Case 1:20-mj-02111-AMD, Document 1 — Attachment A

Summary

A criminal complaint, Case 1:20-mj-02111-AMD, Document 1, filed 10/19/20 in the District of New Jersey, charging Ali Shoultz in Attachment A with conspiracy to commit bank fraud from about April 2020 through about October 2020. The supporting affidavit in Attachment B describes a nationwide effort using counterfeit U.S. Treasury Economic Impact Payment checks deposited into the accounts of recruited account holders. It states that Bank of America's loss exposure from the counterfeit deposits is approximately $320,119.70, with an actual loss of approximately $213,000.00, and that collusive account holders were identified in ten states. The affidavit also traces transfers through Cash App and JPMC accounts, including approximately $14,067 between April 13, 2020 and May 11, 2020.

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Attachment A

(Conspiracy to Commit Bank Fraud)

From at least as early as in or about Apri~ 2020 through in or about October, 2020, in the District
of New Jersey, and elsewhere, the defendant,

ALI SHOULTZ,

did knowingly and intentionally conspire and agree with others, to devise a scheme and artifice to
defraud fmancial institutions and the United States, and to obtain money and property by means of
materially false and fraudulent pretenses, representations, and promises, and for the purpose of
executing such scheme and artifice to defraud a fmancial institution by means of materially false and
fraudulent pretenses, representations, and promises, contrary to Title 18, United States Code, Section
1344, as described in Attachment B.

In violation of Title 18, United States Code Section 1349.
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Attachment B

I, Luis Santana, having conducted an investigation and having spoken with other individua Is,

have knowledge of the following:

I am a Special Agent with Homeland Security Investigations ("HSI"). I am fully familiar with

the facts set forth herein based on my own investigation, my conversations with other law enforcement

officers, and my review of reports, documents, photographs and video recordings of the evidence.

Where statements of others are related herein, they are related in substance and part. Because this

Complaint is being submitted for a limited purpose, I have not set forth each and every fact that I know

concerning this investigation. Where I assert that an event took place on a particular date and time, I am

asserting that it took place on or about the date and time alleged. Except as otherwise indicated,

statements of others identified in this Affidavit are reported in substance and in part.

At all times relevant herein:

1. Bank of America, Wells Fargo & Company (hereinafter "Wells Fargo"), Capital One

Financial Corporation (hereinafter "Capital One"), are ''fmancial institutions" as defmed by Title 18,

United States Code, Section 20;

2. United States Treasury Checks are "securities" as defmed by Title 18, United States

Code, Section 513; and

3. All counterfeit United States Treasury Checks described herein bore a likeness or

resemblance to a genuine United States Treasury Check, including the color, font, and images printed

within the checks.

INVESTIGATION

4. At least as early as April 30, 2020, law enforcement agents learned of a nationwide

scheme to defraud fmancial institutions using forged or counterfeit United States Treasury Checks.
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Conspirators involved in the fraud scheme primarily use social media platforms, such as Instagram 1, to

recruit individuals to participate. Conspirators recruited both genuine victims, those who unknowingly

participated in the fraud scheme, and collusive account holders, those who knowingly participated in the

fraud scheme, to provide their debit card, account information, and PfN. Once in possession of this

information, conspirators in the scheme deposited counterfeit securities, e.g., U.S. Treasury Economic

Impact Payment ("EIP") checks, into genuine victims' and collusive account holders' bank accounts at

various financial institutions. Members of the conspiracy deposited the counterfeit securities at various

bank branches, A TMs, or through mobile deposits. While the funds remained in the account, and before

the individual banks discovered that the securities were counterfeit, co-conspirators used the debit cards

to withdraw the funds through A TM withdrawals or peer to peer payment platforms, thus depleting the

individual accounts before the banks discovered the fraud. The window of time between the fraudulent

deposits and withdrawals was approximately 2-4 days.

