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Home Source documents Court filing — United States v. Farah (Dkt. 929, D. Minn.)

Court filing — United States v. Farah (Dkt. 929, D. Minn.)

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     CASE 0:22-cr-00124-NEB-DTS       Doc. 929   Filed 11/06/25   Page 1 of 15




                       UNITED STATES DISTRICT COURT
                          DISTRICT OF MINNESOTA
                       Criminal No. 22-124(4) (NEB/DTS)

 UNITED STATES OF AMERICA,                )
                                          )
                     Plaintiff,           )
                                          ) GOVERNMENT’S POSITION
       v.                                 ) REGARDING SENTENCING
                                          )
 ABDIMAJID MOHAMED NUR,                   )
                                          )
                     Defendant.           )


      The United States of America, by and through its attorneys, Daniel N. Rosen,

United States Attorney for the District of Minnesota, and Joseph H. Thompson, Harry

M. Jacobs, and Daniel W. Bobier, Assistant United States Attorneys, submits the

following sentencing memorandum and respectfully requests that the Court impose

a sentence of 168 months in prison.

I.    BACKGROUND

      Defendant Abdimajid Nur participated in the largest Covid-19 fraud scheme

in the United States. His crimes have shaken Minnesota to its core—both in terms of

the brazen and staggering nature of the fraud and the complete disrespect and

contempt shown for the criminal justice system. His crimes have changed the state

forever, and not for the better.

      The Court must send a message in the strongest possible terms to Nur and

anyone else who believes they can shamelessly take advantage of state and federal

social safety net programs and steal with impunity money intended for children.
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      A.    Nur’s Fraud Scheme

      Defendant Abdimajid Nur was convicted of participating in a massive

fraudulent scheme to obtain federal child nutrition program funds intended to

provide free meals to children in need. The defendant and his co-conspirators

obtained, misappropriated, and laundered more than $40 million in program funds

that were intended as reimbursements for the cost of serving meals to children. They

did so by exploiting changes in the program intended to ensure children received

adequate nutrition during the Covid-19 pandemic. Nur and his co-conspirators took

advantage of the Covid-19 pandemic—and the resulting program changes—to enrich

themselves by fraudulently misappropriating millions of dollars in federal child

nutrition program funds.

      The scheme originated out of Empire Cuisine & Market, a small storefront

halal market in Shakopee. Empire Cuisine enrolled in the Federal Child Nutrition

Program in April 2020—during the early days of the Covid-19 pandemic and within

weeks of registering the company with the Minnesota Secretary of State.




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      Nur and his co-conspirators immediately opened a number of federal child

nutrition program sites and began claiming—falsely—to be serving meals to

thousands of children per day. These claims were fraudulent. As the Court heard

repeatedly at trial, no meals at all were served at many of the Empire Cuisine “sites.”

Many of their purported food “sites” were nothing more than parking lots or vacant

commercial spaces. Indeed, at some of the sites, it was instead the Shakopee Public

Schools who were actually serving meals to kids on a daily basis. At their fraudulent

peak, Nur and his co-defendants claimed to serve 2.7 million meals to children in the

month of March 2021 alone.

      Abdimajid Nur played a key role in the fraud scheme. He created and

submitted the bulk of the fraudulent meal counts and invoices that he and his co-

conspirators used to support their fraudulent claims, including at the direction of

Abdiaziz Farah.


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      As shown in trial, Nur had many completed and in-progress fraudulent

invoices saved on his Google Drive.




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      Nur submitted these fraudulent meal counts and invoices via email to the

sponsoring agency, Partners In Nutrition, in support of his and his co-conspirators’

fraudulent claims. Nur also created and submitted fraudulent rosters purporting to

list the names of children receiving meals at their fraudulent meal sites. But, as the

Court saw, the rosters were fraudulent, filled with the names of fake children.




