Indictment — United States v. Joseph Oloyede and Edward Oluwasanmi, Northern District of Ohio (Doc. 1)

Summary

An indictment in United States of America v. Joseph Oloyede and Edward Oluwasanmi, Case 1:24-cr-00120-CAB, in the U.S. District Court for the Northern District of Ohio, Eastern Division, filed April 3, 2024 as Doc #: 1. The caption cites Title 18, United States Code, Sections 1343, 1349, 1957, and 2, and Count 1 charges conspiracy to commit wire fraud under 18 U.S.C. § 1349 from about April 2020 through about February 28, 2022. The grand jury alleges that the defendants submitted PPP and EIDL applications with falsified employee, payroll and revenue figures and falsified IRS and Ohio wage documents, and that Oloyede received kickbacks from other borrowers. It alleges that PPP applications for the defendants' own businesses obtained at least $685,222. The forfeiture section, covering Counts 1-13, lists real property in South Euclid and Medina, Ohio.

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“Indictment — United States v. Joseph Oloyede and Edward Oluwasanmi, Northern District of Ohio (Doc. 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-1-24-cr-00120-dkt-1-n-d-ohio-45c8a01bc2/, SHA-256 611570e146928c36842990e615bc27f38db592fbc87cc26af5ab28af2bc73b6e.

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Case: 1:24-cr-00120-CAB Doc #:1 Filed: 04/03/24 1 of 18. PagelD #: 1

FILED
APRO3 2024
CLERK, US. DISTRICT COURT
IN THE UNITED STATES DISTRICT COURT NORTHERN BISTRICT OF OHIO
FOR THE NORTHERN DISTRICT OF OHIO
EASTERN DIVISION
UNITED STATES OF AMERICA, ) INDICTMENT
) ry
Plaintiff, ) 1 e 4 0
4 CR 0120
Vv. ) CASENO.
) Title 18, United States Code,
JOSEPH OLOYEDE, ) Sections 1343, 1349, 1957, and 2
EDWARD OLUWASAMNMI, ) c
JUDGE BOYKO
Defendants. ) te BU WN £

GENERAL ALLEGATIONS

At all times relevant to this Indictment, unless otherwise specified:

The Economic Injury Disaster Loan Program

1. The United States Small Business Administration (“SBA”) was an executive
branch agency of the United States government. The mission of the SBA was to maintain and
strengthen the nation’s economy by enabling the establishment and viability of small businesses
and assist in the economic recovery of communities after disasters.

2. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was a
federal Jaw enacted in or around March 2020 and was designed to provide emergency financial
assistance to Americans suffering the economic effects caused by the COVID-19 pandemic. One
source of relief under the CARES Act was authorization for the SBA to issue loans to small
businesses and non-profit entities experiencing revenue loss due to the pandemic.

3. One form of such assistance was the Economic Injury Disaster Loan (““EIDL”)

program, which provided loan assistance for certain businesses negatively affected by the
Case: 1:24-cr-00120-CAB Doc #:1 Filed: 04/03/24 2 of 18. PagelD #: 2

COVID-19 pandemic. To qualify for an EIDL loan, a business had to, among other
requirements, be in operation prior to February 1, 2020.

4, Applicants for EIDL loans used the SBA online portal to submit their application
materials. The servers that processed the EIDL loan applications were outside the state of Ohio,
in the states of lowa, Virginia, or Washington.

5. Applicants had to certify that the information in the application was true and
correct, under the penalty of perjury and applicable criminal statutes. The application process
involved filling out data fields relating to the size and ownership of the affected business entity,
and other information about the relevant business for the 12 months prior to COVID-19
impacting the national economy, such as the number of employees in the business, the gross
business revenues realized, and the cost of goods sold. This information, submitted by the
applicant, was then used by SBA systems to calculate the amount of money the applicant was
eligible to receive.

6. Pursuant to the provisions governing the EIDL program, loan proceeds could only
be used by the affected business receiving EIDL loans for certain permissible expenses. The
loans could be used by the business to pay fixed debts, payroll, accounts payable, and other bills
that could have been paid had the COVID-19 disaster not occurred.

