Affidavit in Support of Criminal Complaint — United States v. Randy Frasinelli (Dkt. 2-1, April 14, 2021)

Summary

This is an Affidavit in Support of Criminal Complaint, Magistrate No. 21-813, in the Western District of Pennsylvania, sworn by Special Agent (SA) Sean Langford of the Federal Bureau of Investigation (FBI) against Randy Frasinelli, with an [UNDER SEAL] caption. It states there is probable cause to believe he committed bank fraud (18 U.S.C. § 1344) and money laundering (18 U.S.C. § 1957(a)). The affiant says Frasinelli claims to be sole proprietor of four companies and that, between approximately May 2020 and July 2020, he fraudulently applied for and obtained a Paycheck Protection Program loan for each. It describes a Dollar Bank application requesting $509,000 for Grant-Williams Associates Corporation, with average monthly payroll of $203,600 and 23 employees, and says Pennsylvania Department of Revenue records showed no registration or W-2 wage reports for that company.

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“Affidavit in Support of Criminal Complaint — United States v. Randy Frasinelli (Dkt. 2-1, April 14, 2021).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-2-21-mj-00813-dkt-2-1-108010f1c1/, SHA-256 3a282c09849d39687695913aae0b5c21b5901ee5572a51deeb948b072737bb6f.

Full text

Case 2:21-mj-00813-CRE Document 2-1 Filed 04/14/21 Page 1 of 22

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA )
) Magistrate No. 21-813
v. ) [UNDER SEAL]
)
RANDY FRASINELLI )

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

I, Special Agent (SA) Sean Langford, being duly sworn according to law, depose and say

as follows:

1. This affidavit is made in support of a request for a criminal complaint and arrest

warrant against Randy Frasinelli. For the reasons below, there is probable cause to believe that

Randy Frasinelli has committed bank fraud, in violation of 18 U.S.C. § 1344, and money

laundering, in violation of 18 U.S.C. § 1957(a).

2. Affiant is a Special Agent of the Federal Bureau of Investigation (FBI), United

States Department of Justice (USDOJ), and has been so employed for over sixteen years. Since

March 2011, Affiant has been with the Pittsburgh Division assigned to a white-collar and public

corruption crime squad. In the course of my training and experience, Affiant has become familiar

with the methods and techniques associated with the investigations of white-collar schemes to

defraud. My experience as an FBI Special Agent has included the investigation of cases involving

public corruption, bank fraud, mail fraud, wire fraud, money laundering, bankruptcy fraud, and

other financial crimes, and I have enforced federal laws prohibiting these offenses.

3. The facts in this Affidavit come from my personal investigation, witness

interviews, a review of records, including certain records obtained via grand jury subpoena, and

through other investigative techniques.

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4. Since this Affidavit is being submitted for the purpose of securing a criminal

complaint, I am not including each and every fact known to me in this investigation.

OVERVIEW OF THE “CARES” ACT

5. In response to the coronavirus pandemic and economic crisis, Congress passed the

Coronavirus Aid, Relief, and Economic Security (“CARES”) Act. The CARES Act was signed

into law on March 27, 2020, and included funding for the Paycheck Protection Program (PPP).

6. In order to obtain a PPP loan, a qualifying business must submit a PPP loan

application, which is signed by an authorized representative of the business. The PPP loan

application requires the business (through its authorized representative) to acknowledge the

program rules and make certain affirmative certifications in order to be eligible to obtain the PPP

loan. In the PPP loan application, the small business (through its authorized representative) must

state, among other things, its: (a) average monthly payroll expenses; and (b) number of employees.

These figures are used to calculate the amount of money the small business is eligible to receive

under the PPP. In addition, businesses applying for a PPP loan must provide documentation

showing their payroll expenses.

7. A PPP loan application includes the following certifications (emphasis added):

a. The Applicant was in operation on February 15, 2020 and had employees for

whom it paid salaries and payroll taxes or paid independent contractors, as

reported on Form(s) 1099-MISC.

b. Current economic uncertainty makes this loan request necessary to support the

ongoing operations of the Applicant.

c. The funds will be used to retain workers and maintain payroll or make

mortgage interest payments, lease payments, and utility payments, as specified

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under the Paycheck Protection Program Rule; I understand that if the funds are

knowingly used for unauthorized purposes, the federal government may hold

me legally liable, such as for charges of fraud.

d. The Applicant will provide to the Lender documentation verifying the number

of full-time equivalent employees on the Applicant’s payroll as well as the

dollar amounts of payroll costs, covered mortgage interest payments, covered

rent payments, and covered utilities for the eight-week period following this

loan.

e. The Applicant further certifies that the information provided in this application

and the information provided in all supporting documents and forms is true and

accurate in all material respects. I understand that knowingly making a false

statement to obtain a guaranteed loan from SBA is punishable under the law,

including under 18 USC 1001 and 3571 by imprisonment of not more than five

years and/or a fine of up to $250,000; under 15 USC 645 by imprisonment of

not more than two years and/or a fine of not more than $5,000; and if submitted

to a federally insured institution, under 18 USC 1014 by imprisonment of not

more than thirty years and/or a fine of not more than $1,000,000.

