred from CB 3222 to CB 3972.

39. On May 23, 2019, $1,000 was withdrawn via ATM and $9,850 via teller from CB
3972. In the teller transaction, your affiant noted that the teller gave back a document that your
affiant believes based on experience resembled a UK passport. Chase teller and ATM
surveillance from May 23, 2019 resembled ABIOYE.

40. On May 24, 2019, $1,000 was withdrawn via ATM and $9,850 via teller from CB
3972. May 24, 2019 ATM surveillance appears to be ABIOYE. The only surveillance provided
from the teller withdrawal is from some distance. The person in the image is wearing a shirt and
hat that look very similar to the clothing visible in the ATM surveillance.

41. Your affiant pasted below from left to right, a known photo from ABIOYE’s _
driver’s license (#1), a surveillance image from May 22, 2019 (#2), a surveillance image from
the May 23, 2019 ATM transaction (#3), a surveillance image from the May 23, 2019 teller
transaction (#4), and a surveillance image from the May 24, 2019 ATM transaction (#5). Your

| affiant submits that there is ample probable cause to believe that ABIOYE is depicted in all five

_ images (#1 -#5).

16
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#] #2 #3 #4 #5

42. Your affiant further submits that the surveillance image from the May 24, 2019
teller transaction (#6) is likely ABLOYE given the similar shirt and hat in image #5 and image

#6 below:

43. On July 9, 2019, CB 3972 received a wire of $97,850 from a woman with the
initials M.L. who lives in Texas. Your affiant reviewed a complaint filed by M.L. with the IC3.
In the complaint, M.L. explained that in the process of closing on a house, she sent the money as
a result of an email purporting to be from her title company and text messages with the suspected
fraudster.

44. On July 9, 2019, $37,000 from CB 3972 was wired to the Citi corresponding bank

account for the United Bank of Africa, Nigeria.

/ | WARD
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45, On July 9, 2019, $57,220 was withdrawn from CB 3972. $48,220 of this was a
cashier’s check to Bouken Services LLC. Your affiant is unable to determine the form of the
withdrawal ‘of the other $9,000. Your affiant obtained Chase surveillance video from July 9,
2019. The man shown resembles ABIOYE. In addition, in the video the teller can be seen
handing a small item back to the man resembling ABIOYE. Based on your affiant’s experience,
the item resembles a UK passport and is thus likely the Andrew Ali UK passport used to open
multiple Geotric accounts.

46. Your affiant includes below a known picture of ABIOYE from his Maryland
driver’s license on the left (#1) and an image (#2) from Chase surveillance for July 9, 2019 on

the right.

47. Your affiant also obtained video from July 9, 2019 of the deposit of the $48,220
check to Bouken Services purchased from CB 3972. The check was deposited at a Capital One
branch in Reisterstown. Your affiant included a known picture of ABIOYE below along with a
July 9, 2019 surveillance image from Capital One. Your affiant submits the individual in the

Capital One footage resembles ABIOYE.

18
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Il. CONCLUSION

48. This affidavit describes more than $500,000 that was deposited into bank
accounts based on false promises, representations, or statements. The bank accounts that
received the funds (either directly or indirectly) were used by ABIOYE and Person A. Shortly
after these funds were deposited into Geotric’s bank accounts, significant sums were removed
from the accounts -- in many examples by a person closely resembling ABIOYE. Based the
bank records showing the fake UK passport and bank surveillance of an item resembling a UK.
passport, your affiant submits that there is probable cause to believe that ABIOYE used the fake
Ali passport at Chase, Wells Fargo, Bank of America, and Santander banks.

49. _ Moreover, based on the surveillance, your affiant submits there is probable cause
to believe ABIOYE caused financial transactions in such accounts. Your affiant’submits that
there is probable cause to believe that when ABIOYE conducted transactions in the accounts
opened using the entities and/or fake alias, ABIOYE was causing a wire fraud on the banks and
on the individuals whose funds were deposited into those accounts through fraud and deceit.
Finally, your affiant submits that there is probable cause to believe that ABIOYE conspired with
Person A. Your affiant submits that there is probable cause that ABIOYE?’s actions were
coordinated with Person A when ABIOYE obtained checks payable to the New Jersey LLCs .

Bouken and Buchaz using the funds obtained via fraud from victims in multiple states.

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