Information — United States v. Raul Fernandez Vicioso (District of Massachusetts, Document 1)
Summary
This Information, filed in the District of Massachusetts as Case 4:26-cr-40007, charges Raul Fernandez Vicioso in Count One with conspiracy to commit SNAP benefit fraud, in Count Two with conspiracy to commit wire fraud, in Count Three with SNAP benefit fraud, aiding and abetting, and in Count Four with money laundering. The SNAP allegations say that from in or about December 2023 through in or about September 24, 2025, the defendant and coconspirators used stolen personally identifiable information to apply for SNAP benefits in Massachusetts and Rhode Island and used the EBT cards to buy bulk food for the El Primo Restaurant. The Pandemic Unemployment Assistance allegations cover April 2020 through June 2021 and say that over $700,000 in PUA funds was received from Massachusetts, New York, Pennsylvania, Ohio, and Nevada. The Information is dated February 3, 2026.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Cite this document
“Information — United States v. Raul Fernandez Vicioso (District of Massachusetts, Document 1).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-4-26-cr-40007-dkt-1-d-mass-c7e69b905b/
, SHA-256 1dcd5e2558df28c23acb472cce8c57bd680938303640755eb265d68deaa00795.Full text
Case 4:26-cr-40007-MRG Document 1 Filed 02/03/26 Page 1 of 16
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
) Criminal No.
UNITED STATES OF AMERICA )
) Violations:
v. )
) Count One: Conspiracy to Commit SNAP
RAUL FERNANDEZ VICIOSO, ) Benefit Fraud
) (18 U.S.C. § 371)
Defendant )
) Count Two: Conspiracy to Commit Wire Fraud
) (18 U.S.C. § 1349)
)
) Count Three: SNAP Benefit Fraud, Aiding and
) Abetting
) (7 U.S.C. § 2024(b) and 18 U.S.C. § 2)
)
) Count Four: Money Laundering
) ((18 U.S.C. § 1956(a)(1)(B)(i))
)
) SNAP Benefit Fraud Forfeiture Allegation:
) (7 U.S.C. § 2024(f), 18 U.S.C. § 981(a)(1)(C),
) and 28 U.S.C. § 2461(c))
)
) Wire Fraud Forfeiture Allegation:
) (18 U.S.C. § 981(a)(1)(C) and 28 U.S.C.
) § 2461(c))
)
) Money Laundering Forfeiture Allegation:
) (18 U.S.C. § 982(a)(1))
)
INFORMATION
At all times relevant to this Information:
General Allegations
1. Defendant Raul Fernandez Vicioso (FERNANDEZ VICIOSO) was a resident of
Fitchburg, Massachusetts.
2. El Primo Restaurant was located in Leominster, Massachusetts.
Case 4:26-cr-40007-MRG Document 1 Filed 02/03/26 Page 2 of 16
3. The United States Department of Agriculture (USDA), Food and Nutrition Service
(FNS), a United States department and agency, sponsored, supervised, funded, and oversaw the
Supplemental Nutrition Assistance Program (SNAP), a federal government program formerly
known as the Food Stamp Program.
4. SNAP is a federal benefit program intended to assist low-income individuals and
families purchase food. Congress passed SNAP to “promote the general welfare, to safeguard
the health and well-being of the nation’s population by raising levels of nutrition among low-
income households.” 7 U.S.C. § 2011.
5. Under SNAP, eligible individuals receive credits to buy food from retail food stores
that participate in SNAP by means of an electronic benefit transfer (EBT) card, which is used like
a debit or credit card. Critically, SNAP benefits can only be used by authorized users to purchase
foodstuffs.
6. An individual applicant may add eligible family members to an application, which
permits those individuals also to use the EBT card and which increases the benefits disbursed to
that household. Nonfood items, such as gasoline, medicines, alcohol, and cigarettes, are not
eligible for purchase using SNAP funds.
7. The USDA administers SNAP nationally. Individuals or families in need of SNAP
benefits may apply for assistance through State agencies.
8. In Rhode Island, SNAP benefits are administered to recipients by the Rhode Island
Department of Human Services (RI DHS) in accordance with federal requirements. RI DHS is
responsible for determining SNAP eligibility and authorizing benefits for low-income individuals
in need.
