Information — Hashim Campbell (Eastern District of New York)

Summary

Information, Document 6, filed 09/23/21 in the Eastern District of New York, Cr. No. 21-CR-478 (FB), against Hashim Campbell, a resident of New York, New York. It states that Campbell owned and operated Expert Tax Services with members of his family, and owned and operated Apex Accounting & Tax Inc. in Brooklyn, New York. It alleges that Campbell and the Bank 1 Co-Conspirators, who were employees of Bank 1, together with others, orchestrated a scheme to submit fraudulent PPP loan applications for Bank 1 customers who did not legitimately qualify, in exchange for "commissions" taken from the loan proceeds. It also alleges that falsified tax documents were provided as support. A criminal forfeiture allegation follows.

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Case 1:21-cr-00478-FB Document 6 Filed 09/23/21 Page 1 of 8 PageID #: 18

DCP:JN
F. #2020R00955

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
---------------------------X

UNITED STATES OF AMERICA INFORMATION

- against - Cr. No. 21-CR-478 (FB)
(T. 18, U.S.C., §§ 982(a)(2), 982(b)(1),
HASHIM CAMPBELL, 1349 and 3551 et seq.; T. 21, U.S.C.,
§ 853(p))
Defendant.

---------------------------X

THE UNITED STATES CHARGES:

INTRODUCTION

At all times relevant to this Information, unless otherwise indicated:

I. The Defendant and Relevant Individuals and Entities

1. The defendant HASHIM CAMPBELL was a resident of New York, New

York.

2. In or about and between 2015 and the date of this Information, Expert Tax

Services (“Expert Tax”) was a business in New York, New York, which was owned and operated

by the defendant HASHIM CAMPBELL and members of his family. Expert Tax specialized in

income tax return preparation and filing.

3. In or about and between 2016 and the date of this Information, Apex

Accounting & Tax Inc. (“Apex”) was a business owned and operated by the defendant HASHIM

CAMPBELL in Brooklyn, New York. Apex specialized in income tax preparation and filing.

4. Bank 1, an entity the identity of which is known to the United States, was a

federally insured financial institution with branches across the United States, including in the
Case 1:21-cr-00478-FB Document 6 Filed 09/23/21 Page 2 of 8 PageID #: 19

Eastern District of New York. Bank 1 operated a branch located in New York, New York (the

“Bank 1 Branch New York”).

5. Co-Conspirator 1 (“CC-1”), Co-Conspirator 2 (“CC-2”) and Co-Conspirator

3 (“CC-3”), individuals whose identities are known to the United States, were employees of Bank

1 and worked at the Bank 1 Branch New York (the “Bank 1 Co-Conspirators”).

II. The Paycheck Protection Program

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

federal law enacted in or about March 2020, which was designed to provide emergency financial

assistance to the millions of Americans who were suffering the economic effects of the COVID-19

pandemic. One source of relief provided by the CARES Act was the authorization of up to $349

billion in forgivable loans to small businesses for job retention and certain other expenses through

a program referred to as the Paycheck Protection Program (“PPP”). In or about April 2020,

Congress authorized over $300 billion in additional PPP funding.

7. To obtain a PPP loan, a qualifying business was required to submit a PPP

loan application signed by an authorized representative of the business. The PPP loan application

required the business (through its authorized representative) to acknowledge the program rules and

to make certain affirmative certifications in order to be eligible to obtain the PPP loan. In the PPP

loan application, the small business (through its authorized representative) was required to state,

among other things, its: (a) average monthly payroll expenses, and (b) number of employees.

These figures were used to calculate the amount of money the small business was eligible to

receive under the PPP. In addition, businesses applying for a PPP loan were required to provide

documentation showing their payroll expenses.
Case 1:21-cr-00478-FB Document 6 Filed 09/23/21 Page 3 of 8 PageID #: 20

8. The PPP was overseen by the Small Business Administration (“SBA”),

which was headquartered in Washington, D.C., and had authority over all PPP loans. Individual

PPP loans, however, were issued by approved private lenders such as participating financial

institutions and credit unions (the “Lenders”). The Lenders received and processed PPP

applications and supporting documentation and made loans using the Lenders’ own funds.

