Information — United States v. Raheel Malik (Southern District of Texas, Document 1, November 3, 2021)
Summary
Information, Document 1 filed on 11/03/21 in the Southern District of Texas, Houston Division, Criminal No. 4:21-cr-530, against Raheel Malik, a resident of Sugarland, Texas, and a manager of Fascare International, Inc., doing business as Almeda Discount Store. Count One charges conspiracy, beginning in or around April 2020 and continuing until in or around October 2020. It alleges that on or about July 7, 2020, Malik and Amir Aqeel exchanged text messages with an image showing the PPP loan for Texas Lonestar Investments Group, Inc. had been approved in the approximate amount of $614,724. It also alleges that on or about July 13, 2020, Malik cashed a Grandeur Construction check payable to Mauricio Navia in the approximate amount of $1,623. A notice of criminal forfeiture follows.
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Case 4:21-cr-00530 Document 1 Filed on 11/03/21 in TXSD Page 1 of 7
United States Courts
Southern District of Texas
&/>ED
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF TEXAS November 03, 2021
HOUSTON DIVISION EaƚŚĂŶKĐŚƐŶĞƌ, Clerk ofCourt
UNITED STATES OF AMERICA §
§
v. § Criminal No. 4:21-cr-530
§
RAHEEL MALIK, §
§
Defendant. §
INFORMATION
THE UNITED STATES CHARGES:
GENERAL ALLEGATIONS
At all times material to this Information:
The Paycheck Protection Program
1. 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
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”).
2. In order to obtain a PPP loan, a qualifying business submitted a PPP loan application,
which was 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
make certain affirmative certifications in order to be eligible to obtain the PPP loan. In the PPP
loan application (Small Business Administration (“SBA”) Form 2483), the small business (through
its authorized representative) was required to provide, among other things, its: (a) average monthly
Case 4:21-cr-00530 Document 1 Filed on 11/03/21 in TXSD Page 2 of 7
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 confirming their payroll expenses.
3. A PPP loan application was processed by a participating lender. If a PPP loan
application was approved, the participating lender funded the PPP loan using its own monies.
While it was the participating lender that issued the PPP loan, the loan was 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 by the lender to the SBA in the
course of processing the loan.
4. 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 Defendant, Related Entities and Individuals
5. Defendant RAHEEL MALIK (“MALIK”) was a resident of Sugarland, Texas
and was a manager of Fascare International, Inc., doing business as, Almeda Discount Store
(“Almeda”).
6. Almeda was a store located in Houston, Texas that sold a variety of items and
offered cash checking services.
7. Siddiq Azeemuddin (“Azeemuddin”) was a resident of Naperville, Illinois, the
owner of Almeda, and MALIK’s boss.
8. Amir Aqeel (“Aqeel”) was a resident of Houston, Texas, a friend of Azeemuddin’s,
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Case 4:21-cr-00530 Document 1 Filed on 11/03/21 in TXSD Page 3 of 7
and a customer of Almeda.
9. Mauricio Navia (“Navia”) was a resident of Katy, Texas.
10. CC-1 was a resident of Houston, Texas.
11. Grandeur Construction, LLC (“Grandeur Construction”) was a Texas Limited
Liability Company that was registered to Navia.
12. Texas Lonestar Investments Group, Inc. (“Lonestar Investments”) was a Texas
corporation that was registered to MALIK’s relative.
COUNT ONE
(18 U.S.C. § 371 - Conspiracy)
13. Paragraphs 1 through 12 of this Information are re-alleged and incorporated by
reference as though fully set forth herein.
14. Beginning in or around April 2020, and continuing until in or around October 2020,
in the Houston Division of the Southern District of Texas, and elsewhere, the defendant,
RAHEEL MALIK
knowingly and willfully, that is, with the intent to further the objects of the conspiracy, conspired
and agreed with Amir Aqeel, Siddiq Azeemuddin, Mauricio Navia, CC-1, and other individuals,
known and unknown, to commit certain offenses against the United States, namely:
a) to knowingly and intentionally 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 to transmit and cause to be
transmitted, by means of wire communication in interstate and foreign
commerce, writings, signs, signals, pictures, and sounds for the purpose of
executing such scheme and artifice to defraud, in violation of Title 18, United
States Code, Section 1343; and
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Case 4:21-cr-00530 Document 1 Filed on 11/03/21 in TXSD Page 4 of 7
b) to knowingly conduct and attempt to conduct a financial transaction affecting
interstate and foreign commerce, which financial transaction involved the proceeds
of specified unlawful activity, that is, wire fraud, knowing that the property
involved in the financial transaction represented the proceeds of some form of
unlawful activity, and knowing that the transaction was designed, in whole and in
part, to conceal and disguise the nature, the location, the source, the ownership, and
the control of the proceeds of specified unlawful activity, in violation of Title 18,
United States Code, Section 1956(a)(1)(B)(i).
PURPOSE OF THE CONSPIRACY
15. It was the purpose of the conspiracy for MALIK and his co-conspirators to
unlawfully enrich themselves by, among other things: (a) submitting and causing the submission
of false and fraudulent applications for PPP loans and (b) laundering the proceeds from the PPP
loans in order to conceal and disguise the true nature and source of the loan proceeds.