Case 4:26-cr-40007-MRG Document 1 Filed 02/03/26 Page 3 of 16
9. To qualify for SNAP in Rhode Island, the applicant must be a resident of Rhode
Island, meet the financial eligibility requirements, and be a United States citizen or an eligible non-
citizen, such as Lawful Permanent Resident (LPR) who has earned, or can be credited with, 40
quarters of work. An applicant for SNAP benefits must also provide proof of their identity, that is,
the applicant must be the person who they claim to be. Among other things, an applicant must also
furnish a Social Security number or provide proof that the applicant has applied for one.
10. An applicant for SNAP benefits must provide complete and accurate information
both at the time of application and on an ongoing basis for RI DHS to properly assess initial and
continued eligibility for benefits.
11. In Massachusetts, SNAP benefits are administered to recipients by the
Massachusetts Department of Transitional Assistance (MA DTA) in accordance with federal
requirements. MA DTA is responsible for determining SNAP eligibility and authorizing benefits
for low-income individuals in need.
12. Victims 1 through 3 are individuals whose identities were fraudulently utilized by
FERNANDEZ and his coconspirators to apply for SNAP benefits in Massachusetts and/or Rhode
Island. There are approximately 115 other victims whose identities were similarly utilized.
13. The Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”)
created a new temporary federal unemployment insurance program called Pandemic
Unemployment Assistance (PUA).
14. The Massachusetts Department of Unemployment Assistance administered and
managed the PUA program in Massachusetts.
Case 4:26-cr-40007-MRG Document 1 Filed 02/03/26 Page 4 of 16
15. Eligible Massachusetts residents could apply for PUA benefits through an online
portal by providing personally identifiable information (PII), including their first and last name,
Social Security number (SSN), date of birth, residential and mailing addresses, and bank account
information.
16. Other states, such as New York, Ohio, Pennsylvania and Nevada have similar
agencies to administer and manage PUA programs and procedures for eligible residents to apply
for PUA benefits.
SNAP BENEFIT FRAUD
Object and Purpose of the Conspiracy
17. The object of the conspiracy is to commit SNAP Benefit Fraud. The principal
purpose of the conspiracy for the defendant and his coconspirators was to enrich themselves by
using fraudulently obtained SNAP benefits to purchase food to support the operation of the El
Primo Restaurant.
Manner and Means of the Conspiracy
18. Among the manner and means by which FERNANDEZ VICIOSO and his
coconspirators carried out the conspiracy were the following:
a. Acquiring stolen personally identifiable information (PII) of U.S. citizens.
b. Utilizing the stolen PII to fraudulently apply for SNAP benefits in
Massachusetts and Rhode Island.
c. Concealing the scheme by removing the printed names from the fraudulent
SNAP benefit cards and setting identical Personal Identification Numbers
(PINs).
d. Purchasing large quantities of bulk food items (far greater than for personal use)
utilizing the fraudulent SNAP EBT cards at various local wholesalers and food
markets to stock the El Primo Restaurant
Case 4:26-cr-40007-MRG Document 1 Filed 02/03/26 Page 5 of 16
e. Preparing and selling bulk food items purchased with fraudulent SNAP benefit
cards for retail sale at the El Primo Restaurant.
f. Wiring proceeds from these schemes to individuals in Venezuela and the
Dominican Republic.
Overt Acts in Furtherance of the Conspiracy
19. From in or about December 2023 through in or about September 24, 2025,
FERNANDEZ VICIOSO and coconspirators committed and caused to be committed the following
overt acts, among others, in furtherance of the conspiracy:
a. In December 2023, a fraudulent expedited online SNAP application using the
identity of Victim 1 was submitted resulting in the issuance of benefits.
b. In April 2024, a fraudulent online SNAP application using the identity of
Victim 2 was submitted resulting in the issuance of SNAP benefits.
c. In April 2024, a fraudulent online SNAP application using the identity of
Victim 3 was submitted resulting in the issuance of SNAP benefits.
