Criminal Information — United States v. Ibraheem Sabri Samirah (E.D. Va., Document 5, July 21, 2025)
Summary
A Criminal Information in United States of America v. Ibraheem Sabri Samirah, Case 1:25-cr-00210-MSN, in the U.S. District Court for the Eastern District of Virginia, Alexandria Division, filed July 21, 2025 as Document 5. Count 1 charges wire fraud under 18 U.S.C. § 1343 against Sonabank and the SBA from in or about May 2020 to on or about August 2021. It alleges that on or about May 12, 2020 the defendant obtained a PPP loan of approximately $83,300 for Nova Healthy Smiles PLLC by falsely representing four employees and an average monthly payroll of $33,333.32, supported by payroll records for January and February 2020 that were not run until May 2020. It alleges the forgiveness application falsely stated the proceeds were spent on permissible expenses. The information includes a forfeiture notice.
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“Criminal Information — United States v. Ibraheem Sabri Samirah (E.D. Va., Document 5, July 21, 2025).”
Original at ecf.vaed.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/criminal-information-usa-v-samirah-dkt-5-e-d-va-20a4239f06/
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Case 1:25-cr-00210-MSN Document 5 Filed 07/21/25 Page 1 of 8 PageID# 8
FILED
IN OPEN COURT
JUL2 I
IN THE UNITED STATES DISTRICT COURT FOR THf CLERK, U S. DISTRICT COURT
ALEXANDRIA. VIRGINIA
EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES OF AMERICA Case No. l:25-cr-210
V. Count 1: 18U.S.C. § 1343
(Wire Fraud)
IBRAHEEM SABRI SAMIRAH
Defendant. Forfeiture Notice
INFORMATION
THE UNITED STATES CHARGES THAT:
INTRODUCTORY ALLEGATIONS
At all times relevant to the information, unless otherwise stated:
Defendant IBRAHEEM SABRI SAMIRAH (hereafter “SAMIRAH”) resided in
Herndon, Virginia, which was within the Eastern District of Virginia.
2. On September 30, 2019, Nova Healthy Smiles PLLC (NHS) was formed in the
Commonwealth of Virginia, with the principal office address in Herndon, Virginia—the address
for SAMIRAFI’s residence at the time. In September 2020, NHS’s address was updated to
Samirah’s new residential address in Herndon, Virginia.
3. Sonabank, later renamed Primis Bank, provided a range of traditional banking
services throughout the United States, including in the Eastern District of Virginia, and was a
financial institution as defined by Title 18, United States Code, Section 20. Sonabank was
headquartered in Glen Allen, Virginia.
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The CARES Act and PPP
4. The Small Business Administration (“SBA”) was an executive branch agency of
the United States government that provided support to entrepreneurs and small businesses. The
mission of the SBA was to maintain and strengthen the nation’s economy by enabling the
establishment and viability of small businesses and by assisting in the economic recovery of
communities after disasters.
5. In or around March 2020, Congress made government-guaranteed loans available
to qualified small businesses through the Paycheck Protection Program (“PPP”). The purpose of
loans issued under the PPP was to enable small businesses suffering from the economic downturn
to continue to pay salary or wages to their employees. To qualify for a loan under the PPP, an
applicant had to meet certain criteria, including, among other things, that it was in operation on
February 15, 2020, and either had employees for whom it paid salaries and payroll taxes or paid
independent contractors, as reported on an IRS Form 1099-MISC. Moreover, the amount of the
loan that could be approved under the PPP and implementing regulations typically was a function
of the applicant’s historical payroll costs.
6. Small businesses applied for PPP loans with private lenders, including financial
institutions such as Sonabank, that had been approved to participate in the program by the SBA.
As such, Sonabank was authorized to lend funds to eligible borrowers under the terms of the PPP.
The lenders, including Sonabank, used their own funds to make the PPP loans, but the loans were
guaranteed 100 percent by the SBA.