5. Members of multiple law enforcement agencies conducted an investigation into the

counterfeit U.S. Treasury EIP Checks. This type of U.S. Treasury check was issued as part of the

CARES Act. 2 The counterfeit U.S. Treasury EIP checks involved in this scheme utiliz.ed three check

numbers with varying payee names and amounts. The EIP check numbers were xxxx-xxxx2999

(hereinafter "Counterfeit EIP Check A"), xxxx-xxxxl 970 (hereinafter "Counterfeit EIP Check B"); and

1 Instagram, also known as "IG" or "Insta," is a photo and video-sharing social networking service and application

owned by Facebook, Inc. The application, sometimes referred to as an "app," allows users to upload photos and
videos to the service, which can be edited with various filters, and organized with tags and location information,
and are called "posts." An account's posts can be shared publicly or with pre-approved followers.

2 The Coronavirus Aid, Relief, and Economic Security ("CARES") Act, was signed into law on March 27, 2020.

It provides for, in pertinent part, up to $1,200 per adult per household in those American households whose
income was less than $99,000 (or $198,000 for joint filers) and $500 per child under 17 years old- or up to
$3,400 for a family of four. Under the CARES Act, these payments are referred to as Economic Impact Payments
(EIP). The EIP are issued in the form of United States Treasury checks, direct deposits and prepaid debit cards.

2
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xxxx-xxxx5898 (hereinafter "Counterfeit EIP Check C"). These EIP check numbers are associated with

actual U. S. Treasury EIP checks that were issued as part of the CARES Act and are listed below:

• Counterfeit EIP Check A was issued on April 17, 2020 in the amount of $4,210 payable to
C.R. and N.Rresiding in Jurupa Valley, California. Counterfeit EIP Check A is still
outstanding as of September 8, 2020.
• Counterfeit EIP Check B was issued on April 24, 2020 in the amount of $1,200 payable to
C.A. residing in Cleveland, Ohio. Counterfeit EIP Check B was negotiated at Fifth Third
Bank on April 27, 2020.
• Counterfeit EIP Check C was issued on Apri] 28, 2020 in the amount of $1,200 payable to
Takeem Ford residing in Philadelphia, Pennsylvania. Counterfeit EIP Check C was
negotiated at J.P. Morgan Chase ("JPMC") on April 30, 2020

6. Throughout the course of this investigation, investigators identified over 164 counterfeit

U.S. Treasury EIP checks deposited into approximately 51 different Bank of America accounts. The

loss exposure to Bank of America as a result of these counterfeit deposits is approximately $320,119.70

with an actual loss of approximately $213,000.00. Investigators identified collusive account holders in

ten different states across the country: New Jersey, New York, Pennsylvania, Connecticut, Maryland,

California, Georgia, Tennessee, Texas, and South Caro1ina.

i. May 1, 2020 Fraudulent Activity- Account Holder"M.J." and "B.P."

7. On or about May I, 2020, Kass an Knight ("KNIGHT") posted a "story"3 to his Ins ta gram

account stating "gang with me @jayyybandzzz_" referring to Justin Ezeiruaku ("EZEIRUAKU").

During this "story," KNIGHT stated "All OA instant" 4 (with an arrow pointed to a phone emoji)

followed by a video referencing bread5 while standing at a drive thru bank A TM lot with another

3
lnstagram "stories" are a feature that allow users to take photos, add effects and layers, and add them to a
continual series of posts, also called a "story." Images uploaded to a user's "story" expire after 24 hours.
Instagram accmmt holders can change their displayed name, sometimes referred to as a "vanity name," at any
time on their account while maintaining their unique account identification number. Users can browse other
users' content by tags and locations, and view trending content.
4 "OA" and "BOA" refer to Bank of America.
5 Bread is a commonly used slang term referring to money.

3
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individual In the video, Jaw enforcement agents identified EZEIRUAKU as one of the individuals

standing with KNIGHT at the A TM drive thru.

8. Subsequent to tagging EZEIRUAKU, and within the same "story," KNIGHT posted a

Bank of America receipt. The receipt showed that $4,210 was deposited on May 1, 2020, just after

midnight, at an ATM in the Hilton Hotel in Maplewood, New Jersey (the "Hilton ATM''). Based on this

information, investigators learned that two different Bank of America accounts received counterfeit U.S.

