Criminal Complaint and Affidavit — U.S. v. Joff Stenn Wroy Philossaint (S.D. Fla. 9:22-mj-08336)

Summary

A criminal complaint with an affidavit in support, Case 9:22-mj-08336, Document 3, entered 08/08/2022, against Joff Stenn Wroy Philossaint, Southern District of Florida. The complaint lists 18 U.S.C. § 1349, conspiracy to commit wire fraud; § 1956(h), conspiracy to commit money laundering; § 1028A, aggravated identity theft; and § 1425, procurement of citizenship or naturalization unlawfully. Homeland Security Investigations Special Agent Jon A. Longo states that Philossaint and co-conspirators devised a scheme to obtain by fraud millions of dollars in forgivable PPP and EIDL loans, for Philossaint's own companies and for other business owners' companies. The affidavit says they opened approximately 152 payroll processing accounts at ADP, for businesses funded with loans worth approximately $25 million.

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“Criminal Complaint and Affidavit — U.S. v. Joff Stenn Wroy Philossaint (S.D. Fla. 9:22-mj-08336).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-9-22-mj-08336-dkt-3-s-d-fla-a89be60180/, SHA-256 9706c29af9baf49b8145ba5c2e34ef1a0e73940a185fa35f58fc8cabb2e05d25.

Full text

Case 9:22-mj-08336-BER Document 3 Entered on FLSD Docket 08/08/2022 Page 1 of 28

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

Case No. _______________________

UNITED STATES OF AMERICA

__________________________________/

CRIMINAL COVER SHEET

Did this matter originate from a matter pending in the Northern Region of the United States
Attorney’s Office prior to August 8, 2014 (Mag. Judge Shaniek Maynard)? ___ Yes ___ No

Respectfully submitted,

UNITED STATES ATTORNEY

BY: _____________________________________
A. Marie Villafaña
ASSISTANT UNITED STATES ATTORNEY

500 South Australian Avenue, Suite 400
West Palm Beach, Florida 33401
Case 9:22-mj-08336-BER
riminal Complaint Document 3 Entered on FLSD Docket 08/08/2022 Page 2 of 28

UNITED STATES DISTRICT COURT
for the
Southern District of Florida

United States of America )
V. )
) Case No. 22-8336-BER
JOFF STENN WROY PHILOSSAINT, )
)
)
Defendant(s)

CRIMINAL COMPLAINT

I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of April 1, 2020-present in the county of Palm Bch, Broward, Dade in the
Southern District of Florida , the defendant(s) violated:
Code Section Offense Description
18 u.s.c. § 1349 Conspiracy to commit wire fraud
18 U.S.C. § 1956(h) Conspiracy to commit money laundering
18 U.S.C. § 1028A Aggravated identity theft
18 u.s.c. § 1425 Procurement of citizenship or naturalization unlawfully

This criminal complaint is based on these facts:
Aug 5, 2022
See Attached Affidavit

West Palm Beach

Continued on the attached sheet.

Special Agent Jon A. Longo, HSI
Printed name and title.

Sworn and Attested to me by Applicant by Telephone (FaceTime) pursuant to Fed. R. Crim. P. 4(d) and 4.1

Date:
Judge's signature

City and state: West Palm Beach, FL Bruce E. Reinhart, U.S. Magistrate Judge
Printed name and title
Case 9:22-mj-08336-BER Document 3 Entered on FLSD Docket 08/08/2022 Page 3 of 28

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

I, Jon A. Longo, a Special Agent (SA) of the United States Department of Homeland

Security, Homeland Security Investigations (HSI), Office of the Assistant Special Agent in Charge

in West Palm Beach, Florida, being duly sworn, depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of a criminal complaint charging JOFF STENN

WROY PHILOSSAINT (“PHILOSSAINT”) with: conspiracy to commit wire fraud, conspiracy

to commit money laundering, aggravated identity theft, and procurement of citizenship or

naturalization unlawfully, in violation of 18 U.S.C. §§ 1349, 1956(h), 1028A, and 1425, from on

or about April 1, 2020 through the present, in Palm Beach, Broward, Miami-Dade, and St. Lucie

Counties, in the Southern District of Florida, and elsewhere.

2. In summary, PHILOSSAINT and co-conspirators devised and participated in a

scheme to obtain by fraud, millions of dollars in forgivable loans through the Paycheck Protection

Program (“PPP”) and the Economic Injury Disaster Loan (“EIDL”) Program. PHILOSSAINT and

his co-conspirators obtained these loans both for PHILOSSAINT’s own companies and co-

conspirators’ companies. PHILOSSAINT conspired to submit a number of fraudulent loan

applications for other business owners’ companies in order to receive kickbacks from those

approved and funded loans. To inflate the size of the loan amounts, the conspirators relied on a

variety of false statements, including the number of employees, monthly payroll amounts, and

gross revenues, and they submitted falsified tax documents in support of their loan applications.

For example, the conspirators used nearly identical versions of the same fabricated tax documents

in the PPP applications for multiple companies. A number of these loans were approved and

funded by financial institutions and the Small Business Administration (“SBA”), and certain
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proceeds were transmitted to accounts controlled by PHILOSSAINT in the United States and in

the Dominican Republic.

3. I have been employed as a sworn federal Special Agent with Immigration and

Customs Enforcement (ICE) since July 2006. As a federal agent, I am authorized to investigate

violations of laws of the United States, including those related to immigration and benefit fraud,

and to execute warrants issued under the authority of the United States. I have received 23 weeks

of training at the Federal Law Enforcement Training Center, which included the application of

federal statutes, federal court procedures, and the techniques required to insure the admissibility

of evidence at trial. I have also conducted and participated in investigations of this nature.

4. Recently, I have been assigned to work with the Small Business Administration

Office of Inspector General (“SBA-OIG”) and other law enforcement partners, including the

Federal Bureau of Investigation (“FBI”), Internal Revenue Service, Criminal Investigation (“IRS-

CI”), and Secret Service (“USSS”) to investigate PHILOSSAINT and others involved in possible

fraud associated with the stimulus and economic assistance programs created by the federal

government in response to the COVID-19 pandemic.

