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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
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