Indictment — United States v. Cassandra Yolanda Clarke, Southern District of Florida (Document 1)

Summary

A grand jury indictment of Cassandra Yolanda Clarke, Case No. 0:24-cr-60227-AHS, in the U.S. District Court for the Southern District of Florida, entered on the docket November 26, 2024 as Document 1. Counts 1-3 charge wire fraud under 18 U.S.C. § 1343, Count 4 money laundering, and Counts 5-6 monetary transactions under 18 U.S.C. § 1957. The indictment alleges that Clarke, president of Narotique Beauty Bar Inc. and a member of Narotique Med Spa LLC, submitted PPP applications with false IRS forms prepared with an accomplice, and that the companies received loans of approximately $431,342 and $420,552. It alleges the funds paid for the lease of a Bentley Bentayga and luxury purchases, and the charged transactions include a cashier's check of approximately $18,000 and withdrawals of approximately $64,000 and $42,000.

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“Indictment — United States v. Cassandra Yolanda Clarke, Southern District of Florida (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-0-24-cr-60227-dkt-1-s-d-fla-f4207b6a32/, SHA-256 02c7ddd88fc1e518b8987a96cd67e0ff512381e4da6595cbe46d599f89b97852.

Full text

Case 0:24-cr-60227-AHS Document 1 Entered on FLSD Docket 11/26/2024 Page 1 of 8

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO. _24-CR-60227-Singhal/Strauss
_ _ _ _ _ _ _ __
18 u.s.c. § 1343
18 U.S.C. § 1956(a)(l)(B)(i)
18 u.s.c. § 1957
18 u.s.c. § 2
18 U.S.C. § 982(a)(2)
18 U.S.C. § 982(a)(l)

SW
UNITED STATES OF AMERICA

vs. Nov 26, 2024
CASSANDRA YOLANDA CLARKE,
WPB
Defendant.
- - - -- - -- - - - - - -I
INDICTMENT

The Grand Jury charges that:

GENERAL ALLEGATIONS

At all times relevant to this Indictment:

1. Narotique Beauty Bar Inc. was a company incorporated in the State of Florida.

CASSANDRA YOLANDA CLARKE was the president.

2. Narotique Med Spa LLC was a company registered in the State of Florida.

CASSANDRA YOLANDA CLARKE was an authorized member.

3. Kabbage, Inc. ("Kabbage") was a financial services provider headquartered in

Atlanta, Georgia.

4. Bluevine Capital Inc. ("Bluevine") was a financial sei·vices provider headqumtered

in Salt Lake City, Utah.

5. Celtic Bank was a financial institution headqua1tered in Salt Lake City, Utah.
Case 0:24-cr-60227-AHS Document 1 Entered on FLSD Docket 11/26/2024 Page 2 of 8

6. Bluevine processed applications for loans under the Paycheck Protection Program

("PPP") funded by Celtic Bank.

7. Wells Fargo is a financial institution with branches located in the Southern District

of Florida.

COUNTS 1- 3
Wire Fraud
(18 u.s.c. §1343)

1. The General Allegations section of this Indictment is re-alleged and incorporated

by reference as though fully set fo1th herein .

2. From on or about April 22, 2020, to on or about August 26, 2020, in Broward

County, in the Southern District of Florida, and elsewhere, the defendant,

CASSANDRA YOLANDA CLARKE,

did knowingly, and with the intent to defraud, devise, and intend to devise, a scheme and artifice

to defraud, and to obtain money and prope1ty by means of materially false and fraudulent

pretenses, representations, and promises, knowing that the pretenses, representations, and

promises were false and fraudulent when made, and, for the purpose of executing the scheme and

artifice, did knowingly transmit and cause to be transmitted, by means of wire communications in

interstate commerce, certain writings, signs, signals, pictures, and sounds, in violation of Title 18,

United States Code, Section 1343.

PURPOSE OF THE SCHEME AND ARTIFICE

3. It was the purpose of the scheme and artifice for the defendant to unlawfully enrich

herself by, among other things: (a) submitting and causing the submission of false and fraudulent

applications for PPP loans made through the SBA to provide relief for the economic effects caused

by the COVID-19 pandemic; and (b) dive1ting the loan proceeds for her personal use and benefit,

and the use and benefit of others.

-2-
Case 0:24-cr-60227-AHS Document 1 Entered on FLSD Docket 11/26/2024 Page 3 of 8

MANNER AND MEANS OF THE SCHEME AND ARTIFICE

The manner and means by which the defendant sought to accomplish the purpose of the

scheme and artifice included, among other things, the following:

4. CASSANDRA YOLANDA CLARKE submitted and caused the submission of

false and fraudulent PPP loan applications on behalf of, among others, Narotique Med Spa LLC

and Narotique Beauty Bar Inc.

5. In furtherance of the scheme, CASSANDRA YOLANDA CLARKE created and

caused Accomplice 1 to create false and fraudulent documentation for use in PPP loan applications.

6. Also in futtherance of the scheme, CASSANDRA YOLANDA CLARKE

submitted and caused the submission of false and fraudul ent information and documentation in

suppott of PPP loan applications, including false and fraudulent IRS forms.