5. The facts set forth in this affidavit are based upon my personal observations, my

review of records obtained during the course of the investigation, my training and experience, and

information I obtained from other law enforcement agents and government personnel. Because

this affidavit is being submitted for the limited purpose of establishing probable cause in support

of a criminal complaint, I have not included in this affidavit every detail of the investigation.

The Paycheck Protection Program (“PPP”)

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

law enacted in or around March 2020 and designed to provide emergency financial assistance to

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the millions of Americans who are suffering the economic effects caused by the COVID-19

pandemic. One source of relief provided by the CARES Act was the authorization of forgivable

loans to small businesses for job retention and certain other expenses, through a program referred

to as the Paycheck Protection Program (“PPP”).

7. The types of businesses eligible for a loan included sole proprietorships. In order

to obtain a PPP loan, a qualifying business (through its authorized representative or the sole

proprietor) signed and submitted a PPP loan application (Small Business Administration (“SBA”)

Form 2483) online through the lender’s application platform. The PPP loan application required

the business (through its authorized representative or the sole proprietor) to acknowledge the

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

loan. The certifications included an attestation that the business was in operation on February 15,

2020, and had employees for whom it paid salaries and payroll taxes or paid independent

contractors, or was a sole proprietorship with no employees. In the PPP loan application, the small

business (through its authorized representative or the sole proprietor) was required to provide,

among other things, its average monthly payroll expenses and number of employees. In addition,

businesses applying for the PPP loan were required to provide documentation confirming their

payroll expenses. Typically, businesses supplied documents showing the amount of payroll taxes

reported to the Internal Revenue Service (“IRS”). The sole proprietorship had to report and

document the business’ income and expenses, as typically reported to the IRS on Form 1040,

Schedule C. These figures and documentation were used to calculate the amount of money the

small business was eligible to receive under the PPP. Sole proprietorships were eligible to receive

a maximum PPP loan of up to $20,833 to cover lost income.

8. A PPP loan application was processed by a participating lender. The SBA

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delegated authority to third-party lenders to underwrite and approve the loans. If a PPP loan

application was approved, the participating lender funded the PPP loan using its own monies,

which were 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, was transmitted

electronically by the lender to the SBA in the course of processing the loan.

9. PPP loan proceeds were required to be used by the business on certain permissible

expenses — payroll costs, interest on mortgages, rent, and utilities. The PPP allowed the interest

and principal on the PPP loan to be entirely forgiven if the business spent the loan proceeds on

these expense items within a designated period of time and used a defined portion of the PPP loan

proceeds on payroll expenses.

The Economic Injury Disaster Loan (“EIDL”) Program

10. Before the COVID-19 pandemic, SBA’s Economic Injury Disaster Loan (“EIDL”)

program provided low-interest financing to small businesses, renters, and homeowners in regions

affected by declared disasters.

11. The CARES Act also authorized the SBA to provide EIDL assistance to eligible

small businesses experiencing “substantial economic injury” (substantial financial disruptions)

due to the COVID-19 pandemic. In order to obtain a COVID-19 EIDL, a qualifying business was

required to submit electronically an EIDL application to the SBA and provide information about

its operations, such as the number of employees, gross revenues, and the cost of goods sold for the

12-month period preceding January 31, 2020. The applicant was also required to certify under

penalty of perjury that all of the information in the EIDL application was true and correct to the

best of the applicant’s knowledge.

12. EIDL applications were submitted directly to, and processed by, the SBA, with

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support from a government contractor. EIDL funds were issued directly from the United States

Treasury.

13. In addition, the CARES Act authorized the SBA to issue advances of up to $10,000

to small businesses within three days of applying for an EIDL. The amount of the advance was

determined by the number of employees the applicant certified having at the small business. The

advances did not have to be repaid.

14. SBA’s email and loan application servers are located outside the State of Florida,

so wire communications between banks and the SBA and between EIDL applicants located within

Florida and the SBA necessarily traveled in interstate commerce.

The Scheme to Obtain Fraudulent PPP and EIDL Loans

15. Beginning in March 2020, JOFF PHILOSSAINT (“PHILOSSAINT”) and other co-

conspirators devised a scheme to defraud the PPP and EIDL loan programs. As noted above, in

order to be eligible for a PPP or EIDL loan, one had to: (a) have an active business as of the start

of the COVID-19 Pandemic; (b) have paid employees (with the exception of some sole

proprietorship EIDLs); and (c) use the proceeds of the loans to continue to operate the business

and continue paying its employees. The crisis situation of the COVID-19 emergency meant that

banks and the SBA had to rely on documentation provided by and sworn representations made by

the applicants. However, these eligibility requirements can be cross-checked against

documentation that applicant provided – or failed to provide – to other government agencies at

other times. For example, regarding the first requirement, a review of Florida Department of State

records shows that many of the business involved in PHILOSSAINT’s scheme were “Inactive” as

of January 1, 2020, and had been “Inactive” for several years for failure to file annual reports.

Those businesses were re-activated shortly before they filed for the PPP and EIDL loans. And

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with regard to the second and third requirements, wage and earnings records maintained by the

Florida Department of Revenue – which oversees unemployment insurance – and records filed

with the IRS showed that many of the businesses did not employ the individuals listed and did not

have the revenues claimed on the loan applications. Later, during the loan forgiveness phase of

the PPP and EIDL programs, SBA requested specific IRS filings, and it was determined that

PHILOSSAINT and his co-conspirators supplied different versions of those documents to the SBA

than the ones provided to the IRS. In addition, agents involved in the investigation have visited

many of the registered addresses of the businesses that received loans and found no operating

businesses.