Treasury EIP checks, both in the amount of $4,210.
(

9. Investigators learned that the account holder for one of the Bank of America accounts

tied to the counterfeit U.S. Treas~ EIP check deposit made on or about May 1, 2020 was an individual

identified as "M.J." M.J.'s Bank of America account had two counterfeit U.S. Treasury EIP checks,

Counterfeit EIP Check A and Counterfeit EIP Check B, deposited into his/her Bank of America personal

bank account, and was named as the payee on both checks.

10. Counterfeit EIP Check A was deposited into the Hilton ATM. See supra at para. 7.

Surveil1ance footage from the Hilton ATM showed KNIGHT, with EZEIRUAKU, making the deposit.

Both men were depicted wearing the same clothing as on KNIGHT's story posted to Instagram. On the

same day, the money deposited in M.J.'s account was removed through two ATM withdrawals, one

made at the Hilton ATM and the other at a Capital One ATM in Newark, New Jersey, a Zelle bank

transfer, and a debit card purchase. Surveillance footage from the Hilton ATM and Capital One ATM

showed KNIGHT, EZEIRUAKU, and Ali Shoultz ("SHOULTZ") withdrawing the funds. The Zelle

bank transfer was made to Torri Pedro's ("PEDRO") personal JPMC Bank account within minutes of

the Counterfeit EIP Check A deposit. Investigators identified PEDRO to be EZEIRUAKU's paramour.

The debit card purchase occurred at the Gloucester City Post Office, where two legitimate USPS money

orders were purchased, each issued for $150, using M.J. 's compromised account debit card. These

4
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USPS money orders were subsequently cashed with the listed payees as Abdulai M. Kamara, who also

routinely posts ads to social media recruiting for bank accounts, and Shaquilla Little Burton, who is/was

dating SHOULTZ.

11. On or about May 4, 2020, KNIGHT, accompanied by SHOULTZ, deposited Counterfeit

EIP Check B into M.J. 's Bank of America personal bank account, in the amount of $4,300, at an A TM

in Linden, New Jersey. Almost immediately following the deposit, KNIGHT made two ATM

withdrawals from the same ATM, withdrawing a total of $1,500. Approximately ten minutes later,

EZEIRUAKU conducted a balance inquiry from the same A TM in Linden, New Jersey.

12. Investigators identified the second Bank of America account holder, identified as "B.P .,"

who had Counterfeit EIP Check B deposited into his/her personal bank account. B. P. was named as the

payee on the Counterfeit EIP Check B, which was deposited in the amount of $4,210, on or about May

1, 2020, at the Hilton ATM. Surveillance footage of the deposit showed KNIGHT, EZEIRUAKU, and

SHOULTZ together. Soon after the deposit was made, $4,200 was withdrawn from B.P. 's Bank of

American personal bank account through a Zelle bank transfer and a Cash App transfer. The Zelle bank

transfer, in the amount of $2,200, was made to PEDRO's JPMC personal bank account. The Cash App

transfer, in the amount of $2,000, was transferred to B.P. 's account. From there, the funds were

transferred to another Cash App account.

13. Based on these deposits, investigators examined PEDRO's JPMC personal bank account.

Investigators discovered that from on or about April 13, 2020 through May 8, 2020, PEDRO's JPMC

personal checking account received $39,914 in ATM deposits, Cash App transfers, Zelle bank transfers,

and direct deposits. Ofthat sum, $24,924 was deposited in ATM deposits, nearly all of which were

conducted at the JPMC ATM located in Marhon, New Jersey (hereinafter the "JPMC Marhon ATM").

