Indictment — No. 2:22-cr-00344 (Dkt. 1, E.D.N.Y.)
Summary
An indictment filed July 27, 2022 as Document 1 in United States v. Rami Saab, also known as "Rami Hasan", Cr. No. 22-344 (Case 2:22-cr-00344-GRB), in the U.S. District Court for the Eastern District of New York. The introduction describes the COVID-19 pandemic and the Paycheck Protection Program, and alleges a scheme between about June 1, 2020 and May 31, 2021 involving at least six online PPP loan applications for entities associated with the defendant. Count One is captioned Disaster Relief Fraud, Count Two False Statements to the Small Business Administration, Count Three Conspiracy to Commit Wire Fraud, Count Four Wire Fraud and Count Five Conspiracy to Commit Money Laundering, followed by forfeiture allegations.
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“Indictment — No. 2:22-cr-00344 (Dkt. 1, E.D.N.Y.).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-2-22-cr-00344-dkt-1-e-d-n-y-9debba8beb/
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Case 2:22-cr-00344-GRB Document 1 Filed 07/27/22 Page 1 of 9 PageID #: 1
F L ED
.. IN CLERK'S OFFICE
U.S. DISTRICT COURT E.D.N.Y.
CCC:MRM * JUL 17 2022 ★
F.#2020R00902
LONG island office
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
X
UNITED STATES OF AMERICA INDICTMENT
- against - Cr.No r, R 22 3 4 4
(T. 18,U,S.C., §§ 981(a)(1)(C),^82(a)(l),
RAMISAAB, 982(b)(1), 1014,1040(a)(2), lOfl0(b)(1),
also known as "Rami Hasan," 1343, 1349, 1956(h),2 and 35511 et seq.:
T.21,U.S.C.,§ 853(p); T. 28, U S.C., §
Defendant, 2461(c))
X
THE GRAND JURY CHARGES:
INTRODUCTION
At all times relevant to this Indictment, unless otherwise indi\fifl£^KS, M.J.
The COVID-19 Pandemic in the United States
1. In or about December 2019, a novel coronavirus, SARS-CoV-2(the
"coronavirus") caused outbreaks ofthe coronavirus disease COVID-19 that spread globally. On
or about January 31,2020, the Secretary of Health and Human Services declared a nation U
public health emergency under 42 U.S.C. § 247d as a result ofthe spread of COVID-19 to and
within the United States. On or about March 11,2020,the Director-General ofthe World
Health Organization characterized COVID-19 as a pandemic. On or about March 13, 2020,the
President ofthe United States issued Proclamation 9994 declaring a national emergency
beginning on March 1,2020, as a result ofthe rapid spread of COVID-19 within the United
States.
Case 2:22-cr-00344-GRB Document 1 Filed 07/27/22 Page 2 of 9 PageID #: 2
The Paycheck Protection Program
2. On or about March 27,2020,the President signed into law the
Coronavirus Aid, Relief, and Economic Security("CARES")Act. The CARES Act was a
federal law designed to provide emergency financial assistance to the millions of Ameri(;ans who
were suffering the economic effects caused by the COVID-19 pandemic. One source of relief
provided by the CARES Act was the authorization of up to $349 billion in forgivable loans to
small businesses forjob retention and certain other expenses, through a program referred to as
the Paycheck Protection Program ("PPP"). In or around April 2020, Congress authorized over
$300 billion in additional PPP funding.
3. To obtain a PPP loan, qualifying businesses were required to submit a PPP
loan application, which was signed by an authorized representative ofthe business. The PPP
loan application required recipient businesses, through an authorized representative, to
acknowledge the program rules and make certain affirmative certifications to establish eligibility
for the PPP loan. For example,in the PPP loan application, recipient businesses, through an
authorized representative, were required to state, among other things, their average monthly
payroll expenses and number ofemployees. These figures were used to calculate the amount of
money the businesses were eligible to receive under the PPP. The recipient businesses were
also required to provide documentation supporting the information contained in the PPP loan
application.
4. PPP loan proceeds were required to be used by the recipient businesses on
certain permissible expenses,to wit: payroll costs, interest on mortgages, rent and utilities, The
PPP allowed the interest and principal on a PPP loan to be entirely forgiven if the recipient
Case 2:22-cr-00344-GRB Document 1 Filed 07/27/22 Page 3 of 9 PageID #: 3
businesses spent the loan proceeds on these expense items within a designated period offime
after receiving the proceeds and used a certain percentage for payroll costs.
5. The PPP was overseen by the Small Business Administration("SBA"),
which had authority over all PPP loans. Individual PPP loans, however, were issued and
approved by private lenders, which received and processed PPP loan applications and supporting
documentation and,following SBA approval, made loans using the lenders' own funds.
The Defendant and His Fraud Scheme
6. The defendant RAMI SAAB,also known as "Rami Hasan," was a resident
of Glen Cove,New York. SAAB was associated with numerous corporate entities (the 'jSubject
Entities"), through which he committed the fraud described herein.
