Indictment — United States v. Moktar Hassan Aden et al. (D. Minn., Dkt. 1)

Summary

An indictment in United States v. Aden, et al., Case No. 0:25-cr-00349, in the U.S. District Court for the District of Minnesota, filed September 17, 2025 (Doc. 1). It names Moktar Hassan Aden, Mustafa Dayib Ali, Khalid Ahmed Dayib and Abdifitah Mohamud Mohamed as defendants. The grand jury alleges a scheme to defraud Minnesota's Housing Stability Services Program through Brilliant Minds Services LLC, which it says submitted reimbursement claims totaling about $2.3 million between approximately September 2022 and April 2025. Counts 1-6 (Wire Fraud) charge violations of 18 U.S.C. § 1343, and the forfeiture allegations cite 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c).

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UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
UNITED STATES OF AMERICA, INDICTMENT
Plaintiff 18 U.S.C. § 1343
18 U.S.C. § 981(a)(1)(C)
v. 21 U.S.C. § 853(p)

28 U.S.C. § 2461(c)
1. MOKTAR HASSAN ADEN,
2. MUSTAFA DAYIB ALI,
3. KHALID AHMED DAYIB, and
4. ABDIFITAH MOHAMUD MOHAMED,
Defendants.

THE UNITED STATES GRAND JURY CHARGES THAT:

At times relevant to this Indictment:

1. The defendants devised and carried out a scheme to defraud federally
funded health care benefits collected within Minnesota’s Housing Stability Services
Program. That was a program designed to help people with disabilities and addictions
find and maintain housing. Rather than provide such help, the defendants obtained
and misappropriated millions of dollars in program funds that were intended as

reimbursements for services provided to those people.

A. Background on Minnesota’s Housing Stability Services Program

2. In July 2020, Minnesota became the first state in the country to offer
Medicaid coverage for Housing Stabilization Services. The Housing Stabilization
Services Program is a Medical Assistance (that is, Medicaid) benefit designed to help
people with disabilities, including seniors and people with mental illnesses and

substance use disorders, find and maintain housing.

SCANNED

mat SEP 17 2025
U.S. DISTRICT COURT MPLS
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United States v. Aden, et al.

3. The Program permitted reimbursements for four principal kinds of

services:

(a) Housing consultation, during which a consultant (like a social] worker or
nurse) helps a beneficiary complete a Department of Human Services form
called a “Person-Centered, Housing Focused Plan.” The Plan is a form
available from the Department of Human Services. It requires minimal

information. Consultants could bill Medicaid about $174 for a consulting
session.

management of the beneficiary). For Sustaining services, too, providers can
bill about $68 per hour.

(d) Moving expenses of up to $3,000, subject to conditions.

4. By design, the Program had a low barrier to entry for new providers.

a documented disability or “disabling condition,” and be experiencing housing
instability. Program rules defined those final two conditions expansively. To receive
billable services, a beneficiary meeting these requirements just needed to complete,

with a Program-qualified consultant, a document called a Housing Focused Plan,
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United States v. Aden, et al.

detailing their housing challenges and needs. That done, the beneficiary could enroll
with a provider. And the provider could start billing for services provided.

6. To bill, a provider needed to submit only the names of the beneficiaries
serviced, the types of billable services provided, and the hours worked.

7. The HSS Program’s low barriers to entry and minimal records
requirements for reimbursement combined to make the Program susceptible to fraud.

8. Before the Program’s inaugural year, DHS predicted the Program would
cost about $2.6 million annually. That proved to be inaccurate. In 2021 alone, the
Program paid out more than $21 million in claims. That figure ballooned in the
following years: $42 million in 2022, $74 million in 2023, $104 million in 2024. In just
the first six months of 2025, the Program paid out another $61 million.

9. A federal investigation revealed that many Program providers
defrauded the system. These providers acquired the names of Program-eligible
beneficiaries from facilities like addiction treatment centers. They then used those
individuals’ information to submit inflated and fake reimbursement claims. In this
fashion, the providers acquired substantial pay-outs of taxpayer money to which they
were not entitled. They used those ill-gotten gains for their own enrichment.

B. The Defendants and Their Roles
10. MOKTAR HASSAN ADEN registered a company called Brilliant Minds

Services LLC (Brilliant Minds) with the Minnesota Secretary of State in or about
October 2020. In or about April 2022, ADEN and his co-defendants, KHALID DAYIB
and MUSTAFA ALI, completed paperwork to enroll Brilliant Minds as an HSS

Provider.
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United States v. Aden, et al.

11. ADEN, DAYIB, and ALI worked together with ABDIFITAH
MOHAMED to operate Brilliant Minds Services LLC as a provider in the HSS
Program.

12. ABDIFITAH MOHAMED also operated another Program provider.
That company was called Foundation First Services LLC. MOHAMED registered
Foundation First with the Minnesota Secretary of State in or about May 2023.
Through Foundation First, MOHAMED claimed to provide consultation services to
other HSS providers, including Brilliant Minds. There was a demand for such
services because HSS Program rules required each beneficiary to undergo a brief
housing consultation before receiving other reimbursable services from a Provider.
Foundation First was paid through the HSS Program for the consultation services it
claimed to have provided.

13. The defendants, along with their employees at Brilliant Minds, were
supposed to provide housing consulting, transitioning, and sustaining services to
qualifying people in need. Brilliant Minds was paid at quarter-hourly rates and with
Medicaid dollars based on the services it claimed to provide.

14. ‘In all, between approximately September 2022 and April 2025, Brilliant
Minds submitted reimbursement claims totaling about $2.3 million.