8. A PPP loan application must be processed by an authorized Small Business

Administration (SBA) lender. If an application is approved, the participating lender funds the PPP

loan using its own monies, which are 100% guaranteed by the SBA. Data from the application,

including information about the borrower, the total amount of the loan, and the listed number of

employees, is transmitted by the lender to the SBA in the course of processing the loan.

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9. PPP loan proceeds must be used by the business on certain permissible expenses –

payroll costs, interest on mortgages, rent, and utilities. The PPP allows the interest and principal

on the PPP loan to be entirely forgiven if the business spends the loan proceeds on these expense

items within a designated period of time and uses a certain percentage of the PPP loan proceeds

on payroll expenses.

PROBABLE CAUSE

10. Randy A. Frasinelli claims to be the sole proprietor of four different companies:

Grant-Williams Associates (GWA), Grant-Williams Global (GWG), Grant-Williams International

(GWI), and Grant-Williams Associates Corporation (GWAC).

11. Open-source internet searches discovered a LinkedIn account for Randy A.

Frasinelli. The LinkedIn site details Frasinelli earned an undergraduate degree from the University

of Pittsburgh in 1986, an MBA from Cornell University in 1988, and a Ph.D. from Carnegie Mellon

University in 2003. In addition, the LinkedIn site details Frasinelli is the Founder & Global

Managing Director for Grant-Williams Associates, operating in the Greater Pittsburgh Region,

from January 1995 to present.

12. A description of Grant-Williams Associates, as detailed on Frasinelli’s LinkedIn

page, is as follows: “Extensive experience and interest in global affairs and domestic political

policy. Classified technology advisory experience thoughout [sic] the U.S. and Europe. Active

volunteer and committee member for numerous children's charities as well for a variety of national

and international non-profit agencies. Professional direction is toward the matching of Senior

Level professionals within a dynamic corporate culture or culture of an emerging growth

technology driven organization. Our commitment is toward matching professionals for the positive

professional and cultural effect that they can discharge within our client organization.”

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13. A description of Frasinelli’s experience as Managing Director is detailed on

Frasinelli’s LinkedIn account as follows: “Technology advisor to advanced technology companies

on a global basis working on the development and release of classified technology products that

are developed and sold to major defense contractors and defense department in the US, UK, Israel

and other (friendly) countries across the globe. Retained executive search for emerging growth to

Fortune 500 Corporations thoughout [sic] the U.S. & Europe. Very hands-on consultative approach

to recruiting working in this manner with the client and the candidates.”

14. During the investigation, your Affiant noted that between approximately May 2020

and July 2020, Frasinelli fraudulently applied for and obtained a PPP Loan for each of his four

companies: Grant-Williams Associates (GWA), Grant-Williams Global (GWG), Grant-Williams

International (GWI), and Grant-Williams Associates Corporation (GWAC). Frasinelli obtained

GWAC’s PPP Loan from Dollar Bank and the GWA, GWG, and GWI PPP Loans from Bank of

America. Both Dollar Bank and Bank of America are federally insured financial institutions.

Fraudulent Dollar Bank PPP Loan Application

15. On or about June 26, 2020, at approximately 1:12PM, Frasinelli sent an email to

Dollar Bank with the following detailed in the subject line: re: PPP Loan application information

(Grant-Williams Associates Corp). In the body of the email, Frasinelli wrote “Please find attached

all of the documents for my PPP loan application for my company; Grant-Williams Associates

Corp.” Frasinelli’s email signature detailed he is the Managing Director, Grant-Williams, with an

email of randy@grantwilliamsglobal.com, and a reference to his LinkedIn account detailed above

in paragraphs 11-13.

16. The PPP loan application and supporting documentation Frasinelli enclosed in the

email certified that Frasinelli held the title of President of Grant-Williams Associates Corporation,

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that he was also 100% owner of the company, and that he resided at 126 Lindsay Road, Carnegie,

PA 15106.