7, The CARES Act also authorized the SBA to issue advances or grants of up to
$10,000 to small businesses. The amount of the advance was determined by the number of
employees the applicant certified having ($1,000 per employee, up to $10,000). The advances

did not have to be repaid, and documentation of employment was generally not required.
Case: 1:24-cr-00120-CAB Doc #:1 Filed: 04/03/24 3 of 18. PagelD #: 3

The Paycheck Protection Program

8. The CARES Act authorized forgivable loans to small businesses for job retention
and certain other expenses, through a program referred to as the Paycheck Protection Program
(“PPP”), which was administered by the SBA.

9, In order to obtain a PPP loan, a qualifying business submitted a PPP loan
application, which was signed by an authorized representative of the business. The PPP loan
application required the business (through its authorized representative) to acknowledge the
program rules and make certain affirmative certifications in order to be eligible to obtain the PPP
loan. In the PPP loan application (SBA Form 2483), the small business (through its authorized
representative) was required to provide, among other things, its: (a) average monthly payroll
expenses; and (b) number of employees. These figures were used to calculate the amount of
money the small business was eligible to receive under the PPP. In addition, businesses applying
for a PPP loan were required to provide documentation confirming their payroll expenses.

10. A PPP loan application was processed by a participating lender. If a PPP loan
application was approved, the participating lender funded the PPP loan using its own monies.
While it was the participating lender that issued the PPP loan, the loan was 100% 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 servers that processed the PPP loan applications for the SBA
were outside the state of Ohio, in the states of Virginia or Oregon.

11. PPP loan proceeds were required to be used by the business on certain permissible
expenses—-payroll costs, interest on mortgages, rent, and utilities. The PPP allowed the interest

and principal on the PPP loan to be entirely forgiven if the business spent the loan proceeds on
Case: 1:24-cr-00120-CAB Doc #:1 Filed: 04/03/24 4 of 18. PagelD #: 4

these expense items within a designated period of time and used a defined portion of the PPP
loan proceeds on payroll expenses.

Defendants, Person 1, Related Entities, and Banks

12. JOSEPH OLOYEDE (“OLOYEDE”) was a resident of Medina, Ohio.

OLOYEDE was the owner of the following entities incorporated in Ohio:

a. Available Tax Services Inc. (“Available Tax Service”);
b. Available Financial Corporation (“Available Financial”);
c. Available Transportation Company (“Available Transportation’);

d. Available Tutors Inc. (“Available Tutors”);
€. Joseph Oloyede & Associates Limited “JO&A”); and
f. Company 1, a non-profit entity.
13. Available Transportation, Available Tutors, JO&A, and Company | conducted
minimal business operations.
14. EDWARD OLUWASAMMI (““OLUWASANMI”) was a resident of Cleveland,
Ohio. OLUWASANMI was the owner of the following entities incorporated in Ohio:
a. Dayspring Transportation Limited (“Dayspring Transportation”);
b. Dayspring Holdings Inc. (“Dayspring Holdings”); and
c. Dayspring Property Inc (“Dayspring Property”).
15. Dayspring Holdings and Dayspring Property conducted minimal business
operations.
16. Person | was a resident of Medina, Ohio. Person 1 was associated with

Company 1.
Case: 1:24-cr-00120-CAB Doc #:1 Filed: 04/03/24 5o0f18. PagelD#: 5

17. Bank 1 was a financial institution based in Columbus, Ohio and an approved SBA
lender of PPP loans. OLOYEDE, OLUWASAMMIL, and Person 1 each owned and controlled
bank accounts at Bank 1, including the following:

a. OLOYEDE controlled bank accounts at Bank | in the name of Available
Tutors ending in 1545, in the name of Available Tax Services ending 2201, and an individual
account ending in 6944. OLOYEDE also controlled a bank account at Bank 1 in the name of
Company | ending in 5650 jointly with Person 1.

b. OLUWASANMI controlled bank accounts at Bank | in the name of
Dayspring Holdings ending in 9959, and in the name of Dayspring Property ending in 0058.

