Complaint — No. 1:21-mj-05143 (Dkt. 1, W.D.N.Y.)

Summary

A criminal complaint (AO 91) against Hormoz Mansouri in the United States District Court for the Western District of New York, Case 1:21-mj-05143-MJR, filed August 3, 2021 as Document 1 and sworn telephonically before United States Magistrate Judge Michael J. Roemer. It charges Wire Fraud, Bank Fraud, Conspiracy to Commit Wire Fraud and Bank Fraud, and Money Laundering under Title 18, United States Code, Sections 1343, 1344, 1349, 1956, and 1957, between in or about March 2020 and in or about May 2021. The affidavit of FBI Special Agent Allan Rains alleges that Mansouri and others submitted PPP and EIDL loan applications with materially false statements for entities Mansouri operates, including HLM Holding LLC, and moved the funds through numerous bank accounts. It states that Mansouri transferred or paid approximately $644,805 to a casino between April 2020 and May 2021.

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