17. Attached to the email, Frasinelli included the Paycheck Protection Program

Borrower Application Form requesting a loan in the amount of $509,000. In reviewing the

Application, your Affiant noted Frasinelli made the following certifications:

a. The Business Legal Name applying for the PPP Loan is Grant-Williams

Associates Corporation.

b. Grant-Williams Associates Corporation has an IRS Employer ID Number

(EIN) of 26-1724863.

c. Grant-Williams Associates Corporation’s business address is 301 Grant Street,

One Oxford Centre, 43rd Floor, Pittsburgh, PA 15219.

d. Grant-Williams Associates Corporation’s average monthly payroll is $203,600

and the number of employees is “23”.

18. Additional attachments to the June 26, 2020 1:12PM email also included an

Amended IRS Form 940 for the tax year 2019, and an IRS Form 941 for the 1st Quarter of tax year

2020.

19. The Amended IRS Form 940 indicated the name of the company was Grant-

Williams Associates Corp., with an EIN of 26-1724863. The form also indicated “Total payments

to all employees” for the year 2019 was $3,588,000.

20. The IRS Form 941 for the 1st Quarter of 2020 indicated the name of the company

was Grant-Williams Associates Corp., with an EIN of 26-1724863. The form also indicated the

number of employees who received wages, tips, or other compensation for the pay period was 23,

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with actual wages, tips, and other compensation of $897,000 for the quarter, and Federal income

tax withheld of $179,400.

21. On or about June 26, 2020, Frasinelli had an email exchange with two Dollar Bank

officials regarding the Grant-Williams Associates Corp (GWAC) loan application. In the email

exchange, Dollar Bank official M.S. directs Dollar Bank official R.O. to request from Frasinelli

“a break down of salaries showing what employees earned over $100K.” M.S. also directs R.O.

to obtain “copies of the documents showing what state and local taxes were paid by the employer.”

22. Dollar Bank official R.O. next sent an email to Frasinelli, incorporating the request

from M.S. R.O. wrote to Frasinelli: “Thank you for the opportunity to talk with you today. Please

see the requested items below.” In the email to Frasinelli, R.O. was referring to Dollar Bank

official M.S.’ request for employee compensation and tax information paid by Grant-Williams

Associates Corporation.

23. Later that afternoon, on or about June 26, 2020 at approximately 5:46PM, Frasinelli

sends Dollar Bank officials R.O. and M.S. an email stating “Sorry for the delay, as I needed to

track down my assistant/accountant “Jenn” in Boston. I am attaching our 2019 PA State/Local tax

form and a payroll report prepared for us back in April by ADP specially for use with the Cares

Act. ALL 23 members of the members of our team are at the same salary of $156,000. No

one on the team has been paid since March and our upcoming work is developing slower than

anticipated. This PPP program would be a life saver for us.”

24. Frasinelli attached two forms in this email to Dollar Bank officials R.O. and M.S.

The first form was a copy of a handwritten Pennsylvania Department of Revenue Annual

Withholding Reconciliation Statement for Grant-Williams Associates, with EIN 26-172486, for

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the 2019 tax year. The second form was purportedly an ADP 2020 CARES SBA - PPP: Monthly

Payroll Cost report for Grant-Williams Associates.

25. The PA DOR Annual Withholding Reconciliation Statement details that the

number of employees on the payroll, and having received a W-2, was “23”. In addition, the form

details the Total compensation/distribution subject to PA withholding was $3,588,000 for the tax

year 2019. In addition, the form details the PA personal income tax withheld by Grant-Williams

Associates Corporation from its 23 employees was $449,912 for the tax year 2019. At the bottom

of the form, Frasinelli signs the document as “President” purportedly on or about February 21,

2020.

26. The ADP PPP: Monthly Payroll Cost report is dated April 4, 2020 and has the

company name “Grant-Williams Associates” towards the top of the report. The report contains

purported monthly payroll from January 2019 to December 2019. There are four columns on the

report detailing “SBA Gross Pay, Employer Taxes State and Local, Employer Taxes SS/Med, and

total Payroll Cost”. The total SBA Payroll column detailing purported payroll for the tax year

2019 is $3,588,000. The total Employer Taxes State and Local column shows $143,520, and the

total Employer Taxes SS/Med column shows $449,912.

27. After reviewing the two forms Frasinelli emailed the two Dollar Bank officials,

your Affiant noted the total SBA Payroll column on the purported ADP form matches the Total

compensation/distribution subject to PA withholding on the purported PA DOR Annual

Withholding Reconciliation Statement. However, the total Employer Taxes State and Local on

the purported ADP form of $143,520 does not match the PA personal income tax withheld by the

company as shown on the PA DOR Annual Withholding Reconciliation Statement, $449,912.