7. As a result of the false and fraudulent PPP loan applications, Narotique Med Spa

LLC received a PPP loan in the approximate amount of $420,552.

8. As a result of the false and fraudulent PPP loan applications, Narotique Beauty Bar

Inc. received a PPP loan in the approximate amount of $431,342.

9. CASSANDRA YOLANDA CLARKE used the fraudulently obtained fund s to

pay for, among other things, the lease of a Bentley Bentayga and Iuxury purchases at the Bal

Harbour Shops.

USE OF THE WIRES

10. On or about the dates specified below, in the Southern District of Florida,

CASSANDRA YOLANDA CLARKE, for the purpose of executing and in furtherance of the

aforesaid scheme and mtifice to defraud, and to obtain money and prope1ty by means of materially

false and fraudulent pretenses, representations, and promises, knowing that the pretenses,

representations, and promises were false or fraudulent when made, did knowingly transmit and

-3-
Case 0:24-cr-60227-AHS Document 1 Entered on FLSD Docket 11/26/2024 Page 4 of 8

cause to be transm itted in interstate and foreign co mmerce, by means of wire communications,

certain writings, signs, signals, pictures, and sounds , as paiticularly described below:

Count Approximate Date Description of Wire
Emai l from CASSANDRA YOLANDA CLARKE to
I April 24, 2020 Accomplice 1, listing employee names and wages for
Narotiq ue Beauty Bar Inc .

Emai l from Accompl ice 1 to CASSANDRA YOLANDA
2 June 26, 2020 CLARKE, attach ing an IRS Form W-3 forNarotique Med
Spa LLC.

The submission of a PPP application to Kabbage on behalf of
3 July 2, 2020
Narotique Med Spa LLC.

In v iolation of Title 18, Un ited States Code, Sections 1343 and 2.

COUNT4
Money Laundering
(18 U.S.C. §1956(a)(l)(B)(i))

11. The General Allegations section of this Indictment is re-alleged and incorporated

by reference as if fully set fo1th herein .

12. On or about A ugust 18, 2020, in Miami-Dade County, in the Southern District of

Florida, the defendant,

CASSANDRA YOLANDA CLARKE,

did knowingly conduct and attempt to conduct a financial transaction affecting interstate and

foreign commerce, which financial transaction involved the proceeds of specified unlawful

activity, !mowing the prope1ty involved in the financial transaction represented the proceeds of

some form of unlawful activity, and 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 unl awfu l activity, that is, the purchase of a cashier's check, in the approximate amount

-4-
Case 0:24-cr-60227-AHS Document 1 Entered on FLSD Docket 11/26/2024 Page 5 of 8

of $18,000, with the memo line "two and a half months salary," from an account ending in 6754

at Wells Fargo.

13. It is further alleged that the specified unlawful activity is wire fraud, in violation of

Title 18, United States Code, 1343.

14. In violation of Title 18, United States Code, Section 1956(a)(l)(B)(i).
i

COUNTS 5- 6
Money Laundering
(18 u.s.c. §1957)

15 . The General Allegations section of this Indictment is re-alleged and incorporated

by reference as if fully set fo1th herein.

16. On or about the dates specified below, in Broward County, in the Southern District

of Florida, and elsewhere, the defendant,

CASSANDRA YOLANDA CLARKE,

did knowingly engage in, and attempt to engage in, a monetary transaction affecting interstate

commerce, by, through, and to a financial institution, in criminally derived property of a value

greater than $ 10,000, such prope1iy having been derived from a specified unlawfu l activity, and

knowing that the property involved in the financial transaction represented the proceeds of some

form of unlawful activity, as described below:

Count Approximate Date Description of Transaction
Withdrawal, in the approximate amount of $64,000, from an
5 June 4, 2020
account ending in 3433 at Wells Fargo.

Withdrawal, in the approximate amount of $42,000, from an
6 July 9, 2020
account ending in 5842 at -e,A-Ni ()~ ~Ml"llA. ~ ~
-
17. It is fmiher alleged that the specified unlawful activity is wire fraud, in violation of

Title 18, United States Code, Section 1343.

18. In violation of Title 18, United States Code, Sections 1957 and 2.

-5-
Case 0:24-cr-60227-AHS Document 1 Entered on FLSD Docket 11/26/2024 Page 6 of 8

FORFEITURE ALLEGATIONS

l. The allegations of this Indictment are hereby re-alleged and by this reference fully

incorporated herein for the purpose of alleging forfeiture to the United States of America of ce1tain

property in which the defendant, CASSANDRA YOLNDA CLARKE, has an interest.

2. Upon conviction of a violation of Title 18, United States Code, Section 1343, as

alleged in this Indictment, the defendant shall forfeit to the United States of America, pursuant to

Title 18, United States Code, Section 982(a)(2), any property constituting, or derived from ,

proceeds the defendant obtained directly or indirectly, as the result of such violation.

