Government’s Sentencing Memorandum — United States v. Samer Kammo, No. 23-CR-20296 (Dkt. 95, E.D. Mich.)
Summary
In this sentencing memorandum filed February 5, 2026 in United States v. Samer Kammo, Criminal No. 23-CR-20296 (E.D. Mich.), the government asks the Court to sentence Kammo to 51 months' imprisonment, within an advisory guideline range of 46-57 months. Kammo pleaded guilty on August 26, 2025 to conspiring to commit wire and bank fraud under a Rule 11 plea agreement. The memorandum says Kammo worked with Christina Anasi, Kammo's wife, and co-conspirator Rita Shaba to obtain six fraudulent PPP loans, for entities including Wireless Plus and D&H Market, totaling $2,493,348.50, and misused the identities of family members and a third-party tax preparer. It cites prior convictions, including a 36-month federal sentence for controlled substance activity, and asks for restitution to the Small Business Administration of $2,493,348.50.
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Case 2:23-cr-20296-JJCG-APP ECF No. 95, PageID.699 Filed 02/05/26 Page 1 of 10
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff, CRIMINAL NO. 23-CR-20296
v. HONORABLE JONATHAN J.C. GREY
D-2 SAMER KAMMO,
Defendant.
/
Government’s Sentencing Memorandum
After amassing several prior convictions, Samer Kammo decided to exploit a
global pandemic to fraudulently enrich himself and his family members. Kammo
worked with his wife, Christina Anasi, and their co-conspirator, Rita Shaba, to obtain
over $2 million of fraudulent PPP funds. In committing his fraud, Kammo did not
hesitate to misuse the identities of other family members to obtain fraudulent loans
in their names. Kammo and his wife then used those loan proceeds for their own,
impermissible purposes.
Kammo’s sentencing guideline range is 46-57 months’ imprisonment. For
the reasons stated in this memorandum, the Court should sentence Kammo to a 51-
month term of imprisonment.
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I. Facts and Procedural History
On May 24, 2023, Kammo was charged with one count of conspiring to
commit wire fraud and bank fraud; one count of conspiring to make a false statement
in connection with a bank loan; three counts of wire fraud; two counts of bank fraud;
two counts of making a false statement in connection with a bank loan; and three
counts of aggravated identity theft. On August 26, 2025, Kammo entered a guilty
plea to conspiring to commit wire and bank fraud pursuant to a Rule 11 plea
agreement. (ECF No. 67.) As part of that plea agreement, the government agreed to
move to dismiss the remaining charges against Kammo.
In their plea agreement, the parties jointly recommended that the Court apply
sentencing enhancements for an actual loss of $1.5-$3.5 million and the use of
sophisticated means. (ECF No. 67, PageID.430.) The parties also recommended that
the Court provide Kammo with credit for acceptance of responsibility. (PageID.428-
29.) The Probation Department found the same guideline enhancements and
reductions, determined a total offense level of 22, a criminal history category of II,
and an advisory guideline range of 46-57 months’ imprisonment. (PSR ¶¶ 39-47,
80.)
II. Section 3553(a) Factors
The Supreme Court has noted that, in formulating the Sentencing Guidelines,
the U.S. Sentencing Commission’s goal is to carry out the objectives of 18 U.S.C. §
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3553(a). United States v. Rita, 551 U.S. 338 (2007). While advisory, the Guidelines
remain an important factor in fashioning a just sentence. This is because “it is fair to
assume that the Guidelines, insofar as practicable, reflect a rough approximation of
sentences that might achieve section 3553(a)’s objectives.” Id. at 350. Moreover, the
Guidelines “should be the starting point and the initial benchmark” for choosing a
defendant’s sentence. Gall v. United States, 552 U.S. 38, 49 (2007).
Here, the starting point is 46-57 months’ imprisonment.
The guideline range in this case is particularly important because, as the Sixth
Circuit has noted, “[o]ne of the central reasons for creating the sentencing guidelines
was to ensure stiffer penalties for white-collar crimes and to eliminate disparities
between white-collar sentences and sentences for other crime.” United States v.
Davis, 537 F.3d 611, 617 (6th Cir. 2008) (citations omitted). Specifically, Congress
was concerned that, prior to enactment of the Sentencing Guidelines, “[m]ajor white
collar criminals often [were] sentenced to small fines and little or no imprisonment.
Unfortunately, this creates the impression that certain offenses are punishable only
by a small fine that can be written off as a cost of doing business.” S. REP. 98-225,
76, 1984 U.S.C.C.A.N. 3182, 3259,
a. The Nature and Circumstances of the Offense
Pandemic assistance fraud was a massive problem within our local
community and nationwide. Estimates indicate that more than $200 billion in
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potentially fraudulent pandemic assistance loans were disbursed. COVID-19
Pandemic EIDL and PPP Loan Fraud Landscape, U.S. Small Business
Administration (June 27, 2023), https://www.sba.gov/document/report-23-09-
covid-19-pandemic-eidl-ppp-loan-fraud-landscape
Notably, Kammo’s crime was not a one-time lapse in judgment. It was a crime
completed time after time, with each falsified document and each fraudulent loan
application. Kammo repeatedly made the decision to steal.
