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Indictment — United States v. Adepoju Babatunde Salako, District of Colorado (Document 1)

Summary

An Indictment filed May 20, 2025 as Document 1 in United States v. Adepoju Babatunde Salako, Criminal Case No. 25-cr-162-CNS, in the United States District Court for the District of Colorado. Count 1 (Conspiracy to Commit Wire Fraud) alleges that from in or about March 2020 through in or about September 2021 Salako and CONSPIRATOR 1 agreed to commit wire fraud in violation of Title 18, United States Code, Section 1343, and requested CARES Act funding of over $700,000, of which they obtained approximately $73,506.16. The indictment describes unemployment insurance, PPP and EIDL programs as background and includes forfeiture allegations, including for Count 8 under 18 U.S.C. § 1956(h). The signature block names Acting United States Attorney J. Bishop Grewell and Assistant U.S. Attorney Craig G. Fansler.

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“Indictment — United States v. Adepoju Babatunde Salako, District of Colorado (Document 1).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-as-to-adepoju-babatunde-salako-usa-v-salako-dkt-1-d-colo-d59ae95f6f/, SHA-256 bf9d79c982f0a29e8503521c84d7f3bcb1d38bf28ff49051e2c3738052a8293f.

Full text

Case No. 1:25-cr-00162-CNS     Document 1 filed 05/20/25    USDC Colorado     pg 1
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                   IN THE UNITED STATES DISTRICT COURT
                       FOR THE DISTRICT OF COLORADO

Criminal Case No. 25-cr-162-CNS

UNITED STATES OF AMERICA,

      Plaintiff,

v.

1.    ADEPOJU BABATUNDE SALAKO,

      Defendant.


                                  INDICTMENT


The Grand Jury charges:

                                   COUNT 1
                       Conspiracy to Commit Wire Fraud

      At all times material to this Indictment:

Individuals and Entities

      1.      Defendant ADEPOJU BABATUNDE SALAKO was a resident of the

State and District of Pennsylvania.

      2.      SALAKO was the sole owner of Tudor Smart Phones & Accessories

LLC (“Tudor”), a Pennsylvania-registered limited liability company

      3.      CONSPIRATOR 1, whose identity is known to the Grand Jury, resided

in Nigeria.
Case No. 1:25-cr-00162-CNS     Document 1 filed 05/20/25      USDC Colorado        pg 2
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Background on Pandemic Benefit Programs

      4.     Unemployment Insurance (“UI”) is a joint state-federal program that

provides monetary benefits to eligible lawful workers. UI benefits are intended to

provide temporary financial assistance to lawful workers who become unemployed

through no fault of their own. Claimants seeking UI benefits are required to

complete an online application that includes, among other things, the claimant’s

name, date of birth, social security number, and the reason why the claimant is

unemployed. In the State of Colorado, the Colorado Department of Labor and

Employment (“CDLE”) administers the UI program. The CDLE, like other state

workforce agencies, relies upon the information in the application to determine UI

benefits eligibility. If the CDLE approves a UI claim, the claimant can receive UI

benefits by direct deposit.

      5.     In March 2020, the Coronavirus Aid, Relief, and Economic Security

(“CARES”) Act was enacted. It expanded UI benefits by providing additional federal

funding and provided emergency assistance to small business owners suffering

adverse economic effects caused by the COVID-19 pandemic. It also provided

funding for small businesses affected by the COVID-19 pandemic through the

Paycheck Protection Program (“PPP”) and the Economic Injury Disaster Loan

(“EIDL”) program, each administered by the United States Small Business

Administration (“SBA”).

      6.     To receive federal money for UI benefits after passage of the CARES

Act, the CDLE had to request money from the United States Department of the



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Treasury (“Treasury”) through a Treasury web interface program. To request

federal funds, the CDLE made a payment request to Treasury, and Treasury would

then disburse the funds to the CDLE’s bank account.

      7.     The EIDL program is an SBA program that provides low-interest

financing to small businesses in regions affected by declared disasters. During the

COVID-19 pandemic, qualifying businesses affected by the pandemic could obtain

an EIDL by submitting an application to the SBA and providing information about

operations prior to January 31, 2020, including its number of employees, revenues,

and cost of goods sold. The amount of the loan, if approved, was determined in part

based on the information provided concerning the gross revenue and cost of goods

sold. EIDL and EIDG funds were issued directly by the SBA. Until April 2021,

under the EIDL program, a small business could receive a loan from the SBA in an

amount of up to six months of working capital with a maximum of $150,000. In

addition, the CARES Act authorized the SBA to issue advances of up to $10,000 to

small businesses, known as Economic Injury Disaster Grants (“EIDG”). Initially,

the amount of the EIDG was determined by the number of employees the applicant

certified having. The EIDGs did not need to be repaid.

