Case 1:20-mj-02121-AMD, Document 1 — Attachment A

Summary

A criminal complaint, Case 1:20-mj-02121-AMD, Document 1, filed 10/19/20 in the District of New Jersey, charging Daron Curry in Attachment A with conspiracy to commit bank fraud from about April 2020 through about October 2020. The supporting affidavit describes a nationwide effort using counterfeit U.S. Treasury Economic Impact Payment checks deposited into the accounts of recruited account holders, whose funds were withdrawn before banks detected the fraud. 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.

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Attachment A

(Conspiracy to Commit Bank Fraud)

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

DARON CURRY,

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 Js,

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:

I. 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 PIN. 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, ATMs, 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 ATM withdrawals or peer to peer payment platforms, thus depleting the

individua I 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 utilized 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 lnstagram, 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 .R residing 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 CleveJand, Ohio. Counterfeit EIP Check B was negotiated at Fifth Third
Bank on April 27, 2020.
• Counterfeit EIP Check C was issued on April 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, MaryJand,

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

i. May 3, 2020 Fraudulent Activity- Account Holder"S.K."

7. On or about May 3, 2020, Isaiah White ("WHITE") posted an advertisement to his

Instagram "story," 3 with a Bank of America receipt with the following caption, "Servin Instant buckets."

The image depicted information including the date, May 3, 2020, account information, and deposit

amount of $4,800. Investigators provided the details from this receipt to Bank of America who

identified the account holder, identified herein as "S.K.," who had three counterfeit U.S. Treasury EIP

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.
lnstagram accollllt 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.

3
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checks deposited into his/her Bank of America personal bank account. S.K. was named as the payee on

the counterfeit U.S. Treasury EIP check.

8. On or about May 3, 2020, WHITE deposited Counterfeit EIP Check C, in the amount of

$2,400 and payable to S.K., into S.K. 's Bank of America personal bank account. WHITE, who was

with Daron Curry ("CURRY"), 4 deposited the check twice at a Bank of America ATM in Philadelphia,

Pennsylvania. Several hours later, WHITE was recorded on video surveillance depositing another

Counterfeit EIP Check C, in the amount of $2,400 payable to S.K., into S.K.'s Bank of America

personal bank account at the same Bank of America A TM. S.K. 's account was used to transfer $1,000

through Zelle to WHITE's relative, identified herein as "C.White" and who resided in Snellville,

Georgia.

9. The next day, $5,530 was withdrawn from S.K.'s Bank of America personal bank

account through ATM withdrawals, Zelle transfers and Apple Cash peer-to-peer transfers. The ATM

withdrawals consisted of a $600 and $400 withdrawal from the Twin Oaks Bank of America ATM

located in Avondale Estates, in Georgia; these withdrawals were conducted by account holder S.K. The

Zelle transactions consisted of $1,000 transfers to C.White's bank account, and $2,550 to S.W. 5 at PNC

bank. The remaining money was transferred to unknown accounts.

10. Between May 1, 2020 and May 6, 2020, C.White received $11,842.50 through Zelle,

Cash App, and Apple Cash transfers into her Bank of America personal bank account from bank

accounts that were funded by counterfeit U.S. Treasury EIP checks. The Zelle transactions consisted of

four transfers totaling $3,440 from C.T. and a $1,000 transfer from S.K. The C.T. and S.K. Zelle

4
CURRY was observed on Bank of America surveillance footage accessing four different Bank of America
accounts, all of which involved counterfeit U.S. Treasury EIP check transactions. These accounts were all linked
to WHITE and/or his lnstagram advertisements.
5 Investigators linked S. W. to S.K. as current/fonner paramours.

4
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transfers originated from their Bank of America personal bank accounts that were funded by counterfeit

U.S. Treasury EIP checks.6 The Cash App transactions consisted of two transfers from C.White's Cash

App account balance into her personal Bank of America account.

11. From on or about May 4, 2020 through May 6, 2020, $11,791 was withdrawn from

C.White's Bank of America account through various peer-to-peer payments and ATM withdrawa1s.

C. White was recorded on video surveillance making five ATM withdrawals, totaling $4,500, from a

Bank of America A TM in Snellville, Georgia. $5,221.85 was transferred to four accounts through

Apple Cash. $645 was transferred to WHITE through Paypal and Cash App.

ii. May 2, 2020 Fraudulent Activity-Account holder"B.B."

12. On or about May 2, 2020, WHITE and Qwan Taylor ("TAYLOR") 7 posted the same

Bank of America receipt to their Instagram "stories." WHITE removed the deposit location information

and check posting date from the receipt with the caption "All BOA Instant 5k"8 while TA YLORdid not

conceal any information from the receipt and wrote "CHASIN I TOLD YA." Investigators provided the

details from this receipt to Bank of America who identified the account holder, identified herein as

"B.B."

13. On or about May 2, 2020, CURRY deposited Counterfeit EIP Check A, in the amount of

$4,200 and payable to B.B., into B.B.'s Bank of America personal bank account, at the Chestnut Street

ATM.

6 On or about May 4, 2020, Counterfeit EIP Check C, in the amount of$2,400 payable to S.K was deposited

three times into S.K 's Bank of America personal bank account. On or about May 5, 2020, Counterfeit EIP Check
C, in the amount of $1,200 payable to C. T., was deposited eight times into C. T. 's Bank of America personal bank
account.
7 TAYLOR is charged in a separate criminal complaint under 20-mj-2117.
8 ON' and "BOA" refer to Bank of America.

5
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14. On the same day, $2,300, CURRY withdrew $300 from a Bank of America A TM in

Philadelphia, Pennsylvania. The remaining funds were transferred through Cash App to another

account.

15. On or about May 3, 2020, Nakirah Matthews ("MA TIHEWS") posted an advertisement

to her Instagram "story," soliciting for Bank of America accounts with the promise of a $1,000 payout.

This advertisement included a Bank of America receipt showing a May 3, 3030 deposit, at 3:33 a.m., of

three checks, totaling $5,100. The advertisement was edited to conceal the deposit location and account

number, however Bank of America investigators were able to identify the account holder, identified

herein as "T.D." Investigators discovered that T.D. had two counterfeit U.S. Treasury EIP checks

deposited into his/her Bank of America account. T.D. and another account holder identified as "C.B."

were named as the payees on the counterfeit U.S. Treasury EIP checks.

16. On or about May 3, 2020, Justin Ezeiruaku (''EZEIRUAKU") 9 and Kwaeson Watts

("WA TIS") deposited one Counterfeit EIP Check A, in the amount of $1,700 and payable to T.D., into

T.D.'s Bank of America personal bank account. Video surveillance showed EZEIRUAKU and WATTS

depositing this check three times, for a total deposit of $5,100, at a Bank of America A TM in

Pennsauken, New Jersey.

17. Investigators also discovered that several hours prior, WA TIS and TAYLOR attempted

to deposit $4,600.37 into T.D.'s Bank of America personal account but the deposit was rejected by Bank

of America. Shortly after the attempted deposit, WA TIS and TAYLOR made a balance inquiry on

T.D. 's account, and again tried to make a deposit. Less than one hour later, TAYLOR and WA TIS

attempted again to deposit $1,700 into T.D. 's account, but the deposit was rejected. Nearly three hours

9
FZEIRUAKU is charged in a separatecriminalcomplaint under 20-mj-2109.

6
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10/19/2020

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