9. Upon approval of a PPP loan application, the Lender funded the PPP loan,

which was 100 percent guaranteed by the SBA. Data from the PPP loan application, including

information about the borrower, the total amount of the loan and the listed number of employees,

was transmitted by the Lender to the SBA in the course of processing the loan.

10. PPP loan proceeds were permitted to be used by a borrower on specified

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

interest and principal on a PPP loan to be entirely forgiven if the borrower spent the loan proceeds

on the enumerated expenses within a designated period of time and used a certain amount of the

PPP loan proceeds on payroll expenses.

III. The Fraudulent Scheme

A. Overview

11. Following the enactment of the CARES Act, the defendant HASHIM

CAMPBELL and the Bank 1 Co-Conspirators, together with others, orchestrated a scheme to

submit fraudulent PPP loan applications on behalf of Bank 1 customers who did not legitimately

qualify for loans under the PPP program in exchange for “commissions” taken from the loan

proceeds.

12. The defendant HASHIM CAMPBELL and the Bank 1 Co-Conspirators,

together with others, submitted and caused to be submitted to Bank 1 on behalf of borrowers
Case 1:21-cr-00478-FB Document 6 Filed 09/23/21 Page 4 of 8 PageID #: 21

numerous PPP loan applications that contained materially false representations. CAMPBELL and

the Bank 1 Co-Conspirators also obtained falsified tax documents, which were provided as support

for the fraudulent PPP loan applications. Some of the PPP applicants resided in Brooklyn, New

York and withdrew their fraudulent PPP loan proceeds at ATM locations in the Eastern District of

New York. In addition, CAMPBELL and the Bank 1 Co-Conspirators obtained fraudulent PPP

loans for CAMPBELL’s family members and friends.

B. The Fraudulent PPP Loans

13. The Bank 1 Co-Conspirators worked with a network of recruiters to identify

borrowers to fraudulently apply for PPP loans. The borrowers identified by the recruiters were

either existing Bank 1 customers or became Bank 1 customers after they were recruited. In

exchange for their assistance, the Bank 1 Co-Conspirators gave the recruiters “commissions” from

the PPP loan proceeds. The Bank 1 Co-Conspirators enlisted two tax preparers, including the

defendant HASHIM CAMPBELL, to aid applicants and the Bank 1 Co-Conspirators in the

preparation of the fraudulent PPP loan applications and to falsify tax documents submitted with

those applications.

14. Under PPP loan program rules, borrowers generally were eligible to receive

loans of up to 2.5 times their businesses’ average monthly payroll. The defendant HASHIM

CAMPBELL worked with the Bank 1 Co-Conspirators to maximize the loan amount for each

borrower whose business loan documents he helped prepare, including by providing false

documents in support of the PPP applications. CAMPBELL provided borrowers with false

Internal Revenue Service (“IRS”) Form W-2s (reporting wages paid to employees) prepared by his

tax preparation businesses, Expert Tax and Apex, to support the fraudulent PPP loan applications.

CAMPBELL also helped borrowers inflate financial figures in the PPP loan applications. In
Case 1:21-cr-00478-FB Document 6 Filed 09/23/21 Page 5 of 8 PageID #: 22

exchange for helping applicants submit the fraudulent PPP loan applications, CAMPBELL

charged his customers a ten percent fee from the loan proceeds.

15. For example, in or about and between March 2020 and August 2020, the

defendant HASHIM CAMPBELL assisted Individual-1, an individual whose identity is known to

the United States, and other borrowers Individual-1 referred to CAMPBELL, in submitting

fraudulent applications for PPP loans. Specifically, CAMPBELL created fraudulent income tax

returns for Individual-1 and the referred borrowers. Individual-1 and the referred borrowers

submitted the fraudulent tax documents along with their PPP applications and obtained PPP loans

to which they were not entitled.

16. In or about and between March 2020 and August 2020, the defendant

HASHIM CAMPBELL assisted several family members and friends in submitting fraudulent

applications for PPP loans. CAMPBELL also created fraudulent income tax returns for his family

members and friends, which they submitted with their PPP applications to obtain fraudulent loans.