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28. Another form Frasinelli provided to Dollar Bank to support his PPP loan

application for Grant-Williams Associates Corporation was the company’s purported SS-4 EIN

notice letter. The SS-4 EIN notice letter detailed Grant-Williams Associates Corporation’s EIN

as 26-1724863. An EIN is required by companies in order to pay and file payroll and payroll taxes.

The date of the notice letter is June 2, 2020. Your Affiant notes the date of this letter is obviously

well after the tax year 2019 in which Frasinelli is claiming Grant-Williams Associates Corporation

had payroll costs, as claimed on the purported ADP report, PA DOR form, IRS Form 940, and IRS

Form 941 Frasinelli provided to Dollar Bank to support his PPP loan application.

29. Your Affiant received records from the Commonwealth of Pennsylvania

Department of Revenue (PA DOR) relating to Grant-Williams Associates Corporation (GWAC).

The PA DOR certified the following information:

a. There were no Pennsylvania Business Entity Registration records for GWAC

or EIN 26-1724863.

b. There were no W-2 Wages and Withholding Reports for employees of GWAC

or EIN 26-1724863 for the tax years 2019 or 2020.

c. The PA DOR Annual Withholding Reconciliation Statement Frasinelli

provided to Dollar Bank in support of his GWAC PPP Loan application was

never received by the PA DOR.

30. Your Affiant received records from ADP relating to Grant-Williams Associates

Corporation (GWAC). ADP certified the following information:

a. ADP was unable to locate a record of an ADP payroll client by the name of

Grant-Williams Associates Corporation.

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b. ADP was unable to locate a record of a payroll client with the EIN of 26-

1724863.

c. ADP did not create the 2020 CARES SBA – PPP Monthly Payroll Cost report

document Frasinelli provided to Dollar Bank in support of his GWAC PPP

Loan application.

31. Your Affiant observed the business address Frasinelli claimed on his Dollar Bank

PPP Loan application was the address for Grant-Williams Associates Corporation (GWAC), 301

Grant Street, One Oxford Centre, 43rd Floor, Pittsburgh, PA 15219.

32. The address 301 Grant Street, One Oxford Centre, 43rd Floor, Pittsburgh, PA 15219

is the location for Regus in Pittsburgh. Regus is a company that provides serviced offices, virtual

offices, meeting rooms, and videoconferencing to clients on a contract basis.

33. Your Affiant interviewed the Regus Community Manager, H.P., for this Regus

office location. H.P. advised Frasinelli and/or GWAC are not current clients renting office space

and/or business services from Regus. H.P. further advised the name Frasinelli or any of Frasinelli’s

companies, GWAC, GWA, GWG, or GWI, are not familiar to H.P. H.P. has been working at this

location for almost six years.

Fraudulent Bank of America PPP Loan Applications

34. Frasinelli applied for and received three PPP Loans from Bank of America in the

name of Grant-Williams Associates, Grant-Williams Global, and Grant-Williams International in

the amounts of $207,082, $525,000, and $1,304,000, respectively.

35. In each of these PPP Loans, Frasinelli claimed the business address was 126

Lindsay Road, Carnegie, PA 15106. This address is also known to be Frasinelli’s personal

residence.

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36. In each of the PPP Loan applications, Frasinelli indicated what the average monthly

payroll was for the company in order to calculate the PPP Loan amount requested. In addition,

Frasinelli was required to provide documentation to support the average monthly payroll figures.

37. In the PPP Loan application for Grant-Williams Associates (GWA), Frasinelli

claimed GWA had six (6) employees with an average monthly payroll for 2019 of $82,833. To

support this claim, Frasinelli provided a Federal Form 940 for 2019: Employer’s Annual Federal

Unemployment Tax Return. The Form 940 detailed Grant-Williams Associates as the company

name, with an EIN of 20-2462537, an address of 126 Lindsay Road, Carnegie, PA 15106, and total

payroll for the tax year 2019 of $993,996. In dividing the total payroll for the year, Frasinelli came

up with the average monthly payroll of $82,833.

38. To come up with the PPP Loan amount requested, the average monthly payroll is

multiplied by a factor of 2.5. To calculate the PPP Loan amount for GWA, Frasinelli multiplied

the $82,833 by the factor of 2.5 to come up with the loan amount of $207,082.