18. Bank 2 was a financial institution based in Minneapolis, Minnesota and an
approved SBA lender of PPP loans, and had bank branches Jocated in Ohio. OLOYEDE,
OLUWASANML, and Person | each owned and controlled bank accounts at Bank 2, including
the following:

a. OLOYEDE controlled bank accounts at Bank 2 in the name of Available
Transportation ending in 6285, and in the name of JO&A ending in 5823.

b. OLUWASAMMI controlled bank accounts at Bank 2 in the name of
Dayspring Transportation ending in 8658 and 8666.

C. Person | controlled an individual bank account at Bank 2 in the name of
Company 1| ending in 2369,

19. Bank 3 was a financial institution based in Pittsburgh, Pennsylvania and an
approved SBA lender of PPP loans, and with bank branches in Ohio. OLOYEDE controlled a

bank account at Bank 3 in the name of Available Tax Services ending in 9252, OLOYEDE also
Case: 1:24-cr-00120-CAB Doc #:1 Filed: 04/03/24 6 of 18. PagelD #: 6

controlled a bank account at Bank 3 in the name of Company 1 ending in 8024 jointly with
Person 1.

20. Bank 4 was a financial institution based in Providence, Rhode Island and an
approved SBA lender of PPP loans, and with bank branches in Ohio. OLOYEDE controlled a
bank account at Bank 4 in the name of Available Financial ending in 8828.

21. A summary of the relevant individuals, businesses, and bank accounts are

summarized in the below chart:

Account Holder Business Bank Account
OLOYEDE Available Tax Service Bank 1: x2201
Bank 3: x9252

Available Financial Bank 4: x8828

Available Transportation Bank 2: x6285

Available Tutors Bank 1: x1545

JO&A Bank 2: x5823

Company | Bank 1: x5650

Bank 3: x8024

Individual Account Bank 1: x6944

OLUWASANMI Dayspring Transportation Bank 2: x8658
Bank 2: x8666

Daysprings Holdings Bank 1: x9959

Dayspring Property Bank 1: x0058

Person | Individual Bank 2: x2369

COUNT 1

(Conspiracy to Commit Wire Fraud, 18 U.S.C. § 1349)
The Grand Jury charges:
22. The allegations contained in paragraphs 1 through 21 of this Indictment are
incorporated by reference as if stated fully herein.

The Conspiracy and Scheme to Defraud

23. From in or around April 2020, and continuing through on or about February 28,
2022, in the Northern District of Ohio, Eastern Division, and elsewhere, Defendants JOSEPH

OLOYEDE and EDWARD OLUWASANMI knowingly and intentionally combined, conspired,
Case: 1:24-cr-00120-CAB Doc #:1 Filed: 04/03/24 7 of 18. PagelD #: 7

and agreed with each other and with others known and unknown to the Grand Jury, to commit
federal fraud offenses, that is, to knowingly, and with the intent to defraud, 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, knowing that the
pretenses, representations, and promises were false and fraudulent when made, and, for the
purpose of executing the scheme and artifice, to knowingly transmit and cause to be transmitted,
by means of wire communication in interstate commerce, certain writings, signs, signals, pictures
and sounds, in violation of Title 18, United States Code, Section 1343.

Purposes of the Conspiracy and Scheme

24. The purposes of the scheme included, but were not limited to, the following: for
Defendants and their co-conspirators to unlawfully enrich themselves by, among other things:
(a) submitting, and causing to be submitted, false and fraudulent applications for loans and grants
made available through the SBA to provide relief for the economic effects caused by the
COVID-19 pandemic, including PPP and EIDL loans; (b) offering, paying, and receiving
kickbacks in return for the submission of false and fraudulent loan applications and supporting
documentation; and (c) diverting fraud proceeds for the Defendants’ and co-conspirators’
personal use, the use and benefit of others, and to further the conspiracy.

Manner and Means of the Conspiracy and Scheme

25. The manner and means by which Defendants and their co-conspirators carried out
the conspiracy and scheme included, but were not limited to, the following:
a. OLOYEDE, OLUWASANMI, Person 1, and other co-conspirators,
submitted and caused to be submitted PPP and EIDL loan applications containing false

information for entities under their control, including Available Tax Services, Available
Case: 1:24-cr-00120-CAB Doc #:1 Filed: 04/03/24 8 of 18. PagelD #: 8

Financial, Available Transportation, Available Tutors, JO&A, Company 1, Dayspring
Transportation, Dayspring Holdings, and Dayspring Property.

b. OLOYEDE assisted other co-conspirators and confederate borrowers who
submitted and caused to be submitted PPP and EIDL loan applications containing false
information for entities held by other co-conspirators and confederate borrowers.