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      Nur also recruited his sister, Hayat Nur, to help create and submit fraudulent

meal counts. Nur taught his sister how to create fraudulent documentation. In June

2021, for example, Nur sent an email instructing his sister to create fraudulent meal

counts for 11 fraudulent food sites. The meal counts were to claim—falsely—that he

and his co-conspirators had distributed meals to more than 11,000 children a day,

seven days a week.




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      Nur and his co-conspirators engaged in a conspiracy to launder the proceeds of

their fraud scheme using a series of shell companies both in the United States and

Kenya. Nur helped distribute millions of dollars in fraudulent proceeds among their

money laundering entities. Nur and Abdiaziz Farah regularly texted about the

distribution of the fraudulent proceeds.




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      Nur and Abdiaziz Farh created a shell company called Empire Enterprises,

through which they laundered $7 million in fraud proceeds. They used some of this




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money to purchase real estate in Kenya, including an apartment building in

Nairobi.




      Nur also set up his own shell company—Nur Consulting LLC—that he used to

receive and launder his share of the fraud proceeds by disguising them as “consulting”

and similar payments.




      In all, Nur used Nur Consulting to receive more than $900,000 in fraud

proceeds from various entities involved in the scheme, including Empire Cuisine &

Market, Empire Enterprises, and ThinkTechAct Foundation.




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      Nur spent his fraud proceeds freely. He purchased a 2021 Dodge Ram pickup

truck for $64,000. Six weeks later, he purchased a 2021 Hyundai Santa Fe for

$35,000. Nur also used fraud proceeds to take a honeymoon to the Maldives, where

he stayed in a private villa.




Gov’t Ex. G-314. He also spent $30,000 in fraud proceeds to purchase jewelry in

Dubai. PSR ¶79.




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      Finally, as the jury heard at trial, Nur used some of his fraud proceeds to

fraudulently obtain a college degree. In 2021, Nur enrolled in Herzing University, an

online college with campuses in St. Louis Park and other locations around the

country. Nur paid $12,000 to a company called PayMeToDoYourHomework.com to

take his courses for him and complete all homework assignments and exams. They

guaranteed him an A or B in each course.

      Nur paid the company approximately $5,000 to take all his Fall 2021 courses

for him. In January 2022, he paid another $6,000 to have the company take all his

Spring 2022 semester courses. He made these payments via Nur Consulting, the shell

company he created to receive and launder his fraud scheme. Nur appears to have

gotten his money’s worth. According to the PSR, Nur received a bachelor’s degree in

healthcare management from Herzing University in August 2022. PSR ¶157. Despite

having graduated from Shakopee High School in 2019 with only a 1.75 GPA, Herzing

University records show that Nur “earned” his bachelor’s degree in less than 3 years

with a 3.42 GPA.1 PSR ¶¶155-57.

      B.     Abdimajid Nur’s Trial

      Nur has never accepted any responsibility or shown any remorse for his crime.

As the Court is aware, at the end of his six-week trial, Nur and others attempted to

bribe one of the trial jurors in exchange for her return of a not guilty verdict. Nur has




1     Nur told the Probation Office that he completed one semester of MBA classes at the
University of Minnesota. PSR ¶158. Assuming that is true, Nur presumably submitted his
fraudulent Herzing University transcript and diploma when he applied to enter that
program. It is not clear whether he paid someone to take his MBA classes.

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pled guilty for his role in that bribe attempt and faces sentencing in that case at a

later date.

II.    THE GUIDELINES RANGE

       A.     The Base Offense Level and Loss Amount

       The base offense level is 7 pursuant to Guidelines § 2B1.1(a)(1). PSR ¶111. The

base offense level is increased 22 levels pursuant to Guidelines § 2B1.1(1)(L) because

the loss was more than $25 million but less than $65 million. PSR ¶112. The offense

level is increased 2 levels pursuant to Guidelines § 2B1.1(b)(10)(C) because the

offense involved sophisticated means. PSR ¶113.

       The offense level is increased 2 levels pursuant to Guidelines § 2B1.1(b)(12)

because the offense involved conduct described in 18 U.S.C. § 1040 (Fraud in

Connection with a Major Disaster or Emergency Benefits). PSR ¶114. The offense

level is increased by 2 levels pursuant to Guidelines § 2S1.1(b)(2)(B) because the

defendant was convicted under 18 U.S.C. § 1956. PSR ¶113.