39. In the PPP Loan application for Grant-Williams Global (GWG), Frasinelli claimed

GWG had twelve (12) employees with an average monthly payroll for 2019 of $210,000. To

support this claim, Frasinelli provided a Federal Form 940 for 2019: Employer’s Annual Federal

Unemployment Tax Return. The Form 940 detailed Grant-Williams Global as the company name,

with an EIN of 85-1260543, an address of 126 Lindsay Road, Carnegie, PA 15106, and total

payroll for the tax year 2019 of $2,520,000. In dividing the total payroll for the year, Frasinelli

came up with the average monthly payroll of $210,000.

40. To come up with the PPP Loan amount requested, the average monthly payroll is

multiplied by a factor of 2.5. To calculate the PPP Loan amount for GWG, Frasinelli multiplied

the $210,000 by the factor of 2.5 to come up with the loan amount of $525,000.

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41. In the PPP Loan application for Grant-Williams International (GWI), Frasinelli

claimed GWI had sixty-five (65) employees with an average monthly payroll for 2019 of

$521,600. He also represented that GWI was assigned an EIN of 85-1260042 and had a business

address of 126 Lindsay Road, Carnegie, PA 15106. To support this claim, Frasinelli provided a

Federal Form 940 for 2019: Employer’s Annual Federal Unemployment Tax Return. The Form

940 detailed Grant-Williams International as the company name, with an EIN of 85-1260042, an

address of 126 Lindsay Road, Carnegie, PA 15106, and total payroll for the tax year 2019 of

$6,432,000. Dividing that figure by 12 months would yield the average monthly payroll of

$536,000, which matches an early version of a GWI application Frasinelli submitted to Bank of

America. However, the final GWI application submitted by Frasinelli detailed an average monthly

payroll of $521,600. Affiant did not note any supporting documentation in the application to

explain the discrepancy of the two different average monthly payroll figures, $536,000 supported

by the payroll tax forms Frasinelli provided the bank and the $521,600 ultimately used to calculate

the loan amount approved.

42. To come up with the PPP Loan amount requested, the average monthly payroll is

multiplied by a factor of 2.5. To calculate the PPP Loan amount for GWI, Frasinelli multiplied

the $521,600 by the factor of 2.5 to come up with the loan amount of $1,304,000.

43. Your Affiant received records from the Commonwealth of Pennsylvania

Department of Revenue (PA DOR) relating to Grant-Williams Associates (GWA), Grant-Williams

Global (GWG), and Grant-Williams International (GWI). The PA DOR certified the following

information:

a. There were no Pennsylvania Business Entity Registration records for GWA or

EIN 20-2462537, GWG or EIN 85-1260543, or GWI.

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b. There were no W-2 Wages and Withholding Reports for employees of GWA or

EIN 20-2462537, GWG or EIN 85-1260543, or GWI for the tax years 2019 or

2020.

44. Your Affiant received records from ADP relating to Grant-Williams Associates

(GWA), Grant-Williams Global (GWG), and Grant-Williams International (GWI). ADP certified

the following information:

a. ADP was unable to locate a record of an ADP payroll client by the name of

Grant-Williams Associates, Grant-Williams Global, or Grant-Williams

International.

b. ADP was unable to locate a record of a payroll client with the EIN of 20-

2462537 or 85-1260543.

Fraudulent Use of PPP Loan Proceeds

45. As part of the investigation, Affiant has obtained signature cards and bank account

statements for the Grant-Williams Associates Corporation (GWAC) Dollar Bank account, X9209,

and the Grant-Williams Associates (GWA), Grant-Williams Global (GWG), and Grant-Williams

International (GWI) Bank of America accounts, X0375, X0618, and X0049, respectively. In

addition, your Affiant has conducted a thorough review and analysis of the Dollar Bank GWAC

account and all three Bank of America accounts, in addition to other records obtained during the

investigation.

46. Randy A. Frasinelli is the only authorized signer for the Dollar Bank account

X9209, and each of the three Bank of America accounts, X0375, X0618, and X0049.

47. The analysis of the financial records confirms that Frasinelli disbursed the proceeds

of all four PPP Loans in a manner inconsistent with and contrary to the certifications Frasinelli

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made when applying for the PPP Loans. Specifically, the disbursements do not appear to be

necessary to support ongoing operations of GWAC, GWA, GWG, or GWI. In addition, it does

not appear that the four PPP Loan proceeds were used at all to retain workers and maintain payroll,

make mortgage interest payments, lease payments, and utility payments, as specified under the

Paycheck Protection Program Rule.