1. Using ADP to Create False Payroll Records through Identity Theft

16. To create the appearance of having many employees, PHILOSSAINT and his co-

conspirators opened approximately 152 payroll processing accounts at ADP, a national payroll

processing servicer. Publicly available records disclosed that these 152 businesses were all funded

with PPP and EIDL loans worth approximately $25 million. Of these 152 businesses,

approximately 26 were on-boarded through ELITE INTERNATIONAL FINANCIAL GROUP

also known as the business entity ELITE INTERNATIONAL VENTURE CAPITAL (“EIVC”).

PHILOSSAINT is the owner of EIVC and served as the primary payroll contact for each business

on-boarded through EIVC. The 26 businesses on-boarded through EIVC received approximately

33 PPP and EIDL loans totaling $4,878,481.

17. In order to facilitate the scheme by making the businesses look legitimate and

increasing the possibility of receiving large loans, PHILOSSAINT and co-conspirators prepared

and submitted ADP payroll intake documents providing the means of identification of real

individuals to use as purported employees, including their names, social security numbers, dates

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of birth, and other personal identifying information. Many of the employees listed by

PHILOSSAINT’s clients were friends or family members and had no record of receiving wages

prior to or after receiving the loans. Interviews have revealed that at least some of the “employees”

had no knowledge that their personal information was being used in this way, and they have

confirmed that they never worked for the businesses that were listing them as paid employees.

Bank statements confirm that many of these individuals never received payroll payments from the

businesses. In many instances, the bank accounts to which the ADP payroll payments were

directed did not, in fact, go to the named employees but, instead, went back to the owners of the

businesses.

18. Prior to applying for the PPP/EIDL loans, the businesses had not received ADP

payroll services. After receiving sufficient paystubs from ADP, the companies stopped paying

their bills to ADP, and ADP closed the accounts. When the time came to apply for loan

forgiveness, PHILOSSAINT and his co-conspirators made calls to ADP for copies of the

businesses’ payroll records so they could apply for the PPP loans to be forgiven. An analysis of

the records of the businesses opened at ADP by PHILOSSAINT and his co-conspirators showed

that: (a) many of the PPP loans were for the exact same dollar amount; (b) many of the businesses

had the same employees on their payrolls purportedly working full-time at multiple businesses

simultaneously; (c) many of the employee paychecks were whole dollar amounts (e.g., $2,000.00);

(d) many employee payroll checks were direct-deposited into accounts belonging to the owner of

the business, rather than into accounts belonging to the employee; and (e) some employees who

worked for businesses onboarded by PHILOSSAINT and his co-conspirators were simultaneously

employed full-time for other long-standing ADP clients. ADP’s servers are located in Alpharetta,

Georgia so PHILOSSAINT’s and his co-conspirators’ communications with ADP regarding

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payroll services and to obtain payroll records in support of loan applications and loan forgiveness

necessarily involved interstate wire communications.

2. Use of Fabricated Tax Returns

19. To obtain the PPP and EIDL loans and to increase the dollar amount of those loans,

the co-conspirators grossly inflated the number of employees and monthly payroll costs claimed

on the loan applications and submitted fabricated tax returns in support of the applications.

According to IRS records, prior to receiving the PPP and EIDL loans, the members of the

conspiracy did not file IRS Forms 941 for their businesses; thus, the IRS Form 941’s submitted in

support of the loan applications were falsified. Similarly, the Florida Department of Revenue’s

wage and earnings records do not reflect the payroll amounts claimed on the businesses’ PPP loan

applications.

3. Identical Documents and Common IP Address

20. In addition to using the same modus operandi of creating ADP payroll accounts to

create the appearance of having regular employees, using the stolen identities of family members

and friends, and creating and submitting falsified IRS documents, a comparison of the falsified

IRS documents and loan applications across members of the conspiracy showed that many of the

falsified IRS documents contained the identical information. For example, two IRS Forms 941

submitted by two businesses that had nothing in common (other than their link to PHILOSSAINT

and EIVC), had the same: number of employees; wages, tips, and other compensation; federal

income tax withheld; taxable Social Security and Medicare wages; taxes before and after

adjustments; and total balance due – for four consecutive quarters.

21. In addition, it was determined that many of the PPP and EIDL loans were applied

for from the same IP address and device.

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4. Recruiting Others Through the Payments of Kickbacks and Discounts

22. As explained in further detail below, PHILOSSAINT applied for and received PPP

and EIDL loans on behalf of businesses owned by himself and his fiancée, M.T. PHILOSSAINT

also assisted co-conspirators in obtaining PPP and EIDL loans through EIVC’s payroll

coordination services and creating fraudulent payroll and tax documents. In exchange for this,

PHILOSSAINT and his co-conspirators agreed that the co-conspirators would pay

PHILOSSAINT approximately 10% of the value of the loan received for his assistance in setting

up the false payroll accounts and tax documents.

23. Members of the conspiracy could receive “referral credits,” i.e., payments, or

discounts on the 10% that was owed, if they referred others to PHILOSSAINT to apply for PPP

and/or EIDL loans. Once the PPP or EIDL application was funded, the referrer received a discount

on what they owed, or he/she received a referral credit paid out by check from PHILOSSAINT.

5. Laundering of Proceeds

24. Records from PHILOSSAINT’s bank accounts showed that PHILOSSAINT

received multiple checks and/or wire payments from the co-conspirators’ businesses that,

according to SBA records, received PPP and EIDL loans. ADP records reflected the businesses

were listed as clients under PHILOSSAINT’s ADP firm, EIVC. After receiving the loans, that is,

the proceeds of the wire fraud scheme, the businesses sent payments, approximately 10% of the

loan value, via check or wire to PHILOSSAINT. To promote the carrying on of the fraud scheme,

and knowing that the transaction was designed to conceal the nature, source, ownership, or control

of the proceeds of the fraudulent PPP/EIDL loan scheme, PHILOSSAINT instructed his co-

conspirators to separate the kickback payment over multiple checks and put phrases such as,

“advertising”, “commission”, “payroll” or “advertisement” in the memo line of the check. The

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payments from the co-conspirators to PHILOSSAINT were the 10% kickback payment

PHILOSSAINT required to assist in manufacturing the fraudulent payroll and tax documents and

to facilitate the loans, not a business advertisement fee.