Kammo is responsible for securing at least six fraudulent loans as part of his
conspiratorial conduct: Wireless Plus, D&H Market, Different Flavors 14355, C&S
Liquor, W Shallal, and JD Hydro. (PSR ¶¶ 15-35.):
PPP Entity (Loan Number) Principal Obtained
Wireless Plus (1788467808) $557,807.00
W Shallal (2861767904) $388,542.00
JD Hydro (2859458009) $386,667.50
D&H Market (5222247408) $564,032.00
Different Flavors (9434978106) $520,800.00
C&S Liquor (4559707307) $75,500.00
Total $ 2,493,348.50
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In committing their crime, the conspirators misappropriated the identities of
Kammo’s mother’s, his wife’s uncle, and that of a third-party tax preparer. (PSR ¶¶
17-19, 29, 32.) The conspirators also obtained fraudulent loans for two of Kammo’s
cousins and then accessed those fraudulent loan proceeds. (PSR ¶¶ 29-34.)
Discussions between the co-conspirators show that Kammo was responsible
for providing the third-party identities used as part of the fraud. As Kammo told
Shaba during an argument: “I Brong all these motherfuckers to the table”:
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b. History and Characteristics of the Defendant
Unfortunately, this is not Kammo’s first run-in with the criminal justice
system. He was previously sentenced to 36 months in federal custody for significant
controlled substance activity. (PSR ¶ 48.) Kammo has also been convicted for retail
fraud and bad check crimes on two separate occasions; arrested for violent activity
at least three times as an adult; and also arrested for additional drug activity. (PSR
¶¶ 49-52.) Kammo also engaged in extremely dangerous criminal activity as a
juvenile. (PSR ¶ 60.)
Kammo’s prior run-ins with law enforcement, and a significant prior federal
custodial sentence, did not deter him from engaging in this fraud.
c. Seriousness of the Offense, Promotion of Respect for the Law,
and Just Punishment for the Offense
This is a serious offense. Pandemic fraud stole from honest taxpayers. And
such schemes make it more difficult for deserving businesses and individuals to
receive needed assistance in the future.
Notably, Kammo has already received a significant break in this case by virtue
of the government’s agreement to dismiss the multiple aggravated identity theft
charges he faced, which would have guaranteed an additional two-year consecutive
prison sentence. He also received a significant break because of the government’s
agreement not to pursue an intended loss calculation that accounted for the multiple
fraudulent conspiratorial loan applications that were denied.
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A substantial custodial sentence is needed to reflect the seriousness of the
offense, promote respect for the law, and ensure a just punishment
d. Adequate Deterrence and Protection of the Public
Government benefit fraud is both highly lucrative and frequently undetected.
It is this combination that makes general deterrence a particularly important
objective in this case. See United States v. Heffernan, 43 F.3d 1144, 1149 (7th Cir.
1994) (“Considerations of (general) deterrence argue for punishing more heavily
those offenses that either are lucrative or are difficult to detect and punish, since both
attributes go to increase the expected benefits of a crime and hence the punishment
required to deter it.”).
Furthermore, as the Sixth Circuit has recognized, “[b]ecause economic and
fraud-based crimes are more rational, cool, and calculated than sudden crimes of
passion or opportunity, these crimes are prime candidates for general deterrence.”
United States v. Peppel, 707 F.3d 627, 637 (6th Cir. 2013) (citations omitted).
An unambiguous message of deterrence should be sent to others who might
be tempted to steal millions in government benefits: a substantial prison sentence
awaits you.
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e. Providing Defendant with Needed Educational or Vocational
Training, Medical Care, or Other Correctional Treatment in
the Most Effective Manner; Kinds of Sentences Available and
the Need to Avoid Unwarranted Sentencing Disparities
As the PSR notes, after excluding defendants who received a § 5K1.1
substantial assistance departure motion, 96% of defendants with Kammo’s offense
level and criminal history category received a prison sentence. (PSR ¶ 103.) The
median length of imprisonment for those defendants was 38 months. (Id.) A higher
sentence of 51 months is appropriate in this case given the nature and circumstances
of Kammo’s conduct, as well as his prior criminal history, which includes a
substantial prior federal conviction that is not scored. (PSR ¶ 48.)
III. Restitution
Under the Mandatory Victims Restitution Act, restitution is required as
Kammo’s offense involved fraud and deceit. 18 U.S.C. § 3663A(c)(1)(A)(ii).
Furthermore, Kammo has agreed that restitution is due to every identifiable victim
of his offense. (ECF No. 67, PageID.433.)
The government requests that restitution be awarded to the Small Business
Administration in the amount of the loan principal fraudulently obtained by Kammo
and his co-conspirators: $2,493,348.50. (PSR ¶ 90.); see also United States v.
Higgins, No. 22-3538, 2023 WL 6536752, at *12 (6th Cir. Oct. 6, 2023)
(“Restitution awards must reflect the victim's ‘actual losses’”) (citations omitted).
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IV. Conclusion
Samer Kammo victimized the government, financial institutions, and honest
taxpayers. For the reasons discussed above, the Court should impose a sentence of
51 months’ imprisonment.
Respectfully submitted,
JEROME F. GORGON JR.
United States Attorney
s/Andrew J. Yahkind
Assistant United States Attorney
211 W. Fort Street, Suite 2001
Detroit, MI 48226
Phone: (313) 226-9565
E-Mail: andrew.yahkind@usdoj.gov
Dated: February 5, 2026
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Certificate of Service
I certify that on February 5, 2026, I electronically filed the foregoing
document with the Clerk of the Court using the ECF system, which will send
notification of such filing to the following:
Shawn Desai
Attorney for Samer Kammo
I also certify that I will, on today’s date, email a copy of the foregoing
document to Julie Grewe, the assigned probation officer in this matter.
s/Andrew J. Yahkind
Andrew J. Yahkind
Assistant U.S. Attorney
United States Attorney’s Office
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