d. In May 2024, FERNANDEZ VICIOSO used the SNAP EBT cards issued to
the identities of Victims 1 and 2 to complete transactions at BJ’s Wholesale
Club in Leominster, Massachusetts with a membership card issued to the El
Primo Restaurant.
e. In June 2024, FERNANDEZ VICIOSO used the SNAP EBT card issued to
Victim 3 to complete transactions at Hannaford Supermarket in Leominster,
Massachusetts and BJ’s Wholesale Club in Leominster, Massachusetts using a
membership card issued to the El Primo Restaurant.
f. On April 14, 2025, FERNANDEZ VICIOSO used the SNAP EBT card issued
to Victim 2 to complete transactions at BJ’s Wholesale Club in Leominster,
Massachusetts with a membership card issued to the El Primo Restaurant.
g. On September 24, 2024, FERNANDEZ possessed fraudulently obtained
Massachusetts and Rhode Island EBT cards, fraudulent documents bearing a
Providence address involved in the scheme, printed ledgers, and handwritten
lists of more than 100 identities (names, dates of birth, and SSNs), and SNAP-
related mailings.
Case 4:26-cr-40007-MRG Document 1 Filed 02/03/26 Page 6 of 16
PUA FRAUD
Object and Purpose of the Conspiracy
20. The object of the conspiracy is to commit PUA benefit fraud. The principal
purpose of the conspiracy for the defendant and his coconspirators was to enrich themselves by
fraudulently obtaining PUA benefits and payments by causing state agencies in Massachusetts,
New York, Pennsylvania, Ohio, and Nevada to issue PUA benefits and payments to the bank
accounts provided by one or more members of the conspiracy.
Manner and Means of the PUA Fraud Conspiracy and Scheme to Defraud
21. Among the manner and means by which FERNANDEZ VICIOSO and
coconspirators known and unknown to the United States Attorney carried out the conspiracy and
the scheme to defraud were the following:
a. Using email addresses, residential addresses, and phone numbers that they
controlled, to submit the fraudulent PUA applications containing stolen
personally identifiable information (PII) of U.S. citizens.
b. Using bank accounts to receive the proceeds of the fraudulent PUA
applications
c. Submitting fraudulent documents in support of their continued eligibility.
d. Receiving over $700,000 in PUA funds from Massachusetts, New York,
Pennsylvania, Ohio, and Nevada based on fraudulent claims submitted by
FERNANDEZ VICIOSO and coconspirators known and unknown to the
United States Attorney.
e. Using PUA funds for their personal benefit.
Case 4:26-cr-40007-MRG Document 1 Filed 02/03/26 Page 7 of 16
Acts in Furtherance of the Conspiracy and the Scheme to Defraud
22. From in or about April 2020 through in or about June 2021, FERNANDEZ
VICIOSO and coconspirators committed and caused to be committed the following overt acts,
among others, in furtherance of the conspiracy and the scheme to defraud:
a. On or about April 21, 2020, FERNANDEZ VICIOSO submitted a false
application for PUA benefits under his name using IP address 37.1.214.214 and
listing his phone number ending in 0345.
b. On or about April 26, 2020, FERNANDEZ VICIOSO and coconspirators
submitted a false application for PUA benefits using IP address 37.1.214.214
and listing his phone number ending in 0345, though, on this occasion, using a
second email address and another different name.
c. On or about April 27, 2020, FERNANDEZ VICIOSO and coconspirators
submitted a false application for PUA benefits using IP address 37.1.214.214
and listing his phone number ending in 0345, though, on this occasion, using a
third email address and another different name.
d. On or about May 3, 2020, FERNANDEZ VICIOSO and coconspirators
requested payment resulting in payment of approximately $917.00 in fraudulent
PUA payments.
e. On or about January 19, 2021, FERNANDEZ VICIOSO and coconspirators
requested payment resulting in payment of approximately $617.00 in fraudulent
PUA payments.
f. On or about March 15, 2021, FERNANDEZ VICIOSO and coconspirators
requested payment resulting in payment of approximately $617.00 in fraudulent
PUA payments.
g. On or about June 28, 2021, FERNANDEZ VICIOSO and coconspirators
requested payment resulting in payment of approximately $617.00 in fraudulent
PUA payments.