      8.     The PPP provided forgivable loans to small businesses. To obtain a

PPP loan, a qualifying small business was required to submit a PPP loan

application signed by an authorized representative of the business and to make

affirmative certifications, including that the information in the application and

supporting documents was true and accurate. The amount of the loan was



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calculated based on a business’s representations about its monthly payroll

expenses. Businesses were also required to provide documentation showing their

payroll expenses, such as filed federal income tax documents. PPP loan applications

were received and processed, in the first instance, by a participating lender. If a

PPP loan application was approved, the participating lender funded the loan using

its own money, but the loans were 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. The SBA paid participating lenders a processing

fee from its Colorado finance center for each funded PPP loan.

The Conspiracy

      9.      From in or about March 2020 through in or about September 2021, in

the District of Colorado and elsewhere, defendant ADEPOJU BABATUNDE

SALAKO and CONSPIRATOR 1, together and with each other, knowingly agreed to

commit wire fraud, in violation of Title 18, United States Code, Section 1343.

Manner and Means of the Scheme and Conspiracy

      Acting interdependently, SALAKO and CONSPIRATOR 1 carried out the

conspiracy using the following manner and means:

      10.     After the CARES Act authorized EIDL and PPP funding and expanded

federal funding for UI benefits, SALAKO and CONSPIRATOR 1 acted together to

request CARES Act funding of over $700,000. They obtained approximately

$73,506.16.



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      11.    SALAKO and CONSPIRATOR 1 used the WhatsApp messaging

service to exchange messages, documents, and information about the conspiracy,

including to exchange stolen or false identities and to share bank account details for

use on fraudulent applications.

      12.    SALAKO and CONSPIRATOR 1 used an email forwarding service

known as 33mail to create multiple usernames on custom email domains. Although

the email addresses appeared to be unique and refer to different individuals, 33mail

allowed all the usernames on the same domain to forward emails to the same email

address. As one example, SALAKO used multiple usernames on the

tudor31620.33mail.com domain, but all usernames on this domain forwarded to one

of SALAKO’s gmail accounts.

      13.    Along with submitting his own fraudulent applications for UI benefits,

SALAKO aided and abetted CONSPIRATOR 1 by sharing SALAKO’s bank account

numbers, phone number, and other identifiers with CONSPIRATOR 1.

CONSPIRATOR 1 then would list SALAKO’s information on fraudulent loan and

UI benefit applications.

      14.    To conceal that CONSPIRATOR 1 was located overseas, SALAKO’s

United States-based bank accounts and contact information was used on

applications, which created the false appearance to lenders or state workforce

agencies that CONSPIRATOR 1 was located in the United States and eligible for

government benefits.




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UI Benefit Scheme and Conspiracy

       15.    Between January 4, 2021 and March 20, 2021, SALAKO submitted

approximately 15 fraudulent applications for UI benefits to the CDLE, using stolen

or false identities.

              a.       SALAKO subscribed to personal information search websites

                       such as TruthFinder. Before submitting fraudulent applications

                       to the CDLE for UI benefits, SALAKO looked up names and

                       addresses of residents of Colorado so he could submit

                       applications using their actual identifiers.

              b.       Approximately 10 of SALAKO’s UI claims listed as a contact

                       email a username linked to the tudor31620.33mail.com email

                       domain that appeared to be separate emails, but which were

                       configured through the 33mail service to forward to a single

                       gmail account. Three other claims used a different 33mail.com

                       email domain used by SALAKO that forwarded to another email

                       account he monitored.

              c.       The CDLE paid one UI claim submitted by SALAKO. On March

                       3, 2021, the CDLE paid $649 to a Discover Bank account

                       controlled by SALAKO based on a fraudulent UI claim SALAKO

                       submitted using the stolen identity of V.H.

              d.       Other claims were approved for payment, including a claim

                       SALAKO submitted using the stolen identity of M.M. for $890,



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                   but the CDLE placed a payment hold after discovering that the

                   name on the bank account did not match the name on the UI

                   claim.