25. In order to further conceal the nature, source, ownership, or control of the proceeds,

PHILOSSAINT deposited the checks, on different days, into various bank accounts he controlled.

For example, Company 4 (“COMPANY 4”) received a PPP loan in the amount of $143,455.00 on

February 23, 2021. On March 1, 2021, COMPANY 4 wrote four separate checks, check numbers

1122, 1123, 1124 and 1125, totaling $16,842.00, just over 10% of the overall loan value. Between

March 8, 2021 and March 26, 2021, PHILOSSAINT deposited the checks between two separate

bank accounts he was the signatory of. On March 8, 2021, PHILOSSAINT deposited check

number 1125 into PNC bank (“PNC”) account ending in 3583. On March 12, 2021,

PHILOSSAINT deposited check number 1124 into Synovus bank (“SYNOVUS”) account ending

in 4266. On March 26, 2021, PHILOSSAINT deposited check numbers 1122 and 1123 into

SYNOVUS bank account ending in 4266. COMPANY 4 received a second PPP loan on May 5,

2021 in the amount of $143,447.00 and wrote four separate checks, check numbers 1289, 1290,

1291 and 1292, totaling $15,845.00, just over 10% of the overall loan value. On May 19, 2021,

PHILOSSAINT deposited the checks between two separate bank accounts he was the signatory

of. Check numbers 1290 and 1291 were deposited into the SYNOVUS bank account ending in

4274. Check numbers 1289 and 1292 were deposited into the SYNOVUS bank account ending in

4241.

26. PHILOSSAINT opened and operated more than eight bank accounts, across

different banking institutions, using various company names, all in an effort to conceal and transfer

the money he received as proceeds of the fraud.

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27. The below table reflects an example of at-least six businesses, which

PHILOSSAINT and co-conspirators submitted PPP and EIDL applications on behalf of and

created ADP payroll accounts for.

Entity Receiving
EIDL/PPP Check/Wire Check Check/Wire
Loan and Loan Date
Loan Amount Date Number Amount
Sending Wire
Company 1 2/17/2021 Loan 1 2/22/2021 $10,000.00
6625902791
$143,412.00
Company 2 2/17/2021 Loan 1
2/22/2021 1023920902 $10,000.00
$143,222.00
Company 3 2/20/2021 Loan 1 3/12/2021 1017 $5,597.00
$81,952.00
Company 4 2/20/2021 Loan 1 3/1/2021 1122 $2,500.00
$143,445.00 3/1/2021 1123 $2,500.00
3/1/2021 1125 $5,920.00
(Total: $10,920.00)
Company 5 2/23/2021 Loan 1 3/12/2021 2540 $6,784.00
$142,840.00 3/12/2021 2541 $5,000.00
3/25/2021 2542 $2,500.00
3/25/2021 2543 $2,500.00
(Total: $16,784.00)
Company 6 4/9/2021 Loan 1 4/28/2021 1060 $2,500.00
$104,166.67 4/28/2021 1063 $3,000.00
5/17/2021 1064 $2,500.00
6/29/2021 1066 $2,416.70
(Total: $10,416.70)
Company 5 5/3/2021 Loan 2 5/13/2021 2545 $4,344.70
$143,447.00 5/13/2021 2546 $5,000.00
5/17/2021 2547 $2,500.00
5/18/2021 2548 $2,500.00
(Total: $14,344.70)
Company 4 5/5/2021 Loan 2 5/18/2021 1289 $4,445.00
$143,447.00 5/18/2021 1290 $2,500.00
5/18/2021 1291 $4,900.00
5/18/2021 1292 $4,000.00
(Total: $15,845.00)
Company 2 5/6/2021 Loan 2
5/17/2021 1017 $10,000.00
$143,447.00
Company 1 5/6/2021 Loan 2
5/18/2021 WIRE $7,300.00
$143,447.00

Fraudulent PPP and EIDL Applications Submitted for PHILOSSAINT’s Companies

28. On April 1, 2020, PHILOSSAINT applied for an EIDL loan from the SBA as owner

of the business entity named Royal Elite Trans LLC. The application, which was submitted

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through the SBA online portal, resulted in a total of $299,400.00 in loan proceeds, all of which

was approved and disbursed into Bank of America (“BOA”) account ending in 0080 in the name

of “Royal Elite Trans, LLC”. PHILOSSAINT is the sole signatory on this account. According to

BOA records, the BOA account ending in 0080 was opened in April of 2018 with the listed title,

“Royal Elite Trans LLC.”

29. According to the Florida Department of State records, on January 4, 2018,

PHILOSSAINT incorporated Royal Elite Trans LLC with the principal office address at 270 NE

89th St, El Portal, FL 33138. PHILOSSAINT is the sole registered agent of Royal Elite Trans,

LLC. In 2019, the principal place of business was updated to 1000 West Pembroke Road, 320,

Hallandale Beach, FL 33009. This address is a Megacenter Self Storage facility, not an office.

Royal Elite Trans, LLC rented the space as a “virtual office.” A virtual office is part of the flexible

workspace industry that provides businesses with a combination of service, space, and/or

technology, without those businesses bearing the capital expenses of owning or leasing a

traditional office. Although Royal Elite Trans LLC claims to be a limousine company, there are

no limousines registered to the business, nor does PHILOSSAINT have a commercial driver’s

license.

30. According to Internal Revenue Service (“IRS”) records, Royal Elite Trans LLC

filed as a Sole Proprietorship which used Form Schedule C (titled “Profit or Loss From Business”)

on Form 1040 (titled “U.S. Individual Income Tax Return”) to report income or loss from the

business. IRS records indicate Royal Elite Trans filed a Schedule C for tax year 2019 but did not

file a Schedule C for tax years 2020 or 2021 reporting income or loss. Royal Elite Trans did not

file IRS Form 941 (titled “Employer’s Quarterly Federal Tax Return”) for tax year 2019 to reflect

the wages reported on their 2019 Schedule C.