Case 4:26-cr-40007-MRG Document 1 Filed 02/03/26 Page 8 of 16
COUNT ONE
Conspiracy to Commit SNAP Benefit Fraud
(18 U.S.C. § 371)
The United States Attorney charges:
22. The United States Attorney re-alleges and incorporates by reference paragraphs 1-
12 and 17-19 of this Information.
23. From in or about December 2023, through in or about September 24, 2025, in the
District of Massachusetts, and elsewhere, the defendant,
RAUL FERNANDEZ VICIOSO,
conspired with others both known and unknown to the United States Attorney to commit an
offense against the United States, to wit, to knowingly use, transfer, acquire, and possess SNAP
benefits having a value of $5,000 or more, in a manner not authorized by Title 7, United States
Code, Chapter 51, that is, fraudulently obtaining SNAP EBT cards to further obtain bulk food
items for retail sale at the El Primo Restaurant, in violation of Title 7, United States Code, Section
2024(b).
All in violation of Title 18, United States Code, Section 371.
Case 4:26-cr-40007-MRG Document 1 Filed 02/03/26 Page 9 of 16
COUNT TWO
Conspiracy to Commit Wire Fraud
(18 U.S.C. § 1349)
The United States Attorney further charges:
24. The United States Attorney re-alleges and incorporates by reference paragraphs 1-
2, 13-16, and 20-22 of this Information.
25. From in or about April 2020, through in or about June 2021, in the District of
Massachusetts, and elsewhere, the defendant,
RAUL FERNANDEZ VICIOSO,
conspired with others known and unknown to the United States Attorney to commit the following
offense: wire fraud, that is, having devised and intending to devise a scheme and artifice to
defraud and to obtain money and property by means of materially false and fraudulent pretenses,
representations and promises, did transmit and cause to be transmitted, by means of wire
communications in interstate and foreign commerce, writings, signs, signals, pictures and sounds,
for the purpose of executing the scheme to defraud, in violation of Title 18, United States Code,
Section 1343.
All in violation of Title 18, United States Code, Section 1349.
Case 4:26-cr-40007-MRG Document 1 Filed 02/03/26 Page 10 of 16
COUNT THREE
Use, Transfer, Acquisition, and Possession of SNAP Benefits in an
Unauthorized Manner, Aiding and Abetting
(7 U.S.C. § 2024(b), 18 U.S.C. § 2)
The United States Attorney further charges:
26. The United States Attorney re-alleges and incorporates by reference paragraphs 1-
14 of this Information.
27. On or about April 1, 2025, in the District of Massachusetts, and elsewhere, the
defendant,
RAUL FERNANDEZ VICIOSO,
knowingly used, transferred, acquired, and possessed SNAP benefits having a value of $100 or
more, but less than $5,000, in a manner not authorized by Title 7, United States Code, Chapter
51, that is, fraudulently obtaining SNAP EBT cards to further obtain bulk food items for retail
sale at the El Primo Restaurant.
All in violation of Title 7, United States Code, Section 2024(b), and Title 18, United States
Code, Section 2.
Case 4:26-cr-40007-MRG Document 1 Filed 02/03/26 Page 11 of 16
COUNT FOUR
Money Laundering
(18 U.S.C. § 1956(a)(1)(B)(i))
The United States Attorney further charges:
28. On or about April 1, 2025, in the District of Massachusetts, and elsewhere, the
defendant,
RAUL FERNANDEZ VICIOSO,
did conduct and attempt to conduct a financial transaction, to wit, the purchase of bulk food items
intended for resale at the El Primo Restaurant using fraudulent SNAP EBT benefit cards knowing
that the property involved in such transaction represented the proceeds of some form of unlawful
activity, and which in fact involved the proceeds of specified unlawful activity, that is, Conspiracy
to Commit SNAP Benefits Fraud in violation of Title 18, United States Code, Section 371,
knowing that the transaction was designed, in whole and in part, to conceal and disguise the nature,
location, source, ownership, and control of the proceeds of specified unlawful activity.
All in violation of Title 18, United States Code, Section 1956(a)(1)(B)(i).
