Apocalypse Bella — Sealed Indictment
Summary
A sealed indictment, 21 Cr., in the U.S. District Court for the Southern District of New York against Apocalypse Bella, also known as Dias Yumba, Mackenzy Toussaint, also known as Mack, and Amos Mundendi, also known as Mos and El Ashile Mundi. Count One charges conspiracy to commit major fraud against and defraud the United States. The indictment alleges that from about March 2020 the defendants were involved in loan applications seeking at least approximately $14 million in government-guaranteed loans through the SBA's Paycheck Protection Program for various companies. It cites loans to two companies in the district totaling approximately $4 million, and payments of approximately $729,550 to an account controlled by Bella and approximately $138,000 to one controlled by Toussaint.
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- Captured
- 2026-09-25
- Source site
- www-justice-gov
Archived web capture. Preserved source — captured from www-justice-gov; archived 2026-09-25.
Full text
UNITED STATE S DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
- - - - - - - - - - - - - - X
UNITED STATES OF AMERICA
- v. - SEALED INDICTMENT
APOCALYPSE BELLA , 21 Cr .
a/k/a " Dias Yumba ,"
MACKENZY TOUSSAINT ,
a/k/a " Mack ," and
..,, ,
AMOS MUNDEN DI ,
a/k/a " Mos , "
a/k/a "El Ashile Mundi ,"
Defendants .
- - - - - - - - - - - - - - X
COUNT ONE
(Conspiracy to Commit Major Fraud Against and
Defraud the United States)
The Grand Jury charges :
OVERVIEW OF FRAUDULENT SCHEME
1. From at least in or about March 2020 to the present ,
APOCALYPSE BELLA , a/k/a " Dias Yumba ," MACKENZY TOUSSAINT , a/k/a
"Mack ," and AMOS MUNDENDI , a/k/a " Mos ," a/k/a " El Ashile Mundi , "
the defendants , were involved in an extens i ve scheme to prepare
and submit fraudulent applications to the Small Business
Administration (" SBA" ) and to at l east one company which
processes PPP loan applications ("PPP Loan Company - 1 " ) , in order
to obtain at least approximately $14 million in government -
guaranteed loans for various companies through the SBA ' s
Paycheck Protection Program ("PPP"), designed to provide
financial relief to qualifying companies during the novel
coronavirus/COVID-19 pandemic. This scheme resulted in the
approval of fraudulently procured loans for two companies
("Company - 1" and "Company-2" ) , both located in the Southern
District of New York, totaling approximately $4 million , and the
distribution of the proceeds of these fraudulently obtained
funds to a series of bank accounts located in the United States
and elsewhere , including bank accounts controlled by TOUSSAINT
and BELLA.
2. APOCALYPSE BELLA, a/k/a "Dias Yumba ," MACKENZY
TOUSSAINT , a/k/a "Ma ck ," and AMOS MUNDENDI, a/k/a " Mos ," a/k/a
"El Ashile Mundi ," the defendants , devised and executed this
fraudulent scheme by conspiring with individuals (the "Straw
Applicants") , who own , operate or otherwise are affiliated with
businesses (the "Straw Companies " ) , such as Company- 1 and
Company-2. BELLA , TOUSSAINT , MUNDENDI , and other co -
conspirators supervised and coordinated the submission of
fraudulent PPP loan applications for the Straw Companies , and in
some cases , completed and/or submitted the fraudulent
applications themselves.
3. The PPP loan applications for Company- 1 and Company- 2
(" Company-1 PPP Loan Application" and " Company- 2 PPP Loan
Application") were false , designed to maximize proceeds to the
2
fraud scheme . Specifically , applications for both Company-1 and
Company- 2 contained material differences from loan applications
submitted for both companies for the Economic Injury Disaster
Loan (" EIDL " ) program just months earlier . For instance , the
Company- 1 PPP Loan Application represented that Company-1 had
over 100 employees . However , an earlier EIDL loan application
for Company-1 dated on or about March 30 , 2020 , represented that
Company-1 had only four employees . And the Company- 2 PPP Loan
Application was strikingly similar to that of Company- 1 , in
terms of the number o f employees and the size of its payroll ,
although a previously submitted EIDL loan application for
Company- 2 also claimed that Company- 2 had many fewer employees.
Moreover , the Company- 1 and Company- 2 PPP Loan Applications both
contained false information about the number of employees, size
of payrol l, and ot her financial information relating to Company-
1 and Company- 2 . These false representations appear to be
designed to result in the procurement of PPP loans just shy of
$2 million for each company , the largest PPP loan that was
allowed by PPP Loan Company-1 at t h e time that the Company- 1 and
Company- 2 PPP Loan Applications were submitted .
4. In early July 2020 , the PPP l oan applications for both
Company-1 and Company- 2 were approved, resulting in the
disbursement of nearly $4 million total in fraudulently procured
loans to the defendants.