Grant-Williams Associates Corp (GWAC) PPP Loan Proceeds

48. Your Affiant obtained records for the Grant-Williams Associates Corporation

(GWAC) Dollar Bank account ending in X9209 for the time period of June 26, 2020 to February

28, 2021.

49. On or about July 3, 2020, $509,000 was electronically deposited into Frasinelli’s

Grant-Williams Associates Corporation (GWAC) Dollar Bank account ending in X9209. The

$509,000 deposit is loan proceeds for GWAC’s PPP Loan that Frasinelli applied for and obtained

from Dollar Bank.

50. On June 26, 2020, prior to the PPP loan deposit, the balance in the account was

$0.00. This account was opened on or about June 26, 2020. Other than the PPP loan proceeds

deposit on July 3, 2020, there was only a cash counter deposit of $15.48, on or about June 26,

2020, an incoming wire deposit of $5,000 from GWG’s Bank of America account X0618 on or

about June 26, 2020, and a $400 ATM deposit, on or about November 16, 2020. There were no

business revenues deposited into this account during the period reviewed, June 26, 2020 to

February 28, 2021.

51. The financial records show that the GWAC PPP loan proceeds of $509,000 were

utilized by Frasinelli for personal use and not to retain workers, maintain payroll, or make

mortgage interest payments, lease payments, and utility payments for GWAC. From a review of

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the bank records, Affiant did not note any payroll, mortgage, lease, or utility payments from

GWAC for the time period June 26, 2020 to February 28, 2021. On February 4, 2021, this account

was frozen and seized by the government with a balance of $428.98.

52. On or about July 6, 2020, Frasinelli wired $500,000 from the GWAC Dollar Bank

account X9209 to the GWG Bank of America account X0618. Per the PPP Loan program, PPP

loan proceeds are only to be used for the company in whose name the PPP Loan application was

obtained. See below paragraphs 59-63 for a description of how Frasinelli used the $500,000

GWAC PPP loan proceeds after Frasinelli wired them to the GWG Bank of America account

X0618.

53. Examples of how Frasinelli used the remaining GWAC PPP loan proceeds, after

wiring $500,000 to the GWG Bank of America account, include food, wine and spirits, dining out,

retail store purchases, and ATM cash withdrawals.

Grant-Williams Associates (GWA) PPP Loan Proceeds

54. Affiant obtained records for the Grant-Williams Associates (GWA) Bank of

America account ending in X0375 for the time period of May 1, 2020 to February 28, 2021.

55. On or about May 4, 2020, $125,000 was electronically deposited into Frasinelli’s

Grant-Williams Associates (GWA) Bank of America account ending in X0375. The deposit was

detailed on the bank statement as “Cares Act Paycheck Protection Program Deposit”. In addition,

on or about May 27, 2020, $82,082 was electronically deposited into the GWA Bank of America

account ending in X0375. The deposit was detailed on the bank statement as “Cares Act Paycheck

Protection Program Deposit - ADJ”.

56. On May 1, 2020, prior to the PPP loan deposits, the balance in the account was in

overdraft status with a negative balance of -$515.06. Other than the PPP loan proceed deposits,

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on May 4, 2020 and May 27, 2020, and incoming account transfers from the Grant-Williams

International (GWI) and Grant-Williams Global (GWG) Bank of America accounts ending in

X0049 and X0618 respectively, there were no business revenues deposited into this account. The

GWI and GWG incoming account transfers, $44,800 and $13,000, respectively, were disbursed

directly from GWI and GWG’s PPP loan proceeds. PPP loan proceeds are only to be used for the

company in whose name the PPP Loan application was obtained.

57. The financial records show that the GWA PPP loan proceeds of approximately

$207,082, in addition to GWI’s $44,800 and GWG’s $13,000 PPP loan proceeds, were utilized by

Frasinelli for personal use and not to retain workers, maintain payroll, or make mortgage interest

payments, lease payments, and utility payments for any of the companies. From a review of the

bank records, Affiant did not note any payroll, mortgage, lease, or utility payments on behalf of

GWA for the time period May 1, 2020 to February 28, 2021. On February 4, 2021, this account

was frozen and seized by the government with a balance of $788.45.

58. Examples of Frasinelli’s personal use of the GWA, GWG, and GWI PPP loan

proceeds include, Amazon.com and PayPal purchases, food and wine purchases, firearms

purchases, vacation trips, both domestically and internationally, for himself and family members,

college tuition payments for family members, as well as direct payments to multiple Frasinelli

family members.

Grant-Williams Global (GWG) PPP Loan Proceeds

59. Affiant obtained records for the Grant-Williams Global (GWG) Bank of America

account ending in X0618 for the time period of June 5, 2020 to February 28, 2021.