C. OLOYEDE typically directed the co-conspirators and confederate
borrowers to create an account and PPP and EIDL loan application using online loan portals at
Banks 1 through 4 and the SBA.

d. OLOYEDE typically directed the co-conspirators and confederate
borrowers to provide him with the account username and password and any subsequent security
codes so he could submit the application and maintain account access throughout the loan
process,

e, OLOYEDE typically directed the co-conspirators and confederate
borrowers to forward all subsequent email correspondence regarding the loans to one of
OLOYEDE’s email accounts.

f. OLOYEDE and other co-conspirators and confederate borrowers created
PPP and EIDL loan applications that falsified the applicant entities’ operations and finances,
including the number of employees and the amount of monthly payroll related to PPP loans, and
gross revenue and cost of goods sold related to EIDL loans, to maximize loan approval amounts.

g. OLOYEDE and other co-conspirators and confederate borrowers caused
the fraudulent PPP applications to be submitted, typically through the online loan portals at
Banks 1 through Bank 4, and OLOYEDE coordinated the submission of fraudulent EIDL

applications through the SBA’s online loan portal.
Case: 1:24-cr-00120-CAB Doc #:1 Filed: 04/03/24 9 of 18. PagelD #: 9

h. OLOYEDE, OLUWASANMI, and other co-conspirators and confederate
borrowers submitted and caused to be submitted falsified documents to support the falsified
figures in the PPP and EIDL applications including the following tax and wage documents:
Internal Revenue Service (“IRS”) Forms 941 (“Employer’s Quarterly Federal Tax Return”), IRS
Form 940 (“Employer’s Annual Federal Unemployment Tax Return”), IRS Forms W-2 (“Wage
and Tax Statements”), IRS Forms W-3 (“Transmittal of Wage and Tax Statements”), and Ohio
Department of Job and Family Services (“ODJFS”) Quarterly Wage Reports.

i. OLOYEDE typically arranged with the co-conspirators and confederate
borrowers to receive a percentage of their PPP and EIDL loans as a fee, or kickback, for
obtaining the loan. These kickbacks were sent to OLOYEDE by the co-conspirators and
confederate borrowers via check or other means shortly after the PPP and EIDL loans were
funded.

Acts in Furtherance of the Conspiracy and Scheme to Defraud

26. In furtherance of the conspiracy, and to accomplish its object and purpose, in the
Northern District of Ohio, Eastern Division, and elsewhere, Defendants and their co-conspirators
committed and caused to be committed the following acts, among others:

PPP Loans — OLOYEDE & OLUWASANMI Businesses

a. On or about the dates listed below, OLOYEDE and OLUWASANMIL,
submitted and caused to be submitted, fraudulent PPP applications for their businesses through
Bank 1, Bank 2, Bank 3, and Bank 4, obtaining at least $685,222, including the following PPP
loan applications, to the following lenders, with funds directed to be deposited in accounts at the

following banks:
Case: 1:24-cr-00120-CAB Doc #:1 Filed: 04/03/24 10 of 18. PagelD #: 10

EIDL Advances and Loans— OLOYEDE & OLUWASANMI Businesses

On or about the dates listed below, OLOYEDE, OLUWASAMMIL, and

Person 1 submitted fraudulent EIDL loan applications, and applications for reconsideration, for

10
Case: 1:24-cr-00120-CAB Doc #:1 Filed: 04/03/24 11 of 18. PagelD #: 11

their businesses to SBA, obtaining at least $2,229,100, including the following applications, with

the following amounts obtained as a result of these fraudulent EIDL applications, with funds

directed to be deposited in accounts at the following banks:

Application / EIDL Applicant and Business Loan / Deposit
Reconsideration Advance Bank
Date Amount
April 8, 2020 OLOYEDE, Available Tax Services Declined N/A
May 14, 2020 OLOYEDE, Available Tutors $4,100 Bank 1
May 14, 2020 OLOYEDE, Available Tutors (Advance) $8,000 Bank |
June 20, 2020 OLOYEDE, Available Financial Declined N/A
June 20, 2020 OLOYEDE, Available Transportation Declined N/A
June 20, 2020 OLOYEDE, Available Transportation $10,000 Bank 2
(Advance)
June 20, 2020 OLOYEDE, Available Financial (Advance) $10,000 Bank 4
July 13, 2020 OLOYEDE, JO&A Declined N/A
July 16, 2020 Person 1, Company | $150,000 Bank 1
September 7, 2020 | OLUWASANMI, Dayspring Holdings $150,000 Bank |
September 7, 2020 | OLUWASANMI, Dayspring Property $139,000 Bank 1
May 19, 2021 OLUWASAMMI, Dayspring Holdings $350,000 Bank 1
(Increase)
May, 22, 2021 OLUWASANMI, Dayspring Property $361,000 Bank |
(increase)
June 14, 2021 OLOYEDE, JO&A (Advance) $10,000 Bank 2

11
Case: 1:24-cr-00120-CAB Doc #:1 Filed: 04/03/24 12 of 18. PagelD #: 12

Application / EDDL Applicant and Business Loan / Deposit
Reconsideration Advance Bank
Date Amount
June 14, 2021 OLOYEDE, JO&A (Advance) $5,000 Bank 2
June 17, 2021 OLUWASANMIL, Dayspring Property $5,000 Bank 1
(Advance)
June 17, 2021 OLUWASANMI, Dayspring Property $10,000 Bank 1
(Advance)
June 25, 2021 OLOYEDE, Available Transportation $5,000 Bank 2
(Advance)
July 3, 2021 OLOYEDE, Available Tutors (Advance) $2,000 Bank |
July 3, 2021 OLOYEDE, Available Tutors (Advance) $5,000 Bank 1
August 6, 2021 OLOYEDE, Available Financial (Advance) $5,000 Bank 4
October 7, 2021 OLOYEDE, JO&A (Reconsideration) $500,000 Bank 2
October 9, 2021 OLOYEDE, Available Transportation $500,000 Bank 2
(Reconsideration)

Cc.

PPP Loans — OLOYEDE “Clients”

On or about the dates listed below, OLOYEDE submitted and caused to be

submitted fraudulent PPP applications in the names of co-conspirators and confederate

borrowers and their businesses, through Bank 1, Bank 2, and Bank 3, obtaining at least

$724,956, including the following PPP loan applications, to the following lenders, with funds

directed to be deposited in accounts at the following banks:

Application Date PPP Applicant and Business Loan Lender Deposit
Amount Bank

July 27, 2020 Person 2, Company 2 $46,348 | Bank 2 Bank 2

July 31, 2020 Person 3, Company 3 $37,900 | Bank 3 Bank 3

12
Case: 1:24-cr-00120-CAB Doc #:1 Filed: 04/03/24 13 of 18. PagelD #: 13

Application Date PPP Applicant and Business Loan Lender Deposit
Amount Bank

August 3, 2020 Person 4, Company 4 $32,622 | Bank 2 Bank 2
August 4, 2020 Person 2, Company 10 $38,800 | Bank 3 Bank 3
August 7, 2020 Person 5, Company 5 $48,975 | Bank 2 ‘Bank 5
August 10, 2020 Person 6, Company 6 $40,000 | Bank 3 Bank 3
January 30,2021 | Person 7, Company 7 $58,255 | Bank 3 Bank 3
February 5, 2021 Person 2, Company 10 $38,800 | Bank 3 Bank 3
February 12,2021 | Person 3, Company 3 $37,900 | Bank 3 Bank 3
March 13, 2021 Person 2, Company 2 $46,348 | Bank 2 Bank 2
March 21, 2021 Person 6, Company 6 $40,000 | Bank 3 Bank 3
March 25, 2021 Person 6, Company 6 $48,975 | Bank 2 Bank 5
March 27, 2021 Person 7, Company 7 $58,255 | Bank 3 Bank 3
April 13, 2021 Person 4, Company 4 $32,622 | Bank 2 Bank 2
April 24, 2021 Person 8, Company 8 $48,722 | Bank 3 Bank 3
April 27, 2021 Person 9, Company 9 $70,435 | Bank 3 Bank 3°