7. On or about and between June 1,2020 and May 31,2021, both dates being
approximate and inclusive, the defendant RAMI SAAB engaged in a scheme to defraud tpe SBA
and several financial institutions administering the PPP program offederal COVID-19
emergency relieffunds meant for distressed small businesses. It was a part ofthe schema to
defraud that SAAB submitted, or caused to be submitted, at least six online loan applications to
obtain funds through the PPP programs for the Subject Entities. It was further a part ofthe
scheme to defraud that these loan applications and certain supporting documentation contained
materially false and fraudulent information, including, but not limited to, the Subject Entities'
number ofemployees, payroll costs and intended use ofthe loan proceeds, all of which W£.s
specifically designed to mislead the SBA and financial institutions administering the PPP
program into disbursing various loans, which they did.
8. In total, on or about and between June 1,2020 and May 31, 2021, both
dates being approximate and inclusive, as a result of this fraudulent scheme,the SBA and
Case 2:22-cr-00344-GRB Document 1 Filed 07/27/22 Page 4 of 9 PageID #: 4
4
financial institutions administering the PPP programs wire-transferred sums totaling
approximately $3,593,290 in PPP loans for the Subject Entities to bank accounts that the
defendant KAMI SAAB had access to and control over at bank branches in the Eastern district
of New York and elsewhere.
9. Shortly after receiving these loan proceeds,the defendant RAM SAAB,
together with others, engaged in numerous financial transactions designed to conceal the^e
nature and source ofthe funds, including electronically transferring certain ofthe loan proceeds
between various bank accounts to which SAAB had access and control. SAAB then util ized the
laundered loan proceeds to enrich himself and others, including by personally making cash
withdrawals and transferring funds to associates overseas.
COUNT ONE
(Disaster ReliefFraud)
10. The allegations contained in paragraphs one through nine are realleged
and incorporated as iffully set forth in this paragraph.
11. On or about and between June 1,2020 and May 31,2021, both dates being
approximate and inclusive, within the Eastem District ofNew York and elsewhere,the defendant
RAM SAAB,also known as "Rami Hasan," together with others, did knowingly and
intentionally make one or more materially false, fictitious, and fraudulent statements and
representations, and make and use one or more false writings and documents knowing the same
to contain materially false, fictitious, and jfraudulent statements and representations, in
coimection with a procurement of property and services related to an emergency declaration
under Section 501 ofthe Stafford Act, to wit: Proclamation 9994 of March 13,2020 by the
President ofthe United States of America Declaring a National Emergency Concerning a Novel
Case 2:22-cr-00344-GRB Document 1 Filed 07/27/22 Page 5 of 9 PageID #: 5
Coronavirus Disease(COVID-19) Outbreak, which benefits were authorized, transported
transmitted, transferred, disbursed and paid in and affecting interstate and foreign commerce.
(Title 18, United States Code, Sections 1040(a)(2), 1040(b)(1),2 and
3551 et seq.)
COUNT TWO
(False Statements to the Small Business Administration)
12. The allegations contained in paragraphs one through nine are reallpged
and'incorporated as iffully set forth in this paragraph.
13. On or about and between June 1,2020 and May 31,2021, both da^es being
approximate and inclusive, within the Eastern District ofNew York and elsewhere,the defendant
KAMI SAAB,also known as"Kami Hasan," together with others, did knowingly make c(ne or
more false statements and reports for the purpose of influencing the action ofthe SBA in
connection with an application, advance, discount, purchase, purchase agreement,repurchase
agreement, commitment, loan and insurance agreement and application for insurance and
guarantee, and any change and extension ofany ofthe same, by renewal, deferment of action or
otherwise, and the acceptance, release and substitution of security therefor, to wit: SAAB
provided false information in fraudulent PPP loan applications to induce the SBA to approve
loans to the Subject Entities.
(Title 18, United States Code, Sections 1014,2 and 3551 et seq.'l
COUNT THREE
(Conspiracy to Commit Wire Fraud)
14. The allegations contained in paragraphs one through nine are realleged and
incorporated as iffully set forth in this paragraph.
Case 2:22-cr-00344-GRB Document 1 Filed 07/27/22 Page 6 of 9 PageID #: 6
15. On or about and between June 1,2020 and May 31,2021, both dal es being
approximate and inclusive, within the Eastern District ofNew York and elsewhere, the defendant
KAMI SAAB,also known as "Rami Hasan," together with others, did knowingly and
intentionally conspire to devise a scheme and artifice to defraud the SBA and several fm£tncial
institutions administering the PPP program offederal COVTD-19 emergency relieffunds meant
for distressed small businesses, and to obtain money and property from the SBA and the
financial institutions by means of materially false and fraudulent pretenses, representations and
promises,and for the purpose ofexecuting such scheme and artifice, to transmit and caus(; to be
transmitted by means of wire communication in interstate and foreign conimerce, writingsj, signs,
signals, pictures and sounds, contrary to Title 18, United States Code, Section 1343.