       The PSR applied a 2-level enhancement for obstruction of justice based on

Nur’s participation in the attempt to offer a $150,000 bribe to Juror 52 in exchange

for the return of a not guilty verdict. PSR ¶123. Because defendant has pled guilty

and faces sentencing in a separate case for his role in that scheme, the government

does not believe the enhancement applies in this case.

       The defendant receives a 2-level reduction pursuant to Guidelines § 4C1.1

because he qualifies as a zero-point offender. PSR ¶126.




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        B.    Criminal History

        Abdimajid pled guilty for his role in the attempt to bribe Juror 52 but he has

not yet been sentenced in that case. Accordingly, he receives no criminal history

points for that conviction and falls in criminal history category I. PSR ¶132.

        C.    Advisory Guidelines Range

        An offense level of 33 and criminal history level I results in an advisory

Guidelines range of 135 to 168 months in prison.

III.    GOVERNMENT’S SENTENCING RECOMMENDATION

        Based on a review of the § 3553(a) factors, the government recommends that

the Court impose a sentence of 168 months in prison.

        A.    Nature and Circumstances of the Offense

        Nur participated is one of the largest fraud schemes in the history of the

District of Minnesota, and the single largest Covid-19 fraud scheme in the country.

He took advantage of a once-in-a-century global pandemic to enrich himself. He

abused the generosity of Minnesota’s generous social safety net—a system designed

to ensure that no child goes without food.

        The cynicism of his crime is staggering. Nur and his co-defendants carried out

their scheme using fictitious non-profit educational companies. They acted under the

guise of a mosque and a public school district.

         Despite the egregiousness of his fraud scheme, Nur has never taken any

responsibility nor expressed any remorse for his crime. Like his co-defendants, he has

no contrition for defrauding the very country that took him in.



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       B.     History and Characteristics of the Defendant

       Nothing in Nur’s background explains or excuses his crime. Nur came to the

United States at a youth. PSR ¶¶139-41. He ran high school track. PSR ¶¶142-43.

Nur later joined the army reserves. PSR ¶143. He later had an opportunity to attend

college, but rather than take advantage of the opportunity to learn, he paid an online

service to do his homework and take his tests for him.

       C.     The Need for Deterrence

       Nur participated is one of the largest fraud schemes in the history of the

District of Minnesota, and the single largest Covid-19 fraud scheme in the country.

But Nur didn’t just take advantage of the Covid-19 pandemic to enrich himself and

his co-conspirators. He took advantage of our state’s compassion, and its efforts to

ensure no child went hungry.

       Make no mistake, Nur’s fraud has done great damage to the state. It has eroded

trust in the government and raised questions about the sustainability of the state’s

system of social services. Despite this, to this day, Nur has not expressed any remorse

for his actions.

       Cases like this are difficult to investigate and prosecute, which results in the

widely held belief that perpetrators routinely get away with these crimes. The Court

must send a message that these types of crimes against government programs will

not be tolerated. Taking into consideration the Sentencing Guidelines, as well as all

of the other factors required to be considered under § 3553(a), the government

respectfully suggests that a sentence of 168 months in prison appropriately reflects

the seriousness of Nur’s crimes, promotes respect for the law, provides a just

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punishment, and creates adequate deterrence not only to Nur, but to all other

individuals who take advantage of the state and believe that they are above the law.

IV.    CONCLUSION

       For the reasons stated above, the government respectfully requests that the

Court impose a sentence of 168 months in prison.



                                             Respectfully Submitted,

Dated: November 6, 2025                      DANIEL N. ROSEN
                                             United States Attorney

                                              /s/ Joseph H. Thompson
                                       BY:   JOSEPH H. THOMPSON
                                             HARRY M. JACOBS
                                             DANIEL W. BOBIER
                                             Assistant U.S. Attorneys




                                        15


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