Full text
CASE 0:22-cr-00124-NEB-DTS Doc. 961 Filed 03/25/26 Page 1 of 5
UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
UNITED STATES OF AMERICA,
Case No. 22-cr-124 (NEB/DTS)
Plaintiff,
Declaration of Pauline Roase in
v. Support of Motion for Preliminary
Order of Forfeiture
3. MAHAD IBRAHIM,
Defendant.
Pauline Roase, for her declaration pursuant to 28 U.S.C. § 1746, declares under
penalty of perjury as follows:
1. I am employed as a Forensic Accountant with Federal Bureau of
Investigation and have been so employed since August 2014. As a Forensic
Accountant, my primary duties and responsibilities consist of conducting financial
investigations of individuals and businesses for possible violations of federal laws. I
am presently assigned to the FBI’s Minneapolis, Minnesota field office where I am a
member of the Forensic Accounting Squad. During my employment as a Forensic
Accountant, I have participated in various investigations involving mail fraud, wire
fraud, fraud against the government, money laundering, and other criminal acts,
including criminal schemes where individuals misappropriate money from the
investing public. I have received training and gained experience in analyzing personal
and business documents and records, and in analyzing direct and indirect relationships
between various types of personal and business records and documents, tax returns,
and legal and illegal businesses and activities.
CASE 0:22-cr-00124-NEB-DTS Doc. 961 Filed 03/25/26 Page 2 of 5
2. I am one of the investigators assigned to the investigation of Mahad
Ibrahim and his co-defendants in this matter, among others, for their involvement in
the food program fraud scheme.
3. The information contained in this declaration includes information
received from other law enforcement agencies and officers, including forensic
accountants, agents, interviews with witnesses and others, admissions of the
defendants, as well as information I have learned directly through my review of records
and materials. This declaration does not include, and is not intended to include, all
information known to me or to other law enforcement agents regarding this
investigation.
4. In his plea agreement, Ibrahim agreed to the forfeiture of one parcel of
real property and the contents seized from three bank accounts. Ibrahim also
consented to “a money judgment forfeiture in the amount of not more than $7,324,412
but not less than $1.5 million, which represents the amount of proceeds (Ibrahim)
obtained from the wire fraud scheme.” ECF No. 842 ¶ 14.
5. Ibrahim obtained at least $7,324,412 in fraud proceeds. This Declaration
is submitted in support of the Government’s request for the maximum money
judgment amount allowed based upon Ibrahim’s plea agreement.
6. Exhibit A is a spreadsheet summarizing the sources and amounts of
fraud proceeds Ibrahim received which are included in the requested money judgment
forfeiture. Exhibit A illustrates that because of the fraud scheme, Ibrahim obtained at
least $7,324,412 of fraud proceeds directly and through entities he controls.
2
CASE 0:22-cr-00124-NEB-DTS Doc. 961 Filed 03/25/26 Page 3 of 5
7. The first category of proceeds consists of deposits to Afrique Hospitality
Group LLC (“Afrique”). Ibrahim was CFO of Afrique and received half of Afrique’s
earnings. The other half of Afrique’s earnings belonged to Ibrahim’s co-defendant,
Mukhtar Shariff, who was CEO. Exhibit B is a summary chart showing the sources
and uses of the funds that were paid into and out of Afrique’s bank accounts, with
additional calculations shown in the top right of the Exhibit. As Exhibit B shows, the
deposits counted as food program fraud proceeds include money from ThinkTechAct
Foundation, Empire Cuisine and Market LLC (“Empire Cuisine”)/Empire
Enterprises LLC (“Empire Enterprises”), Feeding Our Future, Bushra Wholesalers
LLC, and other Defendant-owned entities. It also accounts for funds paid to
Defendant’s other companies, Empire accounts, Defendant’s personal accounts, and
Ikram Mohamed, among other deductions to avoid double-counting. The subtotal of
net food program fraud proceeds received by Afrique as shown on Exhibit B is
$2,495,448.13. This amount was divided in half in consideration of Shariff and
Ibrahim’s respective roles in operating Afrique. Ibrahim therefore received
$1,247,724.07. This is consistent with the treatment of Defendant Shariff in his money
judgment forfeiture. See ECF No. 680 ¶ 20, Ex. D, Chart 2.