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31. The Florida Department of Revenue, does not possess any wage and earnings

records for Royal Elite Trans for tax year 2019, quarters 1, 3, and 4 of 2020, or tax year 2021 – in

other words, PHILOSSAINT did not report to the State of Florida that Royal Elite Trans had any

employees during all of 2019, quarters 1, 3, and 4 of 2020, and all of 2021. Florida Department

of Revenue records reflect wages of $500.00 paid to one employee, JOFF PHILOSSAINT, for the

second quarter of tax year 2020 only.

32. On or about April 1, 2020, PHILOSSAINT electronically filed an application for

an EIDL with the SBA, falsely asserting that Royal Elite Trans had two employees, gross revenues

of $130,000 for the 12 months ending 12-31-2020, and cost of goods sold for that period of

$101,200. Based upon the false statements in that application, SBA approved an advance of

$2,000, which was transferred via wire into the Royal Elite Trans Bank of America account ending

in 0080 on or about April 22, 2020.

33. On or about April 9, 2020, PHILOSSAINT electronically filed an application for a

PPP loan with Bank of America, falsely asserting that Royal Elite Trans had two employees and

monthly payroll expenses of $7,000.00 per month. In support of the Royal Elite Trans application,

PHILOSSAINT submitted a counterfeit 1099 for tax year 2019, that is, IRS records reflect $0 in

1099 income for PHILOSSAINT for the tax year 2019. Based upon the false statements in that

application, Bank of America approved the application on or about May 1, 2020, and a loan in the

amount of $2,536.00 was transferred via wire into the Royal Elite Trans Bank of America account

ending in 0778 on or about May 4, 2020.

34. On or about March 10, 2021, PHILOSSAINT electronically filed an application for

a PPP loan with Cross River Bank, falsely asserting that Royal Elite Trans had average monthly

payroll expenses of $8,333.00. In support of the Royal Elite Trans application, PHILOSSAINT

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submitted his 2019 individual tax return, 1040, which included a schedule C for Royal Elite Trans.

According to the 1040 Schedule C, the wages listed for the tax year 2019, reflect a total of

$23,500.00 which would equate to $1,958.33 in monthly payroll, not the $8,333.00 stated on the

application. Additionally, IRS records reflect no Forms W2 issued by Royal Elite Trans for tax

year 2019. Based upon the false statement that PHILOSSAINT submitted in support of the

application, Cross River Bank approved the application on or about March 15, 2021, and a loan in

the amount of $20,833.00 was transferred via wire into the Royal Elite Trans Bank of America

account ending in 0080 on or about March 17, 2021.

35. On or about February 24, 2021, PHILOSSAINT electronically filed an application

for an EIDL advance with the SBA, falsely asserting that Royal Elite Trans had eleven employees

and gross receipts of $58,391.00 in fiscal year 2020. IRS records and Florida Department of

Revenue records reflect only one employee for the tax year 2020. According to IRS records, Royal

Elite Trans did not file a schedule C for tax year 2020, that is, the $58,391.00 in gross receipts

PHILOSSAINT listed on the application were never reported to the IRS. Based upon the false

statements, SBA approved an advance of $8,000, which was transferred via wire into the Royal

Elite Trans Bank of America account ending in 0080 on or about July 6, 2021.

36. Between July 2021 and December 2021, SBA advised PHILOSSAINT that his

application for an EIDL loan on behalf of Royal Elite Trans was denied. PHILOSSAINT sought

repeated appeals to get more loan money. Based on PHILOSSAINT’s false statements and false

documents, the SBA approved an EIDL loan of $289,400, which was transferred via wire into the

Royal Elite Trans Bank of America account ending in 0080 on or about December 21, 2021.

Additionally, the EIDL application for Royal Elite Trans was related by device / IP address with

68 other PPP / EIDL applications.

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Fraudulent PPP and EIDL Applications Submitted for Companies related to
PHILOSSAINT’s Fiancée

37. A review of bank records, ADP records, SBA records, travel records, public

records, and interviews have identified M.T. as PHILOSSAINT’s fiancée and one of the members

of the conspiracy.

1. CINDA FOUNDATION EIDL Application

38. One of the companies that EIVC on-boarded with ADP was CINDA

FOUNDATION INC. (“CINDA FOUNDATION”). M.T.’s mother is listed on Florida

Department of State records as the president of CINDA FOUNDATION, but, as noted below, on

at least one loan application, M.T. stated that she was the owner of the business. ADP records

revealed CINDA FOUNDATION created payroll accounts for four employees, M.T., D.D., O.F.

and N.T., all of whom have been identified as family members of M.T. The pay periods associated

with the payroll began in April of 2021 and ended in September of 2021. ADP records indicate

the payroll checks written to D.F. and O.F. were deposited into M.T.’s Chase bank account ending

in 6299. Additionally, payroll earnings for M.T. and N.T. were direct-deposited into Chase bank

account ending in 3281, an account M.T. is the signatory of. An interview with purported

employee N.T., revealed N.T. was never an employee for CINDA FOUNDATION, never received

payment from CINDA FOUNDATION, and never gave permission for M.T. or PHILOSSAINT

to use N.T.’s means of identification.

39. On November 18, 2020, M.T. electronically applied for a SBA EIDL as owner of

the business entity, Cinda Foundation Inc (“CINDA FOUNDATION”). The application, which

was submitted through the SBA online portal, contained multiple false statements as outlined

below.

40. According to Florida Department of State records, on August 24, 2010, D.F.

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(“D.F”) incorporated CINDA FOUNDATION, EIN 27-3302591, as a Florida Not For Profit

Corporation with the principal office address at 2529 Hikers Court, Kissimmee, FL 34743. D.F.

has been identified as M.T.’s mother. On January 31, 2016, CINDA FOUNDATION was

reinstated, the principal address was changed to 4251 SW 139th Avenue, Miramar, FL 33027. The

address is a lot in a residential neighborhood with a registered owner of Quality Farmhouse

Investment LLC according to the Broward County Property Appraiser’s records. Surveillance

revealed no signage or activity indicating the presence of a charitable foundation. The records list

M.T. as the treasurer or trustee and O.F. (“O.F.”) as the Vice President.