15. Between approximately May 2023 and April 2025, Foundation First

submitted reimbursement claims totaling about $222,000.
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United States v. Aden, et al.

The Scheme to Defraud the Housing Stability Services Program

16. From in or about October 2020 through in or about April 2025, in the
State and District of Minnesota, and elsewhere, the defendants,

MOKTAR HASSAN ADEN,
MUSTAFA DAYIB ALI,
KHALID AHMED DAYIB, and
ABDIFITAH MOHAMUD MOHAMED,

and others known and unknown to the grand jury, did knowingly devise and
participate in a scheme and artifice to defraud and to obtain money by means of
materially false and fraudulent pretenses, representations, and promises, and by
concealment of material facts.

17. The purpose of the scheme was to fraudulently obtain millions of dollars
in Housing Stability Services Program funds by causing the submission of fake and
inflated bills. The defendants were responsible for providing program-eligible
housing services through Brilliant Minds to people in need. However, in furtherance
of the scheme, the defendants and their conspirators caused the submission of false
claims information that significantly overrepresented the hours of services they
provided. In so doing, the defendants received HSS Program funds that substantially
exceeded the services they and their company provided.

18. In furtherance of the scheme to defraud, in or about April 2022, ADEN,
DAYIB, and ALI submitted paperwork to DHS for Brilliant Minds to operate as an
HSS provider. The defendants thereafter purported to service individuals in need
through Brilliant Minds from an office suite in the Griggs-Midway Building in St.

Paul, Minnesota.
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19. Also in furtherance of the scheme, for much of the time that the
defendants operated Brilliant Minds, MOHAMED operated Foundation First
Services. Like Brilliant Minds, MOHAMED operated Foundation First from an office
suite in the Griggs-Midway Building. Foundation First generated consultation
paperwork using the names of Program beneficiaries. By doing so, Foundation First
enabled other HSS providers, including Brilliant Minds, to bill for services
purportedly provided to those beneficiaries. Some of the consultation paperwork
Foundation First generated was fabricated.

20. Between about September 2022 and March 2023, ADEN and ALI
completed paperwork to enroll Brilliant Minds with Company A—an electronic
health records company. Using Company A’s services, Brilliant Minds submitted HSS
Program reimbursement claims to about nine different insurers.

21. Ultimately, the defendants claimed to service nearly 350 different
beneficiaries through Brilliant Minds and for such services claimed to be entitled to
nearly $2.3 million. From such claims, in 2024, Brilliant Minds LLC was one of the
ten highest-billing HSS providers state-wide.

22. But in reality, the defendants’ operations at Brilliant Minds provided
only a fraction of their claimed total.

23. The defendants diverted some of those taxpayer dollars to their
conspirators, and they kept much for themselves. At times in the scheme, all four
defendants had control of the Brilliant company bank account, into which their

claimed HSS reimbursements flowed. From about April 2023 through about
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May 2025, each of the defendants personally pocketed between about $300,000 and
$400,000 from Brilliant Minds.

24. The defendants also shared a Platinum American Express credit card,
on which they accrued nearly half a million dollars in charges to fund and enhance
their lifestyles. The defendants paid those charges using Brilliant Mind’s company
accounts.

Counts 1-6
(Wire Fraud)

25. Paragraphs 1 through 24 are incorporated herein.
26. Onor about the dates listed below, in the State and district of Minnesota
and elsewhere, the defendants,

MOKTAR HASSAN ADEN,
MUSTAFA DAYIB ALI,
KHALID AHMED DAYIB, and
ABDIFITAH MOHAMUD MOHAMED,
and others known and unknown to the grand jury, for the purpose of executing the
scheme described above, caused to be transmitted by means of wire communication

in interstate commerce the signals and sounds described below for each count, each

transmission constituting a separate count:

Count Date Wire Details
(on or about)
1 September 8, 2022 | An email from Brilliantmindservices@gmail.com

attaching a document named,
“MNeConnect_Chent_ONBOARDING_SHEET.pdf’

2 March 17, 2028 An email to Brilliantmindservices@gmail.com with
the subject, “Invoice 20242 from [Company A]”
3 April 18, 20238 An email to Brilliantmindservices@gmail.com with

the subject, “Your TIN registration was successful
and next steps.”
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United States v. Aden, et al.

4 April 25, 20238 An email from Brilliantmindservices@gmail.com
with the subject, “Re: Code.”
5 June 26, 2024 An email from Foundation First Services to

Brilliantmindservices@gmail.com with the subject,
“Housing Consultations.”

6 October 17, 2024 | An email from Brilliantmindservices@gmail.com
attaching two documents, one named

“Provider_EFT.pdf.”

All in violation of Title 18, United States Code, Section 1343.

FORFEITURE ALLEGATIONS

27. Counts 1 through 6 of this Indictment are incorporated by reference for
the purpose of alleging forfeiture pursuant to Title 18, United States Code,
Section 981(a)(1)(C) in conjunction with Title 28, United States Code, Section 2461(c).

28. If convicted of any of Counts 1 through 6 of this Indictment, the
defendant shall forfeit to the United States, pursuant to Title 18, United States Code,
Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c), any property,
real or personal, which constitutes or is derived from proceeds traceable to the offense
charged.

29. If any of the above-described forfeitable property 1s unavailable for
forfeiture, the United States intends to seek the forfeiture of substitute property as
provided for in Title 21, United States Code, Section 853(p) as incorporated by Title
28, United States Code, Section 2461(c).

A TRUE BILL

ACTING UNITED STATES ATTORNEY FOREPERSON


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