(Title 18, United States Code, Sections 1349 and 3551 et seq.")
COUNT FOUR
(Wire Fraud)
16. The allegations contained in paragraphs one through nine axQ realle^ed
and incoiporated as iffully set forth in this paragraph.
17. On or about and between June 1,2020 and May 31,2021, both datep being
approximate and inclusive, within the Eastern District ofNew York and elsewhere, the defendant
RAMI SAAB,also known as "Rami Hasan," together with others, did knowingly and
intentionally devise a scheme and artifice to defraud the SBA and several financial institutions
administering the PPP program, and to obtain money and property from the SBA and the
financial institutions, by means of one or more materially false and fraudulent pretenses,
representations and promises, and for the purpose of executing such scheme and artifice did
transmit and cause to be transmitted, by means of wire communication in interstate commerce.
Case 2:22-cr-00344-GRB Document 1 Filed 07/27/22 Page 7 of 9 PageID #: 7
one or more writings, signs, signals and pictures, to wit: an electronic transmission offraudulent
PPP loan applications and falsified supporting documents for the Subject Entities.
(Title 18, United States Code, Sections 1343,2 and 3551 et seq.)
COUNT FIVE
(Conspiracy to Commit Money Laundering)
18. The allegations contained in paragraphs one through nine are reall^ged and
incorporated as iffully set forth in this paragraph.
19. On or about and between June 1,2020 and May 31,2021, both dalles being
approximate and inclusive, within the Eastern District ofNew York and elsewhere,the defendant
RAMI SAAB,also known as "Rami Hasan," together with others, did knowingly and
intentionally conspire to conduct one or more financial transactions in and affecting interstate
and foreign commerce,including deposits, transfers and withdrawals offunds and monetJiry
instruments, which in fact involved the proceeds ofspecified unlawful activity, to wit: wire fraud,
in violation of Title 18, United States Code,Section 1343, knowing that the property involved in
the financial transactions represented the proceeds ofsome form of unlawful activity, and
knowing that the transactions were designed in whole and in part to conceal and disguise the
nature, location, source, ownership and control ofthe proceeds of specified unlawful actiVity,
contrary to Title 18, United States Code, Section 1956(a)(l)(B)(i).
(Title 18, United States Code, Sections 1956(h)and 3551 ^seg.l
CRIMINAL FORFEITURE ALLEGATION
AS TO COUNTS TWO THROUGH FOUR
20. The United States hereby gives notice to the defendant that, upon his
conviction ofany ofthe offenses charged in Count Two through Count Four,the govemmjent
will seek forfeiture in accordance with Title 18, United States Code,Section 981(a)(1)(C)hnd
Case 2:22-cr-00344-GRB Document 1 Filed 07/27/22 Page 8 of 9 PageID #: 8
Title 28, United States Code, Section 2461(c), which require any person convicted of such
offenses to forfeit any property, real or personal, constituting, or derived from,proceeds obtained
directly or indirectly as a result ofsuch offenses.
21. Ifany ofthe above-described forfeitable property, as a result of aqy act or
omission ofthe defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a third party;
(c) has been placed beyond the jurisdiction ofthe court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which cannot be divided
without difficulty;
it is the intent ofthe United States, pursuant to Title 21, United States Code, Section 853(p), to
seek forfeiture of any other property ofthe defendant up to the value ofthe forfeitable prcjperty
described in this forfeiture allegation.
(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))
CRIMINAL FORFEITURE ALLEGATION
AS TO COUNT FIVE
22. The United States hereby gives notice to the defendant that, upon his
conviction ofthe offense charged in Count Five, the government will seek forfeiture in
accordance with Title 18, United States Code, Section 982(a)(1), which requires any person
convicted ofsuch offense to forfeit any property, real or personal, involved in such offense^ or
any property traceable to such property
Case 2:22-cr-00344-GRB Document 1 Filed 07/27/22 Page 9 of 9 PageID #: 9
23. If any ofthe above-described forfeitable property, as a result ofan]^ act or
omission ofthe defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a third party;
(c) has been placed beyond the jurisdiction ofthe court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which cannot be
divided without difficulty;
it is the intent ofthe United States, pursuant to Title 21, United States Code, Section 853(b), as
incorporated by Title 18, United States Code, Section 982(b)(1), to seek forfeiture ofany other
property ofthe defendant up to the value ofthe forfeitable property described in this forfeiture
allegation.
(Title 18, United States Code,Sections 982(a)(1) and 982(b)(1); Title 21, Upited
States Code, Section 853(p))
A TRUE BILL
FOREP^Rsoij;^^;:;:::::^
BREON PEACE
UNITED STATES ATTORNEY
EASTERN DISTRICT OF NEW YORK
By:
Assistant U.S. Attomey
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