7. In order to obtain a PPP loan, a qualifying business was required to submit a PPP
loan application, which was signed by an authorized representative of the business, to a
participating financial institution. The PPP loan application required the business (through its
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authorized representative) to acknowledge the program rules and make certain affirmative
certifications. In the PPP loan application, the small business (through its authorized
representative) had to state, among other things, its: (a) average monthly payroll expenses; and (b)
number of employees. These figures were used by the lender to calculate the amount of money the
small business was eligible to receive under the PPP. In addition, businesses applying for a PPP
loan had to provide documentation showing their payroll expenses. The supporting documentation
often included bank account records and IRS Forms, including the IRS Schedule C (Form 1040),
Profit or Loss Form Business, which reports a sole proprietorship’s income and expenses. The
applicant also needed to certify that the business was in operation as of February 15, 2020, that the
PPP loan would be used to pay payroll, mortgage payments, lease payments, and utility payments
as required by the PPP rules, and that all information in the application supporting document was
true and accurate. The lenders relied on the accuracy of the information contained in the PPP
applications and supporting documents.
8. The proceeds of a PPP loan could be used only for certain specified items, such as
payroll costs, costs related to the continuation of group health care benefits, mortgage interest
payments (but not mortgage prepayments or principal payments), rent payments, utility payments,
interest payments on debt obligations that were incurred before February 15, 2020, or for
refinancing certain specified SBA loans.
9. The PPP allowed the interest and principal on the PPP loans to be entirely forgiven
if the business spent the loan proceeds on these expense items within a designated period of time
and used a certain percentage of the PPP loan proceeds on payroll expenses. To receive PPP loan
forgiveness, a qualifying business was required to submit a PPP loan forgiveness application,
which was signed by an authorized representative of the business, to its PPP lender. In the PPP
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loan forgiveness application, the borrower (through its authorized representative) had to certify,
among other things, that it complied with all the requirements in the PPP rules, including the rules
related to eligible uses of PPP loan proceeds, and that the information provided in the application
was true and correct in alt material respects. The lenders relied on the accuracy of the information
contained in the PPP forgiveness applications and supporting documents.
10. The SBA received PPP forgiveness applications from PPP lenders through a cloud-
based platform, known as Summit, through an Amazon Web Services GovCloud server located in
Oregon. The SBA transmits the forgiveness payments from the SBA to the PPP lender through the
FMS system to the Treasury. The primary server for FMS is in Sterling, VA.
COUNT ONE
(Wire Fraud)
11. The allegations contained paragraphs 1 through 12 of this Indictment are realleged
and incorporated by reference as if set forth fully herein.
12. From in or about May 2020 to on or about August 2021, in the Eastern District of
Virginia and elsewhere, the defendant,
IBRAHEEM SAMIRAH
having knowingly devised and intending to devise a scheme and artifice to defraud Sonabank
and the SBA, and to obtain money and property from them by means of materially false and
fraudulent pretenses, representations, and promises, to transmit and cause to be transmitted by
means of wire communication in interstate commerce writings, signs, signals, pictures, and
sounds for the purpose of executing such scheme and artifice.
Purpose and Objects of the Scheme and Artiifce to Defraud
13. It was a purpose and object of the scheme and artifice to defraud for SAMIRAH to
unlawfully enrich himself by, among other things: (a) submitting and causing the submission of
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false and fraudulent PPP loan application to Sonabank; (b) obtaining money or property - that is,
PPP loan proceeds of Sonabank and the SBA; (c) falsely promising to use the loan proceeds on
permitted business expenses under the PPP; and (d) concealing and causing the concealment of
the scheme.
Wavs, Manner, and Means of the Scheme and Artiifce to Defimid
14. On or about May 12, 2020, SAMIRAH applied for and was approved for a PPP
loan of approximately $83,300 from Sonabank. The loan was for NHS, located in Herndon,
Virginia.
15. In support of the loan, SAMIRAH submitted a signed “Borrower Application
Form” (SBA Form 2483). On the form, SAMIRAH falsely represented that NHS had four
employees and an average monthly payroll of $33,333.32. SAMIRAH further represented that the
purpose of the loan was for payroll, lease/mortgage interest, and utilities.
16. On the Borrower Application Form, SAMIRAH falsely agreed to several
certifications.
17. SAMIRAH falsely certified that NHS “had employees for whom it paid salaries and
payroll taxes or paid independent contractors, as reported on Form(s) 1099-MISC. He further
falsely certified that “[t]he funds w[ould] be used to retain workers and maintain payroll or make
mortgage interest payments, lease payments, and utility payments, as speeified under the Paycheck
Protection Program Rule.” Finally, SAMIRAH certified “that the information provided in th[e]
application and the information provided in all supporting documents and forms is true and
accurate in all material respects.'