      16.    Between January 24, 2021 and May 19, 2021, CONSPIRATOR 1

submitted at least 54 fraudulent applications for UI benefits to the CDLE, using

stolen or false identities and directing that the CDLE deposit payments to accounts

controlled by SALAKO. The CDLE approved 7 of these fraudulent claims and paid

$15,431 in UI benefits to SALAKO-controlled bank accounts.

      17.    SALAKO and CONSPIRATOR 1 acted for their mutual benefit by

coordinating fraudulent activity. They exchanged bank account numbers, updated

each other about the status of claims, and coordinated the deposit and transfer of

fraud proceeds. For example:

             a.    On February 17, 2021, CONSPIRATOR 1 messaged SALAKO

                   that he would direct the CDLE to deposit UI benefits to a bank

                   account in SALAKO’s name. SALAKO agreed to receive the

                   funds. After the CDLE paid $949 to SALAKO’s bank account on

                   February 22, 2021, CONSPIRATOR 1 messaged SALAKO

                   “Colorado don dey payyy!!!”

             b.    On March 14, 2021, SALAKO messaged CONSPIRATOR 1 to

                   work together on a UI claim. SALAKO messaged a bank account

                   number created using the stolen identity of C.W. to

                   CONSPIRATOR 1. CONSPIRATOR 1 then submitted a CDLE



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                      claim using a stolen identity of L.H. The CDLE approved the UI

                      claim for L.H. and direct deposited $598 to the bank account in

                      the name of C.W. on March 15, 2021.

      18.       In addition to submitting fraudulent UI claims to Colorado, SALAKO

submitted fraudulent UI claims in other states using stolen or false identities,

including Maryland, Minnesota, New Hampshire, and New York. He received

approximately $26,801.16 from other states.

      19.       The submission of fraudulent UI claims by SALAKO and

CONSPIRATOR 1 caused a server used by the CDLE located outside of Colorado to

transmit wires to Colorado, which led CDLE employees to mail letters to the

addresses associated with the UI claims.

EIDL Scheme and Conspiracy

      20.       Between January 16, 2021 and March 3, 2021, SALAKO submitted

and aided and abetted in the submission of at least 10 fraudulent applications for

EIDLs to the SBA, using stolen or false identities. The applications requested loans

totaling approximately $287,422.50. The SBA did not approve any of these

applications.

      21.       Between January 26, 2021 and April 26, 2021, CONSPIRATOR 1

submitted and aided and abetted in the submission of at least 3 fraudulent

applications for EIDLs to the SBA, using stolen or false identities. CONSPIRATOR

1 listed a phone number and bank account belonging to SALAKO on each




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application. The applications requested loans totaling $450,000. The SBA did not

approve any of these applications.

PPP Loan Scheme and Conspiracy

      22.    On February 11, 2021, CONSPIRATOR 1 submitted a fraudulent PPP

loan application in the name of Turn-Turn-Turn Woodturning using the stolen

identity of D.P., a resident of Nevada. The application listed a bank account and

phone number belonging to SALAKO and a 33mail.com email address that routed

to a gmail account used by CONSPIRATOR 1. The application provided false

information about the identity of the person submitting the application and the

business’s operations. On February 12, 2021, a lender approved the application

based on the false representations and disbursed $30,625 to a Discover Bank

account in the name of SALAKO.

      23.    The disbursement of the PPP loan to SALAKO caused the SBA’s

finance center in Denver, Colorado to transmit a payment file outside of Colorado

for an associated lender processing fee.

      All in violation of Title 18, United States Code, Section 1349.




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                                  COUNTS 2-7
                  Wire Fraud and Aiding and Abetting Wire Fraud

The Scheme to Defraud

        24.     Beginning in or about January 2021 and continuing through in or

about May 2021, within the State and District of Colorado and elsewhere, defendant

ADEPOJU BABATUNDE SALAKO and CONSPIRATOR 1 together and with each

other, devised, intended to devise, and participated in a scheme to defraud and to

obtain money and property from the CDLE, the Small Business Administration,

and private lenders by means of materially false and fraudulent pretenses,

representations, and promises, and aided and abetted the same.

Manner and Means of the Scheme

        25.     Paragraphs 1-8 and 10-23 are re-alleged and incorporated as if fully

set forth herein.

