Criminal Complaint — United States v. Michael Blanc, Mag. No. 22-11232 (AME) (D.N.J.)
Summary
This criminal complaint in the District of New Jersey, Mag. No. 22-11232 (AME), charges Michael Blanc with wire fraud under Title 18, United States Code, Section 1343, for conduct from about March 2020 through December 2020 that included a wire communication sent on or about May 2, 2020. Special Agent Nicholas Tysk of the Department of Labor-OIG attested to it on the 23rd day of August, 2022. The affidavit states that an IP address ending in 182 was associated with approximately 400 unemployment insurance claims to 5 states, including New Jersey, and that those states paid out approximately $960,000. It states that a bank account ending in 5390 in Blanc's name received approximately $65,000 from an EIDL in the name of Victim-1, and that the IP address used for that application is connected to approximately 67 additional EIDL applications.
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UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
UNITED STATES OF AMERICA Hon. Andre M. Espinosa
v. Mag. No. 22-11232 (AME)
MICHAEL BLANC CRIMINAL COMPLAINT
I, Nicholas Tysk, being duly sworn, state the following is true and correct
to the best of my knowledge and belief:
SEE ATTACHMENT A
I further state that I am a Special Agent with the United States
Department of Labor-Office of Inspector General ("OIG"), and that this
complaint is based on the following facts:
SEE ATTACHMENT B
continued on the attached page and made a part hereof.
Nicholas Ty , Special Agent
Departmen of Labor-OIG
Special Agent Tysk attested to this Complaint by telephone pursuant to FRCP
4. l(b)(2)(A), on the 23rd day of August, 2022.
HONORABLE ANDRE M. ESPINOSA
UNITED STATES MAGISTRATE JUDGE
-,t ()..J.;: E5fJnor~ h-f
Signature of Judicial Officer /
Signed by SA Tysk at Judge Espinosa's direction pursuant to F.R.C.P.
4. l(b)(6)(C).
ATTACHMENT A
From in or around March 2020 through in or around December 2020, in
Mercer County, in the District of New Jersey and elsewhere, defendant
MICHAEL BLANC
did devise and intend to 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, for the purpose of executing and attempting
to execute such scheme and artifice to defraud, did transmit and cause to be
transmitted by means of wire communications in interstate and foreign
commerce, certain writings, signs, signals, pictures, and sounds, including a
wire communication sent on or about May 2, 2020, from a location outside of
New Jersey to a location in New Jersey.
In violation of Title 18, United States Code, Section 1343.
ATTACHMENT B
I, Nicholas Tysk, am a Special Agent with the United States Department
of Labor-OIG. I am familiar with the facts set forth herein based on my own
investigation, my conversations with other law enforcement officers, and my
review of reports, documents, and other evidence. Because this Complaint is
being submitted for a limited purpose, I have not set forth each and every fact
that I know concerning this investigation. Where statements of others are
related herein, they are related in substance and in part unless otherwise
indicated. Where I assert that an event took place on a particular date, I am
asserting that it took place on or about the date alleged.
I. Background Information
A. Unemployment Insurance Benefits
1. On March 18, 2020, the Families First Coronavirus Response Act
("FFCRA") was signed into law. The FFCRA provided additional flexibility for
state Unemployment Insurance ("UI") agencies and additional administrative
funding to respond to the COVID-19 pandemic. Then, the Coronavirus Aid,
Relief, and Economic Security ("CARES") Act was signed into law on March 27,
2020. It expanded states' ability to provide assistance to many workers
impacted by COVID-19, including for workers who are not ordinarily eligible for
UI benefits ("UIBs"). The CARES Act provided for three new temporary UI
programs: Pandemic Unemployment Assistance ("PUA"); Pandemic Emergency
Unemployment Compensation ("PEUC"); and Federal Pandemic Unemployment
Compensation ("FPUC").