On or about April 5, 2020, PEDRO structured four cash deposits totaling $10,119, including one for

5
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$9,999. Based on my training and experience, and lmowledge of this case, I believe PEDRO structured

the cash deposits under $10,000 intentionally in order to avoid a fmancial institution's filing of a

Currency Transaction Report (CTR). PEDRO's JPMC account also received $~,500 in Zelle transfers

from various personal bank accounts, including the two accounts belonging to M.J. and B.P. See supra

at para. 10, 12. PEDRO's JPMC debit card, ending in 5213, was linked to a Cash App account

registered to EZEIRUAKU. EZEIRUAKU's Cash App handle was "Glockboyz." From on or about

April 13, 2020 through May 11, 2020, approximately $14,067 was transferred from EZEIRUAKU's

Cash App account into PEDRO's JPMC account. On or about April 29, 2020, PEDRO's JPMC account

received a deposit of $1,200 via direct deposit from the Internal Revenue Service, U.S. Treasury. This

payment represented PEDRO's legitimate U.S. Treasury EIP check.6

14. From on or about April 13, 2020 through May 12, 2020, the vast majority of the

aforementioned PEDRO JPMC deposits were withdrawn through ATM withdrawals, Cash App

transfers, Zelle bank transfers, wire transfers, and debit card purchases. Approximately $14,860 was

withdrawn at the JPMC Marhon ATM and another JPMC A TM in Cinnaminson, New Jersey. JPMC

provided surveillance footage of the ATM withdrawals on May 5, 2020 and May 12, 2020. On both

dates, EZEIRUAKU was recorded on video surveillance removing funds from the JPMC ATM.

Investigators identified multiple Cash App accounts that received money from PEDRO's JPMC personal

account, including a payment to KNIGHT's Cash App account, identified as "Glo." Investigators also

identified multiple debit card purchases made with PEDRO's JPMC personal account. These purchases

included USPS money orders that were subsequently used to pay monthly rent for an apartment leased

to EZEIRUAKU and a relative of PEDRO, located in Marlton, New Jersey. Investigators also identified

two wire transfers from PEDRO's JPMC account to a car auction in North Miami Beach, Florida. On or

6 PEDRO only earned approximately $5,304.39 during the first quarter of 2020.

6
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about April 20, 2020, and April 23, 2020, two transfers, one for $8,073 and a second for $10,013, for the

purchase of one 2013 Mercedes Benz CLS 550 4M and one 2018 Dodge Charger R/f. Both invoices

were billed to Show Ready Car, LLC,7 a business with an address in Berlin, New Jersey, although

paperwork associated with the vehicles listed EZEIRUAKU as the purchaser. Investigators learned that

the address is a private residence that EZEIRUAKU uses. 8 Between April 15, 2020 and September 22,

2020, EZEIRUAKU purchased six luxury vehicles,9 each costing between approximately $10,000 and

$12,000. On or about June 4, 2020, PEDRO deposited approximately $11,158 in cash into her relative's

personal bank account. to Immediately after the deposit, the funds were wired to the same car auction in

North Miami Beach, Florida, to purchase one 2016 Dodge Challenger. EZEIRUAKU is identified as the

purchaser in the auction paperwork. Based on my training and experience, and in the context of this

investigation, I believe that PEDRO and others used her JPMC account to funnel and launder illicit

proceeds from the counterfeit U.S. Treasury EIP check fraud scheme.

ii. May 4, 2020 Fraudulent Activity-Account holder"T.G."

15. Investigators identified an account holder, identified herein as ''T.G.," who had

counterfeit U.S. Treasury EIP checks deposited into his/her Bank of America personal bank account.

T.G. was named as the payee on the counterfeit U.S. Treasury EIP check.

16. On or about May 4, 2020, EZEIRUAKU and PEDRO were recorded on bank

surveillance footage depositing Counterfeit EIP Check A in the amount of $2,400, payable to T.G., into

7 SHOULTZ lists "Show Ready Car LLC" as his employer according to his Facebook account using the handle

"Ali Mucci."
8 The invoice to "Show Ready Car LLC" also included a phone number and email, both known by investigators to
belong to EZEIRUAKU.
9 The vehicles were one 2013 Mercedes-BenzCLS 550, one 2018 Dodge Charger, one 2015 Dodge Challenger,

one 2016 Infinity Q50, one 2011 BMW 550.
10 Based in part on the facts discussed within this affidavit, JPMC closed PEDRO's personal bank account

Subsequently, PEDRO used her relative's Bank of Princeton account to deposit and wire money obtained from
the fraud scheme.

7
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10/19/2020

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