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60. On or about June 11, 2020, $525,000 was electronically deposited into Frasinelli’s

Grant-Williams Global (GWG) Bank of America account ending in X0618. The deposit was

detailed on the bank statement as “Cares Act Paycheck Protection Program Deposit”.

61. On June 5, 2020, prior to the PPP loan deposit, the balance in the account was

$0.00. This account was opened on or about June 5, 2020. Other than the PPP loan proceeds

deposit on June 11, 2020, and incoming account transfers from the GWI and GWA Bank of

America accounts, ending in X0049 and X0375 respectively, and a GWAC account maintained at

Dollar Bank, there were no business revenues deposited into this account. The Dollar Bank

incoming transfer was on July 6, 2020 in the amount of $500,000. The GWI, GWA, and GWAC

incoming account transfers, $1,181,700, $2,000, and $500,000, respectively, were disbursed

directly from GWI, GWA, and GWAC’s PPP loan proceeds. PPP loan proceeds are only to be

used for the company in whose name the PPP Loan application was obtained.

62. The financial records show that the GWG PPP loan proceeds of $525,000, in

addition to the $1,181,700, $2,000, and $500,000 GWI, GWA, and GWAC PPP loan proceeds,

were utilized by Frasinelli for personal use and not to retain workers, maintain payroll, or make

mortgage interest payments, lease payments, and utility payments for any of the companies. From

a review of the bank records, Affiant did not note any payroll, mortgage, lease, or utility payments

from GWG for the time period June 5, 2020 to February 28, 2021. On February 4, 2021, this

account was frozen and seized by the government with a balance of $891.70.

63. Examples of Frasinelli’s personal use of the GWG, GWI, GWA, and GWAC PPP

loan proceeds include, PayPal purchases, personal vehicle expenses, firearms purchases, vacation

trips, both domestically and internationally, for himself and family members, college tuition

payments for family members, the purchase of precious metals from on-line dealers, as well as

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direct payments to multiple Frasinelli family members. In addition, Frasinelli wired approximately

$1,820,000 to accounts maintained in his name at Fidelity Investments.

Grant-Williams International (GWI) PPP Loan Proceeds

64. Affiant obtained records for the Grant-Williams Global (GWI) Bank of America

account ending in X0049 for the time period of June 29, 2020 to February 28, 2021.

65. On or about July 31, 2020, $1,304,000 was electronically deposited into Frasinelli’s

Grant-Williams International (GWI) Bank of America account ending in X0049. The deposit was

detailed on the bank statement as “Cares Act Paycheck Protection Program Deposit”.

66. On June 29, 2020, prior to the PPP loan deposit, the balance in the account was

$0.00. This account was opened on or about June 29, 2020. Other than the PPP loan proceeds

deposit on June 29, 2020, and incoming account transfers from the Grant-Williams Global (GWG)

Bank of America account ending in X0618, there were no business revenues deposited into this

account. The GWG incoming account transfers totaled $32,000 and were disbursed directly from

GWG’s PPP loan proceeds. PPP loan proceeds are only to be used for the company in whose

name the PPP Loan application was obtained.

67. The financial records show that the GWI PPP loan proceeds of $1,304,000, in

addition to the transferred $32,000 GWG loan proceeds, were utilized by Frasinelli for personal

use and not to retain workers, maintain payroll, or make mortgage interest payments, lease

payments, and utility payments for the companies. From a review of the bank records, Affiant did

not note any payroll, mortgage, lease, or utility payments from GWI for the time period June 5,

2020 to February 28, 2021. On February 4, 2021, this account was frozen and seized by the

government with a balance of $3,584.11.

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68. Examples of Frasinelli’s personal use of the GWI and GWG PPP loan proceeds

include, Amazon.com and PayPal purchases, the purchase of high-end vehicles for himself and

family members, firearms purchases, vacation trips, both domestically and internationally, for

himself and family members, the purchase of precious metals from on-line dealers, jewelry,

artwork, cryptocurrency, as well as direct payments to multiple Frasinelli family members.

Fruits of Fraudulent PPP Applications

69. As detailed above, Frasinelli applied for and received PPP Loans for his

companies Grant-Williams Associates (GWA), Grant-Williams Global (GWG), Grant-Williams

International (GWI), and Grant-Williams Associates Corporation (GWAC).

70. As part of each PPP Loan application, Frasinelli certified that the current economic

uncertainty made these loan requests necessary to support the ongoing operations of the Applicant,

GWA, GWG, GWI and GWAC respectively. In addition, Frasinelli certified that the funds

would be used to retain workers and maintain payroll or make mortgage interest payments, lease

payments, and utility payments, as specified under the Paycheck Protection Program Rule.