Execution of the Scheme

        26.     On or about the dates set forth below, in the State and District of

Colorado, and elsewhere, SALAKO transmitted and caused to be transmitted by

means of wire communication in interstate commerce certain writings, signs,

signals, pictures, and sounds, as set forth below:

  Count         Date                          Description of Wire

    2         01/25/2021 Request for payment routed from Colorado to Treasury web
                         interface outside Colorado caused by fraudulent submission
                         of V.H. UI claim
    3          2/24/2021 Request for payment routed from Colorado to Treasury web
                         interface outside Colorado caused by fraudulent submission
                         of N.B. UI claim


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    4        2/25/2021   Wire from server outside of Colorado to CDLE employee in
                         Colorado related to claim notification letter mailed to D.B.
    5        3/4/2021    Request for payment routed from Colorado to Treasury web
                         interface outside Colorado caused by fraudulent submission
                         of N.B. UI claim
    6        3/6/2021    Request for payment routed from Colorado to Treasury web
                         interface outside Colorado caused by fraudulent submission
                         of L.H. UI claim
    7        3/12/2021   Request for payment routed from Colorado to Treasury web
                         interface outside Colorado caused by fraudulent submission
                         of L.H. UI claim

        All in violation of Title 18, United States Code, Sections 1343 and 2(a).




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                              COUNT 8
            Money Laundering Conspiracy, 18 U.S.C. § 1956(h)

      27.   Paragraphs 1-8 are re-alleged and incorporated as if fully set forth

herein.

      28.   Beginning in or about July 2020, and continuing thereafter until in or

about July 2021, in the State and District of Colorado and elsewhere, defendant

ADEPOJU BABATUNDE SALAKO knowingly combined, conspired, and agreed

with co-conspirators known and unknown to the Grand Jury to:

            a.     knowingly conduct and attempt to conduct financial

                   transactions affecting interstate commerce that involved the

                   proceeds of specified unlawful activity, that is, wire fraud in

                   violation of 18 U.S.C. § 1343, knowing that the transaction was

                   designed in whole or in part to conceal and disguise the nature,

                   location, source, ownership, and control of the proceeds of

                   specified unlawful activity and that while conducting and

                   attempting to conduct such financial transactions knew that the

                   property involved in the financial transactions represented the

                   proceeds of some form of unlawful activity, in violation of 18

                   U.S.C. § 1956(a)(1)(B)(i).

            b.     knowingly engage or attempt to engage in monetary

                   transactions, as defined in Title 18, United States Code, Section

                   1957(f)(1), in criminally derived property of a value greater than

                   $10,000 and that was derived from specified unlawful activity,


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                   to wit, a scheme to commit wire fraud in violation of 18 U.S.C.

                   § 1343, in violation of 18 U.S.C. § 1957(a).

Manner and Means of the Conspiracy

      Acting interdependently, SALAKO and other conspirators known and

unknown carried out the conspiracy using the following manner and means:

      29.    SALAKO’s co-conspirators applied for EIDL, PPP, and UI funding

using stolen or fake identities. As a result of fraudulent applications, SALAKO’s co-

conspirators obtained approximately $4,711,200 in EIDL funding and $893,771.34

in UI funding. To obtain this funding, co-conspirators submitted EIDL applications

using over 1,000 stolen or fake identities and submitted fraudulent UI benefit

claims to approximately 30 different states.

      30.    All EIDL payments originated from an SBA finance center in Denver,

Colorado. SALAKO and his co-conspirators directed the movement of this money

from Colorado to bank accounts in multiple states outside of Colorado.

      31.    SALAKO’s co-conspirators fraudulently obtained approximately

$61,423 in UI benefits from the CDLE after submitting approximately 143

fraudulent UI benefit claims. SALAKO provided his bank account information to co-

conspirators so that they could direct CDLE to deposit funds directly to SALAKO’s

accounts.

      32.    SALAKO and co-conspirators exchanged with each other bank account

information, including some bank accounts in SALAKO’s name and others opened

by SALAKO using stolen and fake identities.



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      33.    After the initial deposit of fraud proceeds in a bank account, SALAKO

and co-conspirators would move fraud proceeds through several intermediate

accounts using various methods, including ATM withdrawals and deposits, wire

transfers, and the purchase and deposit of money orders.

      34.    Eventually, after conducting transfers through intermediate accounts,

SALAKO and co-conspirators spent fraud proceeds or transferred the money

overseas as currency or in the form of goods purchased from the fraud proceeds,

such as cars or solar panels.