18. SAMIRAH submitted supporting documents with the PPP loan application.
including W-4 forms (Employee’s Withholding Certificate), Payroll Journals, and Paychex payroll
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reports for January and February 2020. These documents listed four employees of NHS:
SAMIRAH, Employee 1, Employee 2, and Employee 3. The Payroll Journals and Paychex payroll
reports stated that NHS paid each of the purported employees $8,333.33 per month in January and
February 2020 (of which they each received a net monthly paycheck for $7,695.83), resulting in
total salary payments of $33,333.32 for each month.
19. SAMIRAH falsely represented that NHS paid four purported employees’ payroll in
January 2020 and February 2020, when in truth and fact, NHS did not run payroll journals forthose
periods until May 2020. None of the four purported employees received funds from NHS prior to
May 2020.
20. SAMIRAH wrote checks to NHS’ purported employees from NFIS’s business
account in May and June 2020. Although these checks appeared to represent the purported
employees’ salary payments, the purported employees transferred the money back to SAMIRAH.
21. On or about August 16,2021, SAMIRAH electronically signed and transmitted the
PPP forgiveness application for NHS to Sonabank. Sonabank then submitted the PPP forgiveness
application to the SBA’s cloud-based platform, Summit, via a cloud server located in Oregon.
22. The NHS PPP forgiveness application falsely represented the material fact that
NHS had spent all of the PPP loan proceeds on permissible business expenses, when in truth and in
fact, as the defendant well knew then, the NHS had not spent the PPP loan proceeds on permissible
business expenses, with the exception of employer payroll taxes that were remitted to the Internal
Revenue Service.
Wires in Furtherance
23. On or about August 16,2021, within the Eastern District of Virginia and elsewhere.
the defendant, for the purpose of executing the scheme and artifice to defraud, and to aid and abet
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the same, transmitted and caused to be transmitted by means of wire communications in interstate
commerce writings, signs, signals and sounds by means of wire communications in interstate
commerce, to wit: the defendant caused the electronic transmission of the PPP loan forgiveness
application for NHS from Eastern District of Virginia to the State of Oregon, falsely representing
the material fact that NHS had spent the PPP loan proceeds on permissible expenses, when in truth
and in fact, as the defendant well knew then, NHS had not spent the PPP loan proceeds on
permissible business expenses.
(All in violation of Title 18, United States Code, Sections 1343 and 2.)
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FORFEITURE NOTICE
Pursuant to Federal Rule of Criminal Procedure 32.2(a), defendant IBRAHEEM SABRI
SAMIRAH is hereby notified that upon conviction of the offense alleged in Count 1 (wire fraud)
of the Criminal Information, IBRAHEEM SABRI SAMIRAH shall forfeit to the United States,
pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461, any property constituting, or derived
from, proceeds the defendant obtained directly or indirectly, as the result of the violation.
Pursuant to Federal Rule of Criminal Procedure 32.2(a), defendant IBRAHEEM SABRI
SAMIRAH is hereby notified that upon conviction of the offense alleged in Count 1 of the Criminal
Information, IBRAHEEM SABRI SAMIRAH shall forfeit to the United States, pursuant to 18
U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c), any property, real or personal, constituting or
derived from proceeds traceable to the offense.
Pursuant to 21 U.S.C. § 853(p), IBIU^HEEM SABRI SAMIRAH shall forfeit substitute
property, if, by any act or omission of IBRAHEEM SABRI SAMIRAH, the property
referenced above cannot be located upon the exercise of due diligence; has been transferred, sold
to, or deposited with a third party; has been placed beyond the jurisdiction of the Court; has been
substantially diminished in value; or has been commingled with other property which cannot be
divided without difficulty.
(In accordance with Title 18, United States Code, Section 981(a)(1)(C); Title 21 United
States Code, Section 853(p); Title 28 United States Code, Section 2461(c); and Rule 32.2(a),
Federal Rules of Criminal Procedure.)
ERIKS. SIEBERT
UNITED STATES ATTORNEY
Kathleen E. Robeson
Assistant United States Attorney
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