EIDL Advances and Loans — OLOYEDE “Clients”

On or about the dates listed below, OLOYEDE submitted and caused to be

submitted fraudulent EIDL applications, and applications for reconsideration, in the names of co-

conspirators and confederate borrowers and their businesses, obtaining at least $574,100,

including the following applications, with the following amounts obtained as a result of these

fraudulent EIDL applications, with funds directed to be deposited in accounts at the following

banks:

13
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Application / EIDL Applicant and Business Loan / Advance Deposit
Reconsideration Amount Bank
Date
July 21, 2020 Person 2, Company 2 Declined N/A
September 13, 2020 | Person 2, Company 10 $44,100 Bank 3°
November 7, 2021 | Person 2, Company 2 $500,000 Bank 2
(Reconsideration)

June 17, 2021 Person 2, Company 2 (Advance) $5,000 Bank 2
June 17, 2021 Person 2, Company 10 (Advance) $10,000 Bank 3
June 17, 2021 Person 2, Company 2 (Advance) $10,000 Bank 2
June 17, 2021 Person 2, Company 10 (Advance) $5,000 Bank 3

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

COUNTS 2-10
(Wire Fraud, 18 U.S.C. §§ 1343 and 2)

The Grand Jury further charges:
27. The factual allegations of Count 1 of this Indictment are realleged and
incorporated by reference as if fully set forth herein.

The Scheme to Defraud

28. From in or around April 2020, and continuing through on or about February 28,
2022, in the Northern District of Ohio, Eastern Division, and elsewhere, Defendants JOSEPH
OLOYEDE and EDWARD OLUWASANML with the intent to defraud, did devise, and intend
to devise, a scheme and artifice to defraud, and to obtain money and property from the SBA and

participating PPP lenders by means of materially false and fraudulent pretenses, representations,

14
Case: 1:24-cr-00120-CAB Doc #:1 Filed: 04/03/24 15 o0f18. PagelD #: 15

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

fraudulent when made.

Purposes of the Scheme

29. The purposes of the scheme included, but were not limited to, the purposes
alleged in paragraph 24 of this Indictment.

Manner and Means of the Scheme

30. | The manner and means by which Defendants carried out the scheme included, but
were not limited to, the manner and means alleged in paragraph 25 of this Indictment.

Execution of the Scheme

31. On or about each of the dates set forth below, in the Northern District of Ohio,
Eastern Division, and elsewhere, the defendants identified below, for the purpose of executing
the scheme described above, and attempting to do so, transmitted, and caused to be transmitted,
by means of wire communication in interstate commerce the following writings, signs, signals,

pictures, and sounds, each transmission constituting a separate count of this Indictment:

Count Defendant Date Transmission Originating | Recipient and
Description Location Location
2 JOSEPH June 16, Electronic Ohio SBA, Virginia
OLOYEDE 2020 submission of PPP
loan application in
the name of
Available
Financial
3 JOSEPH September | Bank transfer from | Colorado OLUWASANMI,
OLOYEDE, 11,2020 | the SBA of Ohio
EDWARD $138,900 for EIDL
OLUWASANMI loan in the name of
Dayspring
Property
4 JOSEPH September | Bank transfer from | Colorado OLUWASANMI,
OLOYEDE, 11,2020 | the SBA of Ohio
$149,900 for EIDL

15
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Count Defendant Date Transmission Originating | Recipient and
Description Location Location
EDWARD loan in the name of
OLUWASANMI Dayspring
Holdings
5 JOSEPH August Bank transfer from | Colorado OLUWASANMI,
OLOYEDE, 12, 2021 the SBA of Ohio
EDWARD $350,000 for EIDL
OLUWASANMI loan in the name of
Dayspring
Holdings
6 EDWARD March 11, | In-person Ohio SBA, Oregon
OLUWASANMI | 2021 submission of PPP
loan application in
the name of
Dayspring
Property
7 JOSEPH April 20, | Electronic Ohio SBA, Oregon
OLOYEDE 2021 submission of PPP
loan application in
the name of
Available Tutors
8 JOSEPH August Bank transfer from | Colorado OLUWASAMMI,
OLOYEDE, 31, 2021 the SBA of Ohio
EDWARD $361,000 for EIDL
OLUWASANMI loan in the name of
Dayspring
Property
9 JOSEPH February | Bank transfer from | Colorado OLOYEDE, Ohio
OLOYEDE 15, 2022 the SBA of
$499,900 for EIDL
loan in the name of
JO&A
10 | JOSEPH February | Bank transfer from | Colorado OLOYEDE, Ohio
OLOYEDE 16, 2022 the SBA of
$499,900 for EIDL
loan in the name of
Available Trans