      35.    Co-conspirators also shared in common victims of romance fraud

schemes who received fraud money from government agencies and sent to SALAKO

and other co-conspirators. The involvement of the romance fraud victims added an

additional layer to conceal the involvement of SALAKO and the co-conspirators. In

such instances, fraud money was initially deposited into accounts belonging to

victims of a romance fraud scheme—including P.B. and J.Y.—who were directed to

move fraud proceeds to SALAKO and co-conspirators.

      36.    A romance fraud scheme is a type of scheme by which a scammer

targets persons looking for partners or friendship on dating websites and other

social media platforms. The scammer may create profiles using fictitious or fake

names, locations, images, and personas, allowing the scammer to cultivate

relationships with prospective romance fraud scheme victims. Victims may be asked

to conduct financial transactions on behalf of the scammer, such as transferring

fraud proceeds to conceal the source or destination of the proceeds.



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            c.     Romance-fraud victim J.Y. received approximately $452,300 in

                   EIDL funds and $43,045 in UI benefits to bank accounts in his

                   own name.

            d.     Romance-fraud victim P.B. received approximately $301,400 in

                   EIDL funds, $17,700 in PPP funds, and $7,410 in UI benefits to

                   bank accounts in his name.

      37.   On applications for EIDL, PPP, and UI funding, multiple co-

conspirators designated that lenders or government agencies deposit fraud money

into bank accounts belonging to J.Y. and P.B.

      38.   After J.Y. and P.B. obtained fraud money, they received instructions to

initiate wire transfers and endorse checks and money orders to SALAKO’s business

(Tudor). For example:

            a.     Between June 30, 2020, and July 29, 2020, the SBA made four

                   deposits to J.Y.’s bank account for a total of $452,300 based on

                   four fraudulent EIDL applications submitted using stolen or

                   fake identities. J.Y. was instructed to make cash withdrawals,

                   purchase money orders, and transfer money to Tudor via wire

                   transfer or cashier’s check. J.Y. sent messages to confirm when

                   he completed an instruction. Between July 16, 2020, and August

                   10, 2020, J.Y. sent three cashier’s checks via mail endorsed to

                   Tudor (totaling $105,000) and two $15,000 wires to a Tudor

                   bank account.



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             b.       Between July 2, 2020, and August 10, 2020, the SBA made three

                      deposits to P.B.’s bank account for a total of $301,400 based on

                      three fraudulent EIDL applications submitted using stolen or

                      fake identities. P.B. was instructed to purchase money orders

                      and cashier’s checks and send the money orders and cashier’s

                      checks to Tudor via mail. Between July 25, 2020, and August 29,

                      2020, P.B. sent one money order and six cashier’s checks

                      endorsed to Tudor via mail, totaling $264,504.

             c.       On March 26, 2021, Cross River Bank deposited $17,708 to

                      P.B.’s bank account. The deposit related to a fraudulent PPP

                      loan submitted in the name of identity-theft victim J.B. on or

                      about March 25, 2021. P.B. obtained a teller check for $17,700

                      payable to Tudor. On April 13, 2021, SALAKO deposited this

                      check to a Tudor checking account.

      39.    After SALAKO received money that passed through the bank accounts

of romance-fraud victims, he conducted frequent transactions to move the money to

his personal accounts and conceal the source, nature, location, and destination of

the fraud proceeds.

      40.    It was part of the conspiracy that SALAKO made multiple cash

withdrawals from ATMs and branch locations on the same day or on dates in close

proximity and wired money between multiple business and personal bank accounts

he controlled.



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      41.    After making cash withdrawals from Tudor bank accounts, it was part

of the conspiracy that Salako would deposit the cash to personal bank accounts in

his own name, often on the same or consecutive days as the initial withdrawal from

his business bank account. From his personal bank accounts, SALAKO then

initiated wire transfers to China, Nigeria, and the United Arab Emirates. Between

July 20, 2020 and November 25, 2020, for example, SALAKO wired approximately

$932,881 of fraud proceeds from his personal Bank of America account ending in

3033 overseas to these three countries, as well as approximately $30,000 from his

other bank accounts.

      42.    After receiving one $40,000 cashier’s check from J.Y., SALAKO

explained why he moved the money between bank accounts through multiple

transactions over several days rather than withdrawing all the money at once in a

single transaction: “I don’t withdraw whole 40k just like that. I don’t do thing rush

rush rush rush rush” because it would “raise red flag.” Instead, SALAKO stated

that he did “things clean, slow.”