3
5. Between July and August 2020 , there were significant
disbursements from the Company- 1 Bank Account that did not
appear to meet the requirements for the use of PPP funds ,
including large transfers of funds abroad , the movement of funds
to an investment management company , and the payment of
approximately $729 , 550 in funds to a bank account which is
controlled by APOCALYPSE BELLA , a/k/a "Dias Yumba ," the
defendant , and approximately $138 , 000 to a bank account which is
controlled by MACKENZY TOUSSAINT , a/k/a " Mack ," the defendant .
6. Starting in or about February 2021 , AMOS MUNDENDI ,
a/k/a "Mos ," a/k/a " El Ashile Mundi ," the defendant , began to
facilitate the process of fraudulently applying for a second
round of PPP loans , including for Company- 1 and Company-2 . This
resulted in a second fraudulent PPP Loan Application being
prepared and submitted in the name of Company- 1 requesting an
additional $2 million in PPP funds . Those funds have not yet
been disbursed .
Statutory Allegations
7. From at least in or about March 2020 to the present ,
in the Southern District of New York and elsewhere , APOCALYPSE
BELLA , a/k/a " Dias Yumba ," MACKENZY TOUSSAINT , a/k/a " Mack ," and
AMOS MUNDENDI , a/k/a "Mos ," a/k/a "El Ashile Mundi , " the
defendants , together with others known and unknown , willfully
and knowingly combined , conspired , confederated , and agreed
4
together and with each other to commit an offense against the
United States and to defraud the United States and an agency
thereof , to wit , the SBA , in violation of Title 18 , United
States Code , Sections 1031 and 2.
8. It was a part and an object of the conspiracy that
APOCALYPSE BELLA , a/k/a " Dias Yumba , " MACKENZY TOUSSAINT , a/k/a
" Mack ," and AMOS MUNDENDI , a/k/a " Mos ," a/k/a " El Ashile Mundi ,"
the defendants , together with others known and unknown ,
willfully and knowingly would and did execute and attempt 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 , BELLA , TOUSSAINT , and MUNDENDI engaged in a scheme to
obtain at least approximately $14 million in Government -
guaranteed loans for various companies , including Company- 1 and
Company- 2 , by means of false and fraudulent pretenses ,
representations , and documents , through the PPP of the SBA ,
designed to provide relief to small businesses during the novel
coronavirus/COVID - 19 pandemic .
5
9. It was a further part and an object of the conspiracy
that APOCALYPSE BELLA , a/k/a "Dias Yumba ," MACKENZY TOUSSAINT ,
a/k/a "Mack," and AMOS MUNDENDI , a/k/a " Mos ," a/k/a "El Ashile
Mundi ," the defendants , together with others known and unknown ,
willfully and knowingly would and did defraud the United States,
and an agency thereof, to wit , BELLA , TOUSSAINT , and MUNDENDI
engaged in a scheme to obtain at least approximately $14 million
in Government-guaranteed loans for various companies , including
Company- 1 and Company-2 , by means of false and fraudulent
pretenses , representations , and documents , through the SBA's
Payment Protection Program.
Overt Acts
10. In furtherance of the conspiracy and to effect the
illegal objects thereof , APOCALYPSE BELLA , a/k/a " Dias Yumba ,"
MACKENZY TOUSSAINT , a/k/a " Mack ," and AMOS MUNDENDI , a/k/a
"Mos," a/k/a "El Ashile Mundi ," the defendants , and others known
and unknown , committed the following overt acts , among others ,
in the Southern District of New York and elsewhere :
a. In or about July 2020 , a co-conspirator not named
herein ("CC-1 " ) , who was located in the Southern District of New
York and acts as an agent of both Company- 1 and Company- 2 ,
caused a total of approximately $729 , 550 in proceeds from
fraudulently procured PPP loans to be transferred to a bank
6
account controlled by BELLA from a bank account located in the
Southern District of New York .
b. In or about August 2020 , CC-1 , who was located in
the Southern District of New York , caused a total of
approximately $138 , 000 in proceeds from fraudulently procured
PPP loans to be transferred to an account controlled by
TOUSSAINT from a bank account located in the Southern District
of New York .
c. In or about February 2021 and March 2021 ,
MUNDENDI communicated with CC-1 , who was located in the Southern
District of New York , and caused to be prepared a fraudulent PPP
application for Company- 2 , which was transmitted to CC-1.
(Title 18 , United States Code , Section 371) .
COUNT TWO
(Major Fraud Against the United States)
The Grand Jury further charges :
11 . The allegations set forth in paragraphs 1 to 6 are
repeated and realleged , and incorporated by reference as if
fully set forth herein .
