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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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2026-09-25
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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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