      43.    For his role of laundering fraud proceeds for co-conspirators operating

overseas, SALAKO took fees from the money he laundered, typically between 25-

60% of the value of laundered funds. For example, on July 16, 2020, when

discussing receiving fraud proceeds from J.Y., SALAKO messaged a conspirator

that his fee was 25 percent of laundered funds.

      44.    SALAKO and his conspirators also spent fraud proceeds to carry on

and engage in additional fraud, such as using fraud proceeds to pay phone bills for



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numbers used to facilitate fraud, pay subscriptions for personal information search

websites such as TruthFinder, and pay subscriptions for email accounts used to

facilitate the fraud, including the 33mail.com email domain.

      45.    SALAKO and his co-conspirators caused acts in furtherance of the

money-laundering conspiracy to take place in Colorado. For example, co-

conspirators provided the CDLE with Salako’s bank accounts in the United States

rather than their own to conceal and disguise the nature, location, source,

ownership, and control of their wire-fraud proceeds, including to conceal that the

fraud was committed from overseas and that fraud proceeds were eventually

transmitted overseas. Co-conspirators also provided the SBA with bank accounts

belonging to victims of romance-fraud rather than their own bank accounts for the

SBA to wire money from Colorado to those bank accounts outside of Colorado to

conceal and disguise the nature, location, source, ownership, and control of their

wire-fraud proceeds.

      All in violation of Title 18, United States Code, Section 1956(h).




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                               COUNTS 9-12
                 Aggravated Identity Theft, 18 U.S.C. § 1028A

      46.    On or about the dates listed below, in the District of Colorado and

elsewhere, defendant ADEPOJU BABATUNDE SALAKO knowingly transferred,

possessed, and used, without lawful authority, a means of identification of the below

persons during and in relation to a felony violation enumerated in 18 U.S.C.

§ 1028A(c), to wit, wire fraud in violation of 18 U.S.C. § 1343 and conspiracy to

commit wire fraud in violation of 18 U.S.C. § 1349, knowing that the means of

identification belonged to another actual person.

  COUNT                 DATE                              PERSON
    9                 01/27/2021                  V.H., a Colorado resident
    10                02/18/2021                  M.C.., a Kansas resident
    11                 2/24/2021                  M.M., a Colorado resident
    12                03/15/2021               C.W., a New Hampshire resident

      All in violation of Title 18, United States Code, Section 1028A(a)(1).




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                                    FORFEITURE

      47.    Upon conviction of any of the violations alleged in Counts 1-7 of this

Indictment involving the commission of violations of 18 U.S.C. §§ 1343 and

1349, SALAKO shall forfeit to the United States, pursuant to 18 U.S.C.

§ 981(a)(1)(C) and 28 U.S.C. § 2461(c), any and all rights, title, and interest in all

property constituting and derived from any proceeds obtained directly and

indirectly as a result of such offense or offenses, including, but not limited to a

money judgment in the amount of the proceeds obtained by the defendant’s scheme.

      48.    Upon conviction of the violations alleged in Count 8 of this Indictment,

in violation of 18 U.S.C. § 1956(h), SALAKO shall forfeit to the United States,

pursuant to 18 U.S.C. § 982(a)(1), any and all rights, title, and interest in all

property involved in the offense and any property traceable to such property,

including, but not limited to a money judgment in the amount of value of the

property involved in the offense.

      49.    If any of the property described above, as a result of any act or

omission of SALAKO cannot be located upon the exercise of due diligence; has been

transferred or sold to, or deposited with, a third party; has been substantially

diminished in value; or has been commingled with other property that cannot be

divided without difficulty, it is the intent of the United States, pursuant to 28

U.S.C. § 2461(c), incorporating 21 U.S.C. § 853(p), to seek forfeiture of any other

property of SALAKO up to the value of the forfeitable property described above.




                                           20
Case No. 1:25-cr-00162-CNS      Document 1 filed 05/20/25     USDC Colorado      pg 21
                                       of 21




                                              A TRUE BILL:



                                              Ink Signature on File in Clerk’s Office
                                               FOREPERSON


J. BISHOP GREWELL
Acting United States Attorney

By: s/ Craig G. Fansler___________
Craig G. Fansler
Assistant U.S. Attorney
U.S. Attorney’s Office
1801 California St., Ste. 1600
Denver, CO 80202
Telephone: 303-454-0100
Fax: 303-454-0401
E-mail: Craig.Fansler2@usdoj.gov
Attorney for the United States




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