41. On the EIDL application, M.T. was listed as the authorized representative and

100% owner of CINDA FOUNDATION. According to Florida Department of State records, D.F.

is the president and owner of CINDA FOUNDATION, not M.T.

42. The address listed on the EIDL application for CINDA FOUNDATION was 4251

SW 139th Avenue, Miramar, FL 33027. As noted above, surveillance and public records show

that the property is not owned by CINDA FOUNDATION, D.F., or M.T., and no charitable

foundation is operating out of that residential property.

43. On the EIDL application, M.T. falsely asserted that CINDA FOUNDATION was

an S-Corporation and stated “No”, when asked if the applicant was a Non-Profit Organization.

The Florida Department of State lists CINDA FOUNDATION as a Florida not-for profit

corporation. According to Internal Revenue Service (“IRS”) records, CINDA FOUNDATION

files as a tax-exempt organization which uses Form 990 (titled “Return of Organization Exempt

from Income Tax” and/or Form 990-N (titled “Electronic Notice (e-Postcard)”). Typically, small

tax-exempt organizations that have an annual reporting requirement and generate annual gross

receipts of $50,000.00 or less can satisfy the requirements by submitting Form 990-N.

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44. On the EIDL application, M.T. claimed CINDA FOUNDATION generated gross

revenues of $238,254.00 for the twelve months prior to the date of the disaster (January 31, 2020).

The IRS does not possess any S-Corporation records for CINDA FOUNDATION for tax year

2019, only Form 990-N, which is used for tax exempt organizations with gross receipts as

$50,000.00 or less.

45. On the EIDL application, M.T. claimed CINDA FOUNDATION had 5 employees

as of January 31, 2020. The Florida Department of Revenue has no record of CINDA

FOUNDATION paying employee wages for tax year 2019 or 2020, thus the employee number

was fabricated.

2. FERRO’S EIDL Application

46. On July 22, 2020, O.F., who has been identified as M.T.’s stepfather, received a

SBA EIDL for Ferro’s Entertainment and Production LLC (“FERRO’S”). On July 27, 2020,

$72,800.00 was electronically funded into Popular Bank account ending in 3145, an account O.F.

is an authorized signatory of. The same day, a wire in the amount of $70,800.00 was sent to M.T.’s

Chase bank account ending in 6299, with the remark “Investment working capital for law firm.”

Per the SBA guidelines, the proceeds from an EIDL are to be used as working capital of the

established business that received the loan; not to start a new business or expand a different

business. Pursuant to the provisions governing the EIDL program, loan proceeds must be used by

the business that received the loan on certain permissible expenses. The EIDL (working capital)

loans may only be used by the afflicted business, which must have existed in an operational

condition on February 1, 2020, to pay fixed debts, payroll, accounts payable, and other bills that

could have been paid had the COVID-19 disaster not occurred.

47. According to Florida Department of State records, Ferro’s Entertainment &

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Production LLC was incorporated on December 12, 2016 by O.F. as the sole registered agent.

FERRO’S principal place of business is listed as 4251 SW 139th Ave, Miramar, FL 33027 – the

same address listed for CINDA FOUNDATION. Surveillance and public records show that the

property is not owned by FERRO’S, O.F., or M.T., and no “entertainment and production”

company is operating out of that residential property.

48. After filing an Annual Report on April 26, 2017, FERRO’S was dormant until the

entity was re-instated on July 28, 2020 – after the start of the pandemic and after the EIDL

application was submitted and funded – with the registered agent updated to M.T. Also, D.F.

(M.T.’s mother) was added as vice-president of the entity on February 1, 2021. The principal place

of business for the entity was updated on February 1, 2022 to 5365 SW 155 Ave, Miramar FL

33027, which is M.T.’s residential address. Additionally, the Florida Department of Revenue has

no record of FERRO’S paying any employee wages.

3. CINDA FOUNDATION PPP Application

49. On or around February 15, 2021, a PPP loan application for CINDA

FOUNDATION was electronically filed through Cross River Bank (“CRB”). On or around April

7, 2021, a total of $104,166.67 was funded electronically into D.F.’s Popular Community Bank

(“PCB”) account ending in 6917. D.F. is the authorized signatory of this account. The PPP loan

application listed D.F. as the 100% owner and authorized representative of the applicant business.

The application contained multiple false statements as outlined below.

50. According to Florida Department of State records, on August 24, 2010, D.F.

incorporated CINDA FOUNDATION, EIN 27-3302591, as a Florida Not For Profit Corporation

with the principal office address at 2529 Hikers Court, Kissimmee, FL 34743. On January 31,

2016, CINDA FOUNDATION was reinstated, the principal address was changed to 4251 SW

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139th Avenue, Miramar, FL 33027. The records list M.T. as the treasurer or trustee and O.F. as

the Vice President.

51. CINDA FOUNDATION’s PPP loan application claimed to have five employees

and monthly payroll of approximately $57,168.00. IRS records reflect no quarterly employee

wage documentation (Forms 941 titled “Employer’s Quarterly Federal Tax Return”) for CINDA

FOUNDATION for tax years 2019 and 2020. Additionally, the Florida Department of Revenue

does not possess any wage and earnings records for CINDA FOUNDATION for tax years 2019

and 2020, thus the employee and payroll numbers were fabricated.

52. The address listed on the PPP loan application for CINDA FOUNDATION was

4251 SW 139th Avenue, Miramar, Florida 33027. As noted above, physical surveillance showed

that the foundation was not operating out of that address.