3. Upon conviction of a violation of Title 18, United States Code, Section 1956 and/or

Section 1957, as alleged in this Indictment, the defendant shall forfeit to the United States of

America, pursuant to Title 18, United States Code, Section 982(a)(l), any property, real or

personal, involved in such violation, or any prope1ty traceable to such prope1ty.

All pursuant to Title 18, United States Code, Sections 982(a)(l) and (a)(2), and the

procedures set forth at Title 21, Un ited States Code, Section 853, as made applicable by Title 18,

United States Code, Section 982(6)(] ).

Ch-~ (3 -~
tt5NATHAN BAIL~
ASSISTANT UNITED STATES ATTORNEY

-6-
Case 0:24-cr-60227-AHS Document 1 Entered on FLSD Docket 11/26/2024 Page 7 of 8

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
24-CR-60227-Singhal/Strauss
CASE NO.: _ _ _ _ _ _ _ _ _ __ _ __
UNITED STATES OF AMERICA

v.
CERTIFICATE OF TRIAL ATTORNEY
CASSANDRA YOLANDA CLARKE I
Superseding Case Information:
New Defendant(s) (Yes or No)
Court Division (select one) Number of New Defendants
0 Miami □ Key West O FTP Tota l number of counts
0FTL □ WPB

I do hereby certify that:
I. I have carefully considered the allegations of the indictment, the number of defendants, the number of probable
witnesses and the legal complexiti es of the fndictment/fnformation attached hereto.
2. I am aware that the information supplied on thi s statement will be relied upon by the Judges of this Court in setting
their calendars and scheduling criminal trials under the mandate of the Speedy Trial Act, Title 28 U.S .C. §3161.

3. Interpreter: (Yes or No) No
---
List language and/or dialect:
-------
4. Thi s case wil l take_s__ c!ays for the pa1iies to try.

5. Please check appropriate category and type of offense listed below:
(Check only one) (Check only one)
I 0 0 to 5 days □ Petty
IIO 6 to JO days O Minor
D 11 to 20 days
III D Misdemeanor
IVO 21 to 60 days [{] Felony
V O 61 days and over

6. Has this case been previously filed in this District Court? (Yes or No)_N_o_ _
If yes, Judge___________ Case No. _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
7. Has a complaint been filed in this matter? (Yes or No) No
Ifyes, Magistrate Case No. _ _ _ _ _ _ _ _ _ _ __
---
8. Does this case relate to a previously filed matter in this District Court? (Yes or No) -
No- -
Ifyes, Judge _ _ _ _ _ _ _ _ _ _ _ Case No. _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
9. Defendant(s) in federal custody as of _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ __
I 0. Defendant(s) in state custody as of _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
11. Rule 20 from the _ _ _ _ District of _ _ _ _ _ __
12. Is this a potential death penalty case? (Yes or No) _N_o_ _
13. Does this case originate from a matter pending in the Northern Region of the U.S. Attorney's Office prior
to August 8, 2014 (Mag. Judge Shaniek Maynard? (Yes or No) No
- --
14. Does this case originate from a matter pending in the Central Region of the U.S. Attorney's Office prior
to October 3, 2019 (Mag. Judge Jared Strauss? (Yes or No) No
- --
15 . Did this matter involve the paiiicipation of or consultation with now Magistrate Judge Eduardo I. Sanchez
during his tenure at the U.S. Attorney's Office, which concluded on January 22, 2023? _N_o_ _
16. Did this matter involve the pa1iicipation of or consultation with now Magistrate Judge Maita Fulgueira
Elfenbein during her tenure at the U.S. Attorney's Office, which concluded on March 5, 2024? No
By: fjo1iadan, l3ai1tfn, - -- - -~----
Jonathan Bailyn
Assistant Un ited States Attorney
Court ID No. A5502602
Case 0:24-cr-60227-AHS Document 1 Entered on FLSD Docket 11/26/2024 Page 8 of 8

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

PENAL TY SHEET

Defendant's Name: CASSANDRA YOLANDA CLARKE

24-CR-60227-Singhal/Strauss
Case No: - - - - -- - - -- - - -- -- -- - - -- - - - - -- - - - -

Counts #: 1-3

Wire Fraud

Title 18 United States Code Section 1343
* Max.Term oflmprisonment: 20 Years ' Imprisonment
* Mandatory Min. Term of Imprisonment (if applicable): NIA
*Max.Supervised Release: 3 Years
* Max. Fine: $250,000

Cou nt#: 4

Money Laundering

Title 18, United States Code, Secti on l 956(a)(l)(B)(i)
* Max.Term of Imprisonment: 10 Years' Imprisonment
* Mandatory Min. Term oflmprisonment (if applicable): N/A
* Max.Supervised Release: 3 Years
* Max. Fine: $250,000

Counts #: 5-6

Money Laundering

Title 18 United States Code Section 1957
* Max.Term oflmprisonment: 10 Years' Imprisonment
* Mandatory Min. Term oflmprisonment (if applicable): N/A
* Max. Supervised Release: 3 Years
* Max. Fine: $250,000

*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms, or forfeitures that may be applicable.

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