Indictment — United States v. Brian Manley and Lacole Manley, Eastern District of Virginia (Document 1)

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A grand jury indictment of Brian Manley and Lacole Manley, Case No. 2:24-cr-00056-AWA-LRL, in the U.S. District Court for the Eastern District of Virginia, filed June 5, 2024 as Document 1. Counts One and Two charge money laundering under Title 18, United States Code, Section 1956(a)(1)(B)(i) and 2. It alleges that Manley Enterprises, Inc., of which Brian Manley was Director, and Lashed by Lynn, Inc., of which Lacole Manley was Director, each fraudulently applied for a PPP loan, and that Cross River Bank wired approximately $350,000 to Brian Manley's bank account on or about May 27, 2020 and Celtic Bank wired approximately $350,000 to Lacole Manley's account on or about June 5, 2020. The charged transactions are a $350,000 transfer on or about May 27, 2020 and a $200,000 transfer on or about June 12, 2020, and the forfeiture section lists a Land Rover Range Rover Velar.

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Case 2:24-cr-00056-AWA-LRL Document1 Filed 06/05/24 Page 1 of 5 PagelD# 1

FILED
—__IN OPE
IN THE UNITED STATES DISTRICT COURT N.COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Norfolk Division
CLERK, U.S. DISTRICT COURT
UNITED STATES OF AMERICA ) NORFOLK, VA
) CRIMINAL NO. 2:24cr Ble
V. )
) 18 U.S.C. 1956(a)(1)(B)G)
BRIAN MANLEY, ) Money Laundering
(Count 1) ) (Counts 1-2)
)
and ) 18 U.S.C. § 982(a)(1)
) Forfeiture
LACOLE MANLEY )
(Count 2) )
)
Defendants )
)
)
INDICTMENT

June 2024 Term — at Norfolk, Virginia
THE GRAND JURY CHARGES THAT:
GENERAL ALLEGATIONS

At all relevant times:

1. Manley Enterprises, Inc. was incorporated with the Commonwealth of Virginia.
Defendant BRIAN MANLEY was Director of Manley Enterprises Inc.

ans On or about May 25, 2020, Manley Enterprises, Inc. fraudulently applied for a
Paycheck Protection Program loan.

3: As a result of this application, on or about May 27, 2020, Cross River Bank wired
approximately $350,000 to BRIAN MANLEY’s bank account.

4. Lashed by Lynn, Inc. was incorporated with the Commonwealth of Virginia.

Defendant LACOLE MANLEY was Director of Lashed by Lynn, Inc.
Case 2:24-cr-00056-AWA-LRL Document 1 Filed 06/05/24 Page 2 of 5 PagelD# 2

5. On or about June 4, 2020, Lashed by Lynn, Inc. fraudulently applied for a
Paycheck Protection Program loan.
6. As a result of this application, on or about June 5, 2020, Celtic Bank wired

approximately $350,000 to LACOLE MANLEY’s bank account.

COUNT ONE
(Money Laundering)

7. The General Allegations of this Indictment are realleged and incorporated as if
fully set forth herein.

8. On or about May 27, 2020, in the Eastern District of Virginia and elsewhere,
defendant BRIAN MANLEY did knowingly conduct and attempt to conduct a financial
transaction affecting interstate and foreign commerce, to wit, a transfer of $350,000 from a bank
account ending in -1619 to a bank account ending in -0621, which involved the proceeds of a
specified unlawful activity, that is, Wire Fraud and Bank Fraud, knowing (i) that the transaction
was designed in whole and in part to conceal and disguise the nature, location, source, ownership,
and control of the proceeds of specified unlawful activity and (ii) that the property involved in the
financial transaction represented the proceeds of some form of said unlawful activity.

(In violation of Title 18, United States Code, Section 1956(a)(1)(B)(i) and 2.)

COUNT TWO
(Money Laundering)

9. The General Allegations of this Indictment are realleged and incorporated as if
fully set forth herein.

10. On or about June 12, 2020, in the Eastern District of Virginia and elsewhere,
defendant LACOLE MANLEY did knowingly conduct and attempt to conduct a financial
transaction affecting interstate and foreign commerce, to wit, a transfer of $200,000 from a bank

account ending in -1892 to another account ending in -1783, which involved the proceeds of a

2
Case 2:24-cr-00056-AWA-LRL Document1 Filed 06/05/24 Page 3 of 5 PagelD# 3

specified unlawful activity, that is, Wire Fraud and Bank Fraud, knowing (i) that the transaction
was designed in whole and in part to conceal and disguise the nature, location, source, ownership,
and control of the proceeds of specified unlawful activity and (ii) that the property involved in the

financial transaction represented the proceeds of some form of said unlawful activity.

(In violation of Title 18, United States Code, Section 1956(a)(1)(B)(i) and 2.)
Case 2:24-cr-00056-AWA-LRL Document 1 Filed 06/05/24 Page 4 of 5 PagelD# 4

FORFEITURE

THE GRAND JURY FURTHER FINDS PROBABLE CAUSE THAT:

1. The defendants, if convicted of either of the violations alleged in this indictment,
shall forfeit to the United States, as part of the sentencing pursuant to Federal Rule of Criminal
Procedure 32.2, any property, real or personal, involved in the violation, or any property traceable
to that property.

2. If any property that is subject to forfeiture above is not available, it is the intention
of the United States to seek an order forfeiting substitute assets pursuant to Title 21, United States
Code, Section 853(p) and Federal Rule of Criminal Procedure 32.2(e).

3. The assets subject to forfeiture include, but are not limited to:

i. a Land Rover Range Rover “Velar” (bearing vehicle identification number
SALYK2EX6LA239039)

(In accordance with Title 18, United States Code, Section 982(a)(1).)
Case 2:24-cr-00056-AWA-LRL Document 1 Filed 06/05/24 Page 5 of 5 PagelD# 5

United States v. Brian Manley and Lacole Manley, Criminal No. 2:24cr Qo

JESSICA D. ABER
UNITED STATES ATTORNEY

United States Attorney’s Office
101 West Main Street, Suite 8000
Norfolk, VA 23510
757-441-6331 Office
757-441-6689 Fax

anthony.mozzi@usdoj. gov

By:

Pursunt to the E-Government Act,
Use criginal of this page hes been filed
under seal in the Clerk's Office

A TRUE BILL:
REDACTED COPY

FOREPERSON


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