53. In support of the PPP loan application for CINDA FOUNDATION, counterfeit IRS

forms were submitted—that is, documents that were never submitted to the IRS, but instead were

created to support the approval of the PPP loan application. CINDA FOUNDATION submitted

four counterfeit Forms 941 with their PPP loan application for quarters one through four of tax

year 2020. According to IRS records, CINDA FOUNDATION did not file employee wage

documentation (Forms 941) for tax years 2018 through 2020. Additionally, the 2020 Forms 941

CINDA FOUNDATION submitted with their PPP loan application are identical to Forms 941

submitted by at least three other corporations that also worked with PHILOSSAINT in preparing

PPP loan applications, except for the EIN, corporate name, address, quarter, and federal income

tax withheld.

54. ADP records revealed CINDA FOUNDATION created payroll accounts for four

purported employees, M.T., D.D., O.F. and N.T., all of whom have been identified as family

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members of M.T. The pay periods associated with the payroll began in April 2021 and ended in

September 2021. Bank records for CINDA FOUNDATION revealed no prior employee or payroll

transaction before receiving the PPP loan. The ADP payroll account was created to facilitate the

scheme and make the businesses look legitimate in order to receive loan forgiveness.

55. On or around September 24, 2021, CINDA FOUNDATION submitted SBA Form

3508S (titled “PPP Loan Forgiveness Form”), which asserted that $65,353.80 of the total funded

PPP loan amount of $104,166.67 was spent on CINDA FOUNDATION’s payroll costs for five

employees. The Florida Department of Revenue records list total wages paid of $27,230.75 for

only four employees, for the second quarter of tax year 2021 only. The Florida Department of

Revenue does not possess any wage and earnings records for CINDA FOUNDATION for quarters

one, three, and four of tax year 2021.

56. ADP records indicate the payroll checks written to D.F. and O.F. were deposited

into M.T.’s Chase bank account ending in 6299. Additionally, payroll earnings for M.T. and N.T.

were direct-deposited into Chase bank account ending in 3281, an account M.T. is the signatory

of. An interview with purported employee N.T., revealed N.T. was never an employee for CINDA

FOUNDATION, never received payment from CINDA FOUNDATION, and never gave

permission for M.T., PHILOSSAINT, or anyone else to use N.T.’s means of identification for any

purpose, including in furtherance of the wire fraud scheme.

57. After obtaining the loan proceeds, M.T. and J.P. received $21,416.70. Six checks

from the CINDA FOUNDATION Popular Bank account ending in 6917 were written to EIVC and

M.T. Between April 15, 2021 and June 29, 2021, check numbers 1060, 1063, 1064 and 1066,

totaling $10,416.70 – that is, exactly 10% of the loan’s value, were deposited into EIVC bank

accounts ending in 6361 and 4241. Check numbers, 1062 and 1067, totaling $11,000.00, were

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deposited into M.T.’s Chase bank accounts ending in 6299 and 6300.

58. CINDA FOUNDATION did not use the loan proceeds toward business expenses.

On SBA Form 2483, the applicant certifies that the loan proceeds would be used to retain workers

and maintain payroll; or make payments for mortgage interest, rent, utilities, cover operations

expenditures, covered property damage costs, covered supplier cost, and covered work protection

expenditures as specified under the Paycheck Protection Program Rules. The applicant further

certifies that he/she understands that if the funds are knowingly used for unauthorized purposes,

the federal government may hold the applicant legally liable, such as for charges of fraud.

PHILOSSAINT’s Movement of Loan Proceeds

59. After fraudulently obtaining the EIDL proceeds, PHILOSSAINT attempted to

conceal the fact that he was not using the loan proceeds towards business expenses by moving the

funds between various bank accounts belonging to himself and his fiancée, M.T., who further

facilitated the scheme by wiring the funds to international bank accounts naming PHILOSSAINT

as the recipient. Driver’s license records show that PHILOSSAINT and M.T. share the same

residence. Recent surveillance also shows that Royal Elite Trans and M.T.’s businesses are in the

same location.

60. On December 20, 2021, the Royal Elite Trans BOA account ending in 0080 had a

balance of $2,039.50. On December 21, 2021, the account balance increased to $291,439.50 after

the EIDL disbursement was electronically deposited. A review of the transactions following the

EIDL deposit revealed PHILOSSAINT did not use the loan proceeds to support his business.

Instead, PHILOSSAINT and M.T. transferred money from the loan to other bank accounts for

personal use, as outlined below.

61. On December 21, 2021, PHILOSSAINT completed two separate Zelle account

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transfers totaling $10,000.00 to another bank account under his name.

62. Between December 22, 2021 and January 20, 2022, PHILOSSAINT sent in total

$264,325.07 through Zelle, checks, and wire payments to accounts controlled by M.T.

a. December 22, 2021, BOA account ending in 0080 check #283 in the amount of

$34,000.00, was deposited into Chase bank account ending in 6299. Chase records

show M.T. is the sole authorized signatory of this account.

b. December 22, 2021, BOA account ending in 0080 check #284 in the amount of

$6,573.63, was deposited into Chase bank account ending in 3281. Chase records

show this is a joint checking account listing M.T. and D.M.F. as authorized

signatories. D.M.F. is a relative of M.T.

c. On January 5, 2022, a wire in the amount of $26,371.30 from Royal Elite’s BOA

account ending in 0080 was deposited in Chase account ending in 1969. Chase

records show M.T. is the sole authorized signatory of this account.

d. On January 18, 2022, a Zelle payment in the amount of $7,380.14 from Royal

Elite’s BOA 0080 account was sent to M.T.’s Chase account ending in 6299.

e. On January 20, 2022, a wire in the amount of $190,000.00 from Royal Elite’s BOA

account ending in 0080 was deposited into M.T.’s Chase account ending in 1969.

63. A review of M.T’s accounts reflect that, once she received the wires from

PHILOSSAINT, M.T. sent international wires to a bank account in the Dominican Republic that

listed JOFF PHILOSSAINT as the recipient.

64. The day after the deposit of $26,371.30 from Royal Elite’s BOA account ending in

0080 into M.T.’s Chase account 1969 on January 5, 2022, M.T. submitted an international wire in

the amount of $26,371.30 to JOFF PHILOSSAINT’s Dominican Republic bank account.