MANNER AND MEANS OF THE CONSPIRACY
16. The manner and means by which MALIK and his co-conspirators sought to
accomplish the objects and purpose of the conspiracy included, among others, the following:
17. MALIK, Aqeel, Azeemuddin, Navia, CC-1, and others submitted, and caused to
be submitted, false and fraudulent PPP loan applications in the name of certain entities to various
SBA-approved PPP lenders and companies. These applications contained false and fraudulent
representations as to the number of employees and the average monthly payroll. As a result of
these false and fraudulent applications, MALIK’s co-conspirators, including Aqeel, obtained
millions of dollars in fraudulent PPP loans.
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Case 4:21-cr-00530 Document 1 Filed on 11/03/21 in TXSD Page 5 of 7
18. As part of the scheme, Aqeel asked MALIK to refer other people to Aqeel who
wanted PPP loans. In return, Aqeel promised MALIK a referral fee. MALIK provided Aqeel
with information about Lonestar Investments, a business owned by MALIK’s relative. MALIK
allowed Aqeel to apply for a PPP loan on behalf of Lonestar Investments knowing that certain
representations made in the PPP loan application were false and fraudulent. The false and
fraudulent PPP loan application on behalf of Lonestar Investments was submitted via the use of
interstate wires to a participating SBA approved lender that authorized a PPP loan in the amount
of $614,725, which was later canceled.
19. As part of the scheme, MALIK, Aqeel, Azeemuddin, Navia, CC-1, and others
agreed to and did launder PPP loan funds that were obtained via the fraudulent PPP loan
applications through Almeda.
20. As part of the scheme, Aqeel and others provided blank checks to MALIK for some
of the businesses that had received fraudulent PPP loans. Aqeel and Azeemuddin instructed
MALIK to fill out the blank checks by putting the names of fake employees in the payee line.
MALIK then cashed the checks at one of two financial institutions. MALIK knew that these
paychecks were for fake employees both when MALIK was writing the names on the checks and
when MALIK was cashing the checks. MALIK then transported the cash generated from cashing
the fake paychecks to other members of the conspiracy, including, but not limited to, Aqeel, Navia,
and CC-1.
21. In total, MALIK and others cashed over one thousand fake paychecks received
from Aqeel and others and laundered approximately $3,147,007 in fraudulently obtained PPP loan
funds through Almeda on behalf of the conspiracy.
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OVERT ACTS
22. In furtherance of the conspiracy, and to accomplish its objects and purpose, at least
one of the co-conspirators committed and caused to be committed, in the Houston Division of the
Southern District of Texas and elsewhere, at least one of the following overt acts, among others:
23. On or about June 16, 2020, MALIK and Aqeel exchanged text messages in which
MALIK provided copies of various incorporation documents for Lonestar Investments.
24. On or about July 4, 2020, MALIK and Aqeel exchanged text messages in which
MALIK provided an image of an Excel document containing several names of fake employees
including, but limited to, Navia, CC-1, and one of Aqeel’s relatives.
25. On or about July 4, 2020, MALIK and Aqeel exchanged text messages in which
MALIK sent an image of an endorsed check from an account in the name of Grandeur
Construction, which was dated July 3, 2020, and in the approximate amount of $1,221.15. The
payee line was blank.
26. On or about July 7, 2020, MALIK and Aqeel exchanged text messages in which
MALIK sent an image from an SBA-approved PPP lender indicating that the PPP loan for
Lonestar Investments had been approved in the approximate amount of $614,724.
27. On or about July 13, 2020, MALIK cashed a check from Grandeur Construction
with the payee of Navia in the approximate amount of $1,623.
All in violation of Title 18, United States Code, Section 371.
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NOTICE OF CRIMINAL FORFEITURE
(18 U.S.C. § 981(a)(1)(C); 28 U.S.C. § 2461(c))
1. Pursuant to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United
States Code, Section 2461(c), the United States gives notice that upon the defendant’s conviction
of Count One of this Information, the United States will seek forfeiture of all property, real or
personal, which constitutes or is derived from proceeds traceable to the conspiracy.
2. The United States also gives notice that it will seek a money judgment against the
defendant.
3. In the event that one or more conditions listed in Title 21, United States Code,
Section 853(p) exist, the United States will seek to forfeit any other property of the defendant up
to the amount of the money judgment.
Jennifer Lowery Joseph S. Beemsterboer
Acting United States Attorney Acting Chief, Fraud Section
Southern District of Texas Criminal Division
U.S. Department of Justice
By: _________________________ _______________________
Rodolfo Ramirez Della Sentilles
ssistant United States Attorney
A i Louis Manzo
Southern District of Texas Trial Attorneys
RRamirez3@usa.doj.gov Criminal Division, Fraud Section
(713) 314-6024 Della.Sentilles@usdoj.gov
(202) 445-8793 (Sentilles)
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Case 4:21-cr-00530 Document 1-1 Filed on 11/03/21 in TXSD Page 1 of 1
AO 455 (Rev. 1/09) Waver of an Indictment
UNITED STATES DISTRICT COURT
for the
Southern DISTRICT OF Texas
United States of America )
V.
)
Case No: 4:21-cr-530
)
)
RAHEEL MALIK )
Memo for Alias: )
)
)
WAIVER OF INDICTMENT
I understand that I have been accused of one or more offenses punishable by imprisonment for more than
one year. I was advised in open court of my rights and the nature of the proposed charges against me.
After receiving this advice, I waive my right to prosecution by indictment and consent to prosecution
by information.
Date:
Defendant's signature
Signature of defendant's attorney
Printed name of defendant's attorney
Judge's signature
Judge's printed name and title
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