71. However, Frasinelli instead used the funds to purchase vehicles, precious metals,

jewelry, artwork, firearms and firearm accessories, and personal investments.

72. Frasinelli also wired $1,820,000 in PPP Loan proceeds to investment accounts in

his name at Fidelity Investments. Both accounts are in the name of Randy A. Frasinelli at 126

Lindsay Road, Carnegie, PA 15106. The wire payments are detailed as followed:

a. 6/23/2020 - $250,000 wire from GWG’s Bank of America account X0618;

b. 6/25/2020 - $150,000 wire from GWG’s Bank of America account X0618;

c. 6/25/2020 - $20,000 wire from GWG’s Bank of America account X0618;

d. 7/07/2020 - $250,000 wire from GWG’s Bank of America account X0618;

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e. 7/08/2020 - $150,000 wire from GWG’s Bank of America account X0618;

f. 8/03/2020 - $250,000 wire from GWG’s Bank of America account X0618; and,

g. 8/03/2020 - $750,000 wire from GWG’s Bank of America account X0618.

73. Affiant obtained records for the Fidelity Investments accounts, #X91-661654 and

#X91-661655, for the time period of April 1, 2020 to January 31, 2021. Account X91-661654 is

a General Investment account styled Fidelity Account Randy A. Frasinelli – Individual TOD.

TOD is an acronym for Transfer on Death. Account X91-661655 is a General Investment account

styled Fidelity Cash Management Account Randy A. Frasinelli – Individual.

74. On April 1, 2020, prior to all three PPP loan deposits, the balance in account X91-

661654 was $0.00. On this same date, the balance in account X91-661655 was in overdraft status

with a negative balance of -$54.69.

75. Your Affiant reviewed the Fidelity Investment accounts statements and noted the

following:

a. The only funding deposits for these two personal Fidelity Investment accounts was

from the GWG Bank of America account X0618, the above detailed $1,820,000 in

wire payments.

b. The account activity consisted of the buying and selling of various equity stock

mutual funds.

76. Between approximately August 21,2020 and October 1, 2020, Frasinelli directed

Fidelity Investments to sell some of his equity positions and wire funds to the GWI Bank of

America account X0049 totaling $770,000. These funds were spent in the same manner as

described earlier in paragraphs 67 and 68.

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Search and Seizure Warrants

77. On or about February 3, 2021, the Honorable Patricia L. Dodge signed a search

warrant for Frasinelli’s residence at 126 Lindsay Road, Carnegie, PA 15106, as well as eighteen

seizure warrants for property traceable to proceeds of Frasinelli’s fraud, including a Ford Mustang,

two Mercedes SUVs, a BMW sedan, a Land Rover Defender, a Porsche Panamera, gold bars and

silver coins, watches and accessories, works of art, firearms, and the contents of two investment

accounts and four bank accounts. These warrants are filed at Magistrate Numbers 21-204 to 21-

222. The warrants were executed the following day, February 4, 2021.

New PPP Application

78. On April 13, 2021, Affiant received information from an agent with the Small

Business Administration’s Office of Inspector General. This new information indicated that, on

or about March 13, 2021, Randy Frasinelli received a fifth PPP loan in the amount of $1,340,000.

The loan was funded by Bank of America. The application was made in Frasinelli’s own name,

rather than in a business name. Affiant queried publicly available data regarding granted PPP

loans through www.federalpay.org. That data indicates that Randy Frasinelli, as a sole proprietor

without an entity name, received a $1.34 million PPP loan that was approved by Bank of America

on March 13, 2021. The data suggests that the loan resulted in 53 jobs being retained.

CONCLUSION

79. For all the foregoing reasons, there is probable cause to believe that bank fraud, in

violation of 18 U.S.C. § 1344, and money laundering, in violation of 18 U.S.C. § 1957(a), have

been committed by Randy Frasinelli, in the Western District of Pennsylvania. Accordingly, your

Affiant requests that a criminal complaint and arrest warrant be issued.

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The above information is true and correct to the best of my knowledge, information and

belief.

/s/ Sean Langford__
SEAN LANGFORD
Special Agent, FBI

Sworn and subscribed before me, by telephone
pursuant to Fed. R. Crim. P. 4.1(b)(2)(A),
this 14th day of April, 2021.

HONORABLE CYNTHIA REED EDDY
CHIEF UNITED STATES MAGISTRATE JUDGE

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