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65. Following the January 20, 2022, deposit of $190,000.00 from Royal Elite’s BOA

account ending in 0080 into M.T.’s Chase bank account ending in 1969, on January 25, 2022, M.T.

submitted an international wire in the amount of $200,000.00 to JOFF PHILOSSAINT’s

Dominican Republic bank account.

PHILOSSAINT’s Naturalization Fraud

66. On or about February 24, 2020, in Miami-Dade County, in the Southern District of

Florida, PHILOSSAINT, who was born in Haiti and was a Haitian citizen, applied to naturalize as

a United States citizen. Specifically, PHILOSSAINT submitted an Application for Naturalization

(Form N-400) to the Hialeah, Florida, office of the United States Citizen and Immigration Services.

PHILOSSAINT affirmed his application under the penalty of perjury that it was true and correct.

67. On or about December 15, 2020, in Miami-Dade County, in the Southern District

of Florida, PHILOSSAINT appeared before a naturalization examiner for an interview based on

his previously submitted Form N-400 Application. He was then placed under oath and affirmed

under penalty of perjury that the statements he had earlier provided on the N-400 form were still

true and correct. During that time, PHILOSSAINT was given an opportunity to change any of

the answers he had previously provided on the N-400 if in fact, they were no longer true.

68. On his Form N-400 Application at Part 12, Question 22, and in his subsequent

interview under oath, PHILOSSAINT stated that he had never, “committed, assisted in

committing, or attempted to commit, a crime or offense” for which he had not been arrested, when

in truth and in fact, and as PHILOSSAINT then and there knew during his interview, he had

committed crimes for which he had not been arrested in the ten month time period following the

submission of his N-400, but before his naturalization interview, that is, the crimes described in

this affidavit, and related offenses.

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69. On his Form N-400 Application at Part 12, Question 30 (i), and in his subsequent

interview under oath, PHILOSSAINT stated that he had never, “Made any misrepresentation to

obtain any public benefit in the United States” when in truth and in fact, and as PHILOSSAINT

then and there knew at his naturalization interview, that following the submission of his N-400

and before his naturalization interview, he had misrepresented businesses, their earnings, and their

employee workforce in an effort to obtain multiple United States Covid-19 Disaster Loans.

70. On his Form N-400 Application at Part 12, Question 31, and in his subsequent

interview under oath, PHILOSSAINT stated that he had never, “given any U.S. Government

officials any information or documentation that was false, fraudulent, or misleading” when in truth

and in fact, and as PHILOSSAINT knew then and there at his naturalization interview, that

following the submission of his N-400, but before his naturalization interview, he had

misrepresented businesses, their earnings, and their employee workforce, including submitting

fraudulent tax returns, to obtain multiple United States Covid-19 Disaster Loans.

71. On February 9, 2021, PHILOSSAINT became a naturalized United States citizen

in a ceremony conducted by the United States Citizen and Immigration Services in Hialeah,

Florida.

72. In an attempt to confirm that the naturalized JOFF PHILOSSAINT in question is

the same JOFF PHILOSSAINT who applied for and received U.S. Covid Disaster Loans, a

comparison was done of both applicant’s identifying information. In addition to the same name,

JOFF PHILOSSAINT, being used by both applicants, the full Social Security Number, date of

birth, and telephone number were given on both the N-400 and U.S. Covid Disaster Loan

applications.

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CONCLUSION

73. Based on the aforementioned information, I respectfully submit that there is

probable cause to believe that JOFF PHILOSSAINT did:

a. willfully, that is, with intent to further the object of the conspiracy, and
knowingly combine, conspire, confederate, and agree with persons known and unknown
to commit wire fraud, that is, to knowingly and with intent to defraud, devise and intend 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 and, for the
purpose of executing such scheme, did knowingly transmit and cause to be transmitted by
means of wire communication in interstate and foreign commerce, certain writings, signs,
signals, pictures, and sounds; in violation of 18 U.S.C. § 1343, all in violation of Title 18,
United States Code, Section 1349;

b. knowingly and willfully conspire with persons known and unknown to: (i)
conduct a financial transaction affecting interstate and foreign commerce involving the
proceeds of specified unlawful activity (wire fraud), knowing that the property involved in
the transaction represented the proceeds of some form and unlawful activity, and knowing
that the transaction was designed in whole or in part to conceal or disguise the nature,
location, source, ownership, or control of the proceeds of specified unlawful activity, in
violation of 18 U.S.C. § 1956(a)(1)(B)(i); and (ii) transmit, and transfer monetary
instruments and funds, from a place in the United States to and through a place outside the
United States, knowing that the monetary instruments and funds represented the proceeds
of some form of unlawful activity and knowing that such transmission and transfer was
designed in whole or part to conceal and disguise the nature, location, source, ownership,
and control of the proceeds of specified unlawful activity (wire fraud), in violation of 18
U.S.C. § 1956(a)(2)(B)(i); and (iii) engage in monetary transactions by, through, and to
financial institutions affecting interstate and foreign commerce, in criminally derived
property of a value greater than $10,000 that is derived from specified unlawful activity
(wire fraud), in violation of 18 U.S.C. § 1957; all in violation of Title 18, United States
Code, Section 1956(h);

c. knowingly transfer, possess, and use, without lawful authority, the means
of identification of another person, during and in relation to a felony violation of 18 U.S.C.
§ 1343, all in violation of Title 18, United States Code, §§ 1028A(a)(1) and 2; and

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Case 9:22-mj-08336-BER Document 3 Entered on FLSD Docket 08/08/2022 Page 28 of 28

d. knowingly procure, contrary to law, naturalization as a United States citizen
for himself; in violation of Title 18, United States Code, Section 1425(a).

FURTHER YOUR AFFIANT SA YETH NAUGHT.

SP~~,~
H DSE

Sworn and Attested to before me by Applicant by Telephone (Facetime)

pursuant to Fed. R. Crim. P. 3, 4(d), and 4.1 this _ _ day of August, 2022.

BRUCE E. REINHART
UNITED STATES MAGISTRATE JUDGE

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