All in violation of Title 18, United State Code, Sections 1343 and 2.

16
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COUNTS 11-13

(Engaging in Monetary Transactions in Criminally Derived Property, 18 U.S.C. §§ 1957 and 2)

The Grand Jury further charges:

and incorporated by reference as if fully set forth herein.

32. The factual allegations of Counts | through 10 of this Indictment are realleged

33. On or about the dates listed below, in the Northern District of Ohio, Eastern

Division, and elsewhere, the defendants identified below did knowingly engage and attempt to

engage in the following monetary transaction by, though, and to a financial institution, affecting

interstate and foreign commerce, in criminally derived property of a value greater than $10,000,

such property having been derived from specified unlawful activity, to wit, Wire Fraud, in

violation of Title 18, United States Code, Section 1343, each transaction constituting a separate

count of this Indictment:

Count

Defendant

Date

Amount

Account

Transaction Description

EDWARD
OLUWASANMI

September
18, 2020

$221,880.40

Bank 1 —
x9975

Wire transfer to a title
agency for the purchase of
commercial property at
422 South Green Road,
South Euclid, Ohio

EDWARD
OLUWASANMI

October
26, 2021

$1,000,000

Bank 2 —
x8666

Wire transfer to a
Dayspring Transportation
brokerage account

JOSEPH
OLOYEDE

July 25,
2022

$24,473.62

Bank 4 —
x8828

OLOYEDE caused a
payment by check to be
issued to a general
contractor as payment for
the building of a residence
at 4641 Foote Rd.,
Medina, Ohio

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

17
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FORFEITURE
The Grand Jury further charges:

34. The allegations of Counts 1-13 of this Indictment are hereby re-alleged and
incorporated herein by reference for the purpose of alleging forfeiture pursuant to Title 18,
United States Code, Section 981(a)(1)(C), Title 18, United States Code, Section 982(a)(2), and
Title 28, United States Code, Section 2461(c) (wire fraud/wire fraud conspiracy offenses); and,
Title 18, United States Code, Section 982(a)(1) (money laundering offenses). As a result of the
foregoing offenses, defendants JOSEPH OLOYEDE and EDWARD OLUWASANMI shall
forfeit to the United States: all property, real and personal, which constitutes—or is derived
from—proceeds traceable to the commission of the wire fraud/wire fraud conspiracy offenses; all
property constituting, or derived from, proceeds the defendants obtained, directly or indirectly, as
the result of the wire fraud/wire fraud conspiracy offenses; and, any and all property, real and
personal, involved in the money laundering offenses, and any property traceable to such
property; including, but not limited to:

a. The real property located at 422 South Green Road, South Euclid,
Cuyahoga County, Ohio; Permanent Parcel Nos. 701-13-064, 701-13-065, 701-13-066, and 701-
13-123. The property was purchased in or around September 2020. The property is titled to
Dayspring Property Incorporated and associated with EDWARD OLUWASAMMI.

b. The real property located at 4641 Foote Road, Medina, Medina County,
Ohio; Parcel No. 026-06D-21-105. The property was purchased in or around May 2021, and is
associated with JOSEPH OLOYEDE.

A TRUE BILL.

Original document - Signatures on file with the Clerk of Courts, pursuant to the E-Government Act
of 2002.

File and source

File: 1-indictment.pdf
Size: 545,257 bytes
SHA-256: 611570e146928c36842990e615bc27f38db592fbc87cc26af5ab28af2bc73b6e
Our copy: 1-indictment.pdf
Original: archive.org