Case 4:26-cr-40007-MRG Document 1 Filed 02/03/26 Page 12 of 16
SNAP BENEFIT FRAUD FORFEITURE ALLEGATION
(7 U.S.C. § 2024(f), 18 U.S.C. § 981(a)(1)(C), and 28 U.S.C. § 2461(c))
1. Upon conviction of one of more of the offenses in violation of Title 18, United
States Code, Sections 371 and Title 7, United States Code, Section 2024(b), set forth in Counts
One and Three, the defendant,
RAUL FERNANDEZ VICIOSO,
shall forfeit to the United States, pursuant to Title 7, United States Code, Section 2024(f), any
nonfood items, moneys, negotiable instruments, securities, or other things of value that are
furnished by any person in exchange for benefits, or anything of value obtained by use of an access
device, in any manner contrary to Title 7, United States Code, Section 2024, and, 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
offenses.
2. If any of the property described in Paragraph 1, above, as being forfeitable pursuant
to Title 7, United States Code, Section 2024(f), Title 18, United States Code, Section
981(a)(1)(C), and Title 28, United States Code, Section 2461(c), as a result of any act or omission
of the defendant --
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction of the Court;
d. has been substantially diminished in value; or
Case 4:26-cr-40007-MRG Document 1 Filed 02/03/26 Page 13 of 16
e. has been commingled with other property which cannot be divided without
difficulty;
it is the intention of the United States, pursuant to Title 28, United States Code, Section 2461(c),
incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any other property
of the defendant up to the value of the property described in Paragraph 1 above.
All pursuant to Title 7, United States Code, Section 2024(f), Title 18, United States Code,
Section 981(a)(1)(C), and Title 28, United States Code, Section 2461(c).
Case 4:26-cr-40007-MRG Document 1 Filed 02/03/26 Page 14 of 16
WIRE FRAUD FORFEITURE ALLEGATION
(18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c))
1. Upon conviction of the offense in violation of Title 18, United States Code, Section
1349, set forth in Count Two, the defendant,
RAUL FERNANDEZ VICIOSO,
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.
2. If any of the property described in Paragraph 1, above, as being forfeitable pursuant
to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United States Code, Section
2461(c), as a result of any act or omission of the defendant --
f. cannot be located upon the exercise of due diligence;
g. has been transferred or sold to, or deposited with, a third party;
h. has been placed beyond the jurisdiction of the Court;
i. has been substantially diminished in value; or
j. has been commingled with other property which cannot be divided without
difficulty;
it is the intention of the United States, pursuant to Title 28, United States Code, Section 2461(c),
incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any other property
of the defendant up to the value of the property described in Paragraph 1 above.
All pursuant to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United
States Code, Section 2461(c).
Case 4:26-cr-40007-MRG Document 1 Filed 02/03/26 Page 15 of 16
MONEY LAUNDERING FORFEITURE ALLEGATION
(18 U.S.C. § 982(a)(1))
1. Upon conviction of the offense in violation of Title 18, United States Code, Section
1956, set forth in Count Four, the defendant,
RAUL FERNANDEZ VICIOSO,
shall forfeit to the United States, pursuant to Title 18, United States Code, Section 982(a)(1), any
property, real or personal, involved in such offense, and any property traceable to such property.
2. If any of the property described in Paragraph 1, above, as being forfeitable pursuant
to Title 18, United States Code, Section 982(a)(1), as a result of any act or omission of the
defendant --
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction of the Court;
d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be divided without
difficulty;
it is the intention of the United States, pursuant to Title 18, United States Code, Section 982(b),
incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any other property
of the defendant up to the value of the property described in Paragraph 1 above.
Case 4:26-cr-40007-MRG Document 1 Filed 02/03/26 Page 16 of 16
All pursuant to Title 18, United States Code, Section 982(a)(1).
Respectfully submitted,
LEAH B. FOLEY
United States Attorney
By: /s/ Danial E. Bennett
Danial E. Bennett
Assistant U.S. Attorney
Date: February 3, 2026
File and source
- File
- 1.pdf
- Size
- 162,613 bytes
- SHA-256
- 1dcd5e2558df28c23acb472cce8c57bd680938303640755eb265d68deaa00795
- Our copy
- 1.pdf
- Original
- archive.org