2. On August 8, 2020, after FPUC expired, a Presidential
Memorandum authorized the Federal Emergency Management Agency
("FEMA'') to use disaster relief funds pursuant to Section 408, Other Needs
Assistance, of the Robert T. Stafford Disaster Relief and Emergency Assistance
Act, 42 U.S.C. §§ 5121-5207, to provide supplemental payments for lost wages
to help ease the financial burden on individuals who were unemployed as a
result of COVID-19. The Lost Wages Assistance Program ("LWA") served as a
temporary measure, if a State Workforce Agency ("SWA") chose to administer it,
to provide an additional $300 per week via a total of approximately $42.5
billion in FEMA funds. The period of assistance for LWA was August 1, 2020 to
December 27, 2020, or termination of the program, whichever was sooner.
3. Regardless of which of the three programs described above was
involved (that is, whether PUA, PEUC, or FPUC), funds were distributed to
program participants by the SWA. The SWA received these funds from the
United States Department of the Treasury ("Treasury'').
4. The New Jersey Department of Labor and Workforce Development
("DLWD"), Division of Unemployment Insurance, administers and manages the
regular and other UIB programs for the State of New Jersey. The DLWD offers
an online portal (the "Portal") through which applicants can apply for UIBs and
other benefits. The servers that host the Portal are located in New Jersey.
B. The Defendant
5. Defendant Michael Blanc was a resident of Miami-Dade County,
Florida.
C. The Investigation
6. Between in or around March 2020 and in or around December
2020, the Internet Protocol Address ("IP Address") ending in "182" (the "182 IP
Address") was associated with approximately 400 claims for UIBs that were
made to 5 states, including approximately 144,claims to the State of New
Jersey.
7. The approximately 5 States paid out approximately $960,000 in
response to these claims.
8. Law enforcement interviewed 4 individuals in whose names UIB
claims associated with the 182 IP Address were made to the State of New
Jersey. Each individual stated, in substance and in part, that: (a) s/he did not
make a claim for UIBs to the State of New Jersey; (b) s/he did not authorize
anyone else to make such a claim; and (c) s/he did not know Michael Blanc.
9. One of the approximately 400 claims directed that the UIBs be
deposited into a PayPal account ending in 5082 (the "5082 PayPal Account").
The 5082 account is in the name of Blanc's wife.
10. PayPal records also show that the 5082 PayPal Account received
approximately $28,000 in UIBs from Florida, Texas, and California in response
to UIB claims separate and apart from those described in paragraph 6 of this
Complaint.
11. During the timeframe of the offense, the 182 IP Address was used
to log into, among other accounts: (a) a bank account ending in 5390 in Blanc's
name (the "5390 Bank Account"); (b) a Green Dot account in Blanc's name, (c)
a Square account in Blanc's name; and (d) an AOL account in Blanc's name.
12. The 5390 Bank Account was used in relation to numerous UIB
claims in 2020 separate and apart from those set forth in paragraphs 6 and 9
of this Complaint. Specifically, the Bank Account was used in connection with
approximately: (a) 87 UIB claims to Rhode Island, approximately 15 of which
were paid for a total of approximately $31,000; (b) 10 UIB claims to Arizona,
approximately 1 of which was paid for a total of approximately $7,500; and (c)
21 UIB claims to Massachusetts, none of which were paid.
13. Law enforcement interviewed 4 individuals in whose names UIB
claims associated with the 5390 Bank Account were made. Each individual
stated, in substance and in part, that: (a) s/he did not make a claim for UIBs;
(b) s/he did not authorize anyone else to make such a claim; and (c) s/he did
not know Michael Blanc.
14. The CARES Act also enabled the Small Business Association
("SBA") to offer funding through the COVID-19 Economic Injury Disaster Loans
("EIDL") program to business owners negatively affected by the COVID-19
pandemic. On or about July 2, 2020, the 5390 Bank Account received
approximately $65,000 in response to an EIDL in the name ofVictim-1. A
family member of Victim-1 told law enforcement, in substance and in part, that
Victim-1 could not have filed an application for the loan as he previously
suffered a debilitating stroke. The IP address used to file the EIDL application
is also connected to approximately 67 additional EIDL Applications. A total of
approximately $250,000 has been provided in response to these applications.
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