8. The second category of proceeds consists of deposits to ThinkTechAct
Foundation. Exhibit C is a is a summary chart showing the sources and uses of funds
that were paid into and out of ThinkTechAct Foundation’s US Bank checking account
ending in 3379, with additional calculations shown in the middle left of the Exhibit.
3
CASE 0:22-cr-00124-NEB-DTS Doc. 961 Filed 03/25/26 Page 4 of 5
Partners in Nutrition ($18,006,479.56) and Feeding Our Future ($3,758,133.59)
provided a total of $21,764,613.15 in food program fraud proceeds to ThinkTechAct,
which, in turn, provided Empire Cuisine ($12,242,852.71), Empire Enterprises
($3,189,119.83), Afrique ($1,783,583.90), and defendants’ other entities ($177,390.00)
with a total of $17,392,946.44. This movement of funds was one part of the massive
money laundering scheme prosecuted in this case. Ibrahim’s acknowledged in his plea
agreement that he was aware of the high probability that Empire Cuisine, Empire
Enterprises, Feeding Our Future, and Partners in Nutrition used ThinkTechAct to
claim entitlement to reimbursement for food that was never actually served. ECF No.
842 ¶ 2. ThinkTechAct Foundation received a net $4,371,666.71—that is, the
difference between the food program fraud proceeds received and the fraud proceeds
redistributed to co-conspirators.
9. The third category of proceeds consists of deposits to MIB Holdings
LLC. Exhibit D is a summary chart showing the sources and uses of the funds that
were paid into and out of MIB Holdings LLC’s bank accounts. As shown in Exhibit
D, four co-conspirator entities provided food program fraud proceeds to MIB Holdings
LLC: Empire Cuisine ($915,300), Empire Enterprises ($538,829.80), and Afrique
Hospitality Group (net total $84,040.38), for a sum of $1,538,170.18. Ibrahim is the
sole owner of MIB Holdings LLC.
10. The fourth category of proceeds consists of deposits to Mahad Ibrahim’s
personal accounts. Exhibit E is a summary chart showing the sources and uses of the
4
CASE 0:22-cr-00124-NEB-DTS Doc. 961 Filed 03/25/26 Page 5 of 5
funds that were paid into and out of Ibrahim’s personal bank accounts. As shown in
Exhibit E, Afrique Hospitality Group deposited $104,813.27 and Empire Cuisine
made two deposits ($30,000 and $12,000) totaling $42,000, for a total of $146,813.27.
11. The fifth category of proceeds consists of deposits to Mind Foundry.
Exhibit F is a summary chart showing the sources and uses of funds from a Mind
Foundry checking account. As shown in Exhibit F, Mind Foundry received
$41,391.43 from Partners in Nutrition, which was active in the food program fraud
scheme. Mind Foundry in turn provided $21,353.41 to Empire Cuisine as part of the
money laundering scheme. The difference between the Partners in Nutrition deposit
and the payment to Empire Cuisine is the money that Ibrahim personally obtained, a
total of $20,038.02.
12. I am also aware that law enforcement agents and officers have searched
for property that constitutes or is traceable to proceeds Ibrahim obtained as a result of
the charges for which he pled guilty, but they have been unable to locate any such
directly traceable proceeds that can be seized for forfeiture other than the assets
described above or in Ibrahim’s plea agreement. The remaining proceeds Ibrahim
obtained because of the fraud scheme and conspiracy have been spent, transferred,
hidden or otherwise been made unavailable for seizure for forfeiture.
13. I declare under penalty of perjury that the foregoing is true and correct.
Dated: 3/25/2026 s/Pauline Roase
Pauline Roase
Forensic Accountant, FBI
5