12 . From at least in or about March 2020 to the present,
in the Southern District of New York and elsewhere , APOCALYPSE
BELLA , a/k/a "Dias Yumba ," MACKENZY TOUSSAINT , a/k/a " Mack ," and
AMOS MUNDENDI , a/k/a "Mos ," a/k/a "El Ashile Mundi , " the
defendants , willfully and knowingly executed , and attempted to
execute , a scheme and artifice with t he intent to defraud the
7
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 , BELLA, TOUSSAINT , AND MUNDENDI engaged in a scheme to
obta in at least approximately $14 million in Government-
guaranteed loans by means of false and fraudulent pretenses ,
representations , and documents, including for Company- 1 and
Company- 2 , through the PPP .
(Title 18, United States Code , Sections 1031 and 2 . )
COUNT THREE
(Wire Fraud Conspiracy)
The Grand Jury further charges:
13 . The allegations set forth in paragraphs 1 to 6 are
repeated and realleged , and incorporated by reference as if
fully set forth herein .
14. From at least in or about March 2020 through at least
in or about May 2020 , in the Southern District of New York and
elsewhere , APOCALYPSE BELLA , a/k/a "Dias Yumba," MACKENZY
TOUSSAINT , a/k/a "Mack," and AMOS MUNDENDI , a/k/a "Mos," a/k/a
"El Ashile Mundi ," the defendants, and others known and unknown ,
willfully and knowingly did combine , conspire , confederate , and
8
agree together and with each other to commit wire fraud , in
violation of Title 18 , United States Code , Section 1343 .
15. It was a part and an object of the conspiracy that
APOCALYPSE BELLA, a/k/a "Dias Yumba," MACKENZY TOUSSAINT , a/k/a
"Mack ," and AMOS MUNDENDI , a/k/a "Mos, " a/k/a "El Ashile Mundi, "
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, 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 ,
to wit , BELLA, TOUSSAINT , AND MUNDENDI engaged in a scheme to
obtain at least approximately $14 million in Government -
guaranteed loans by means of false and fraudulent pretenses ,
representations , and documents, including Company- 1 and Company-
2 , through the PPP , including the online submission of PPP loan
applications transmitted from the Southern District of New York .
(Title 18 , United States Code, Sections 1349 and 2.)
9
COUNT FOUR
(Wire Fraud)
The Grand Jury further charges:
16 . The allegations set forth in paragraphs 1 to 6 are
repeated and realleged , and incorporated by reference as if
fully set forth herein .
17 . From at least in or about March 2020 to the present ,
in the Southern District of New York and elsewhere , APOCALYPSE
BELLA , a/k/a "Dias Yumba ," MACKENZY TOUSSAINT , a/k/a " Mack ," and
AMOS MUNDENDI , a/k/a "Mos," a/k/a "El Ashile Mundi ," the
defendants , 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 , 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 , to wit , BELLA , TOUSSAINT,
AND MUNDENDI engaged in a scheme to obtain at least
approximately $14 million in Government-guaranteed loans by
means of false and fraudulent pretenses , representations , and
documents , including for Company-1 and Company- 2 , through the
PPP , for which fraudulent PPP loan applications were accessed
online from the Southern District of New York .
10
(Title 18 , United States Code , Sections 1343 and 2 . )
FORFEITURE ALLEGATIONS
18. As the result of committing the offenses charged in
Counts Th r ee a n d Four of this Indictment , APOCALYPSE BE LLA ,
a/k/a " Dias Yumba ," MACKENZY TOUSSAINT , a/k/a " Mack ," and AMOS
MUNDENDI , a/k/a " Mos ," a/k/a " El Ashile Mundi ," the defendants ,
shal l forfeit to the Un i ted States , pursuant to Tit l e 1 8 , United
States Code , Section 981 (a) (1) (C) and Title 28 United States
Code , Section 2461(c) , any and all property , real and personal ,
that constitutes , or is derived from , proceeds traceab l e to the
commission of said offenses , including but not limited to a sum
of money in United States currency representing the amount of
proceeds t raceable to t h e commission of said offenses .
Substitute Assets Provision
19 . If any of the above - described forfeitable property , as
a resu l t 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 ;
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 subdivided without difficulty ;
11
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 246l(c) , 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 981 ;
Title 21 , United States Code , Section 853 ; and
Title 28 , United States Code , Section 2461 . )
RAUSS ffe l
tates Attorney
12
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
V.
APOCALYPSE BELLA, a/k/a "Dias Ywnba,"
MACKENZY TOUSSAINT, a/k/a "Mack," and
AMOS MUNDENDI, a/k/a "Mos," a/k/a "El Ashile
Mundi,"
Defendants.
SEALED INDICTMENT
21 Cr .
(18 U. S . C . §§ 371 , 1031 , 1343 , 1349 and 2 . )
AUDREY STRAUSS
Un i ted States Attorney
A TRUE BILL
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