With CAMPBELL’s assistance, his family and friends obtain approximately $200,000 in

fraudulent PPP loans.

17. In total, in or about and between March 2020 and August 2020, the

defendant HASHIM CAMPBELL, together with others, fraudulently obtained PPP loans for New

York-based businesses in an amount exceeding one million dollars. These loans were fully

funded based on fraudulent information provided in the PPP loan applications. CAMPBELL

personally obtained nearly $100,000 in “commissions” from the PPP loan proceeds. CAMPBELL

was ineligible to receive any commissions from the PPP loan proceeds per the terms of the

program.
Case 1:21-cr-00478-FB Document 6 Filed 09/23/21 Page 6 of 8 PageID #: 23

CONSPIRACY TO COMMIT WIRE FRAUD AND BANK FRAUD

18. The allegations contained in paragraphs one through 17 are realleged and

incorporated as if fully set forth in this paragraph.

19. In or about and between March 2020 and August 2020, both dates being

approximate and inclusive, within the Eastern District of New York and elsewhere, the defendant

HASHIM CAMPBELL, together with others, did knowingly and intentionally conspire to execute

a scheme and artifice, to wit:

(a) to defraud and to obtain money and property from Bank 1 and the

SBA by means of one or more materially false and fraudulent pretenses, representations and

promises, and to transmit and cause to be transmitted by means of wire communications in

interstate commerce, writings, signs, signals, pictures and sounds, for the purpose of executing the

scheme to defraud, contrary to Title 18, United States Code, Section 1343; and

(b) to defraud Bank 1, a financial institution, and to obtain money,

funds, credits and other property owned by and under the custody and control of Bank 1, by means

of one or more materially false and fraudulent pretenses, representations and promises, contrary to

Title 18, United States Code, Section 1344.

(Title 18, United States Code, Sections 1349 and 3551 et seq.)

CRIMINAL FORFEITURE ALLEGATION

20. The United States hereby gives notice to the defendant that, upon his

conviction of the offense charged herein, the government will seek forfeiture in accordance with

Title 18, United States Code, Section 982(a)(2), which requires any person convicted of such

offense to forfeit any property constituting, or derived from, proceeds obtained directly or

indirectly as a result of such offense.
Case 1:21-cr-00478-FB Document 6 Filed 09/23/21 Page 7 of 8 PageID #: 24

21. If any of the above-described forfeitable property, 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;

(d) has been substantially diminished in value; or

(e) has been commingled with other property which cannot be divided

without difficulty;

it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), as

incorporated by Title 18, United States Code, Section 982(b)(1), to seek forfeiture of any other

property of the defendant up to the value of the forfeitable property described in this forfeiture

allegation.

(Title 18, United States Code, Sections 982(a)(2) and 982(b)(1); Title 21, United

States Code, Section 853(p))

__________________________________
JACQUELYN M. KASULIS
ACTING UNITED STATES ATTORNEY
EASTERN DISTRICT OF NEW YORK

____________________________________
JOSEPH S. BEEMSTERBOER
ACTING CHIEF
CRIMINAL DIVISION, FRAUD SECTION
U.S. DEPARTMENT OF JUSTICE
Case 1:21-cr-00478-FB Document 6 Filed 09/23/21 Page 8 of 8 PageID #: 25

F.#: 2020R00955
FORM DBD-34 No.
JUN. 85
UNITED STATES DISTRICT COURT

EASTERN District of NEW YORK

CRIMINAL DIVISION

THE UNITED STATES OF AMERICA

vs.

HASHIM CAMPBEEL,

Defendant.
INFORMATION
(T. 18, U.S.C., §§ 982(a)(2), 982(b)(1), 1349 and 3551 et seq.; T. 21, U.S.C., §
853(p))
A true bill.
________________________________________
Foreperson

Filed in open court this _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ day,

of _ _ _ _ _ _ _ _ _ _ _ _ A.D. 20 _ _ _ _ _
_______________________________________
Clerk

Bail, $ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Julia Nestor and Chand Edwards-Balfour, Assistant U.S. Attorneys
(718) 254-6297/6238
Michael McCarthy, Trial Attorney (202) 305-3995

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