Indictment — United States v. Ricardo Santiago, District of Connecticut (Document 1)

Summary

An indictment in United States of America v. Ricardo Santiago, Case 3:24-cr-00097-VDO, in the U.S. District Court for the District of Connecticut, filed May 1, 2024 as Document 1. Counts One Through Three charge wire fraud under 18 U.S.C. § 1343. The grand jury alleges that from about April 8, 2002 through about April 30, 2024 Santiago concealed employment income exceeding $500,000 from the Social Security Administration, the Connecticut Department of Labor and the Connecticut Department of Social Services. It alleges that Santiago received Retirement Survivors Disability Insurance payments totaling more than $300,000, SNAP benefits totaling more than $17,000, and unemployment insurance benefits totaling more than $30,000 between about April 1, 2020 and about February 1, 2021. The forfeiture allegation seeks a sum of money equal to the proceeds.

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“Indictment — United States v. Ricardo Santiago, District of Connecticut (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-3-24-cr-00097-dkt-1-d-conn-2ac427578a/, SHA-256 890857d2d2b800bde2e606a9c24d27893cb0173fa44229b608c7547aa627e814.

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Case 3:24-cr-00097-VDO Document 1 Filed 05/01/24 Page 1 of 10

UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT

GRAND mRY H-24-1

UNITED STATES OF AMERICA CRIMINAL NO. 3:24CR °17 (voo)(SW)

V.
VIOLATIONS:
RICARDO SANTIAGO
18 U.S.C. § 1343
(Wire Fraud)

INDICTMENT

The Grand Jury charges:

COUNTS ONE THROUGH THREE
(Wire Fraud)

Introduction

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

1. The defendant RICARDO SANTIAGO ("SANTIAGO") resided m Hartford,

Connecticut.

2. Achieve Financial Credit Union was a National Credit Union Administration

insured credit union headquartered in Berlin, Connecticut and has branch locations in New Britain,

Connecticut and Meriden, Connecticut. Since at least November 1, 2016, SANTIAGO has

maintained an account at Achieve Financial Credit Union with an account number ending -7029.

The Retirement Survivors Disability Insurance Program

3. The Social Security Administration ("SSA"), an agency of the United States,

administers certain government benefit programs, including the Retirement Survivors Disability

Insurance ("RSDI") program.
Case 3:24-cr-00097-VDO Document 1 Filed 05/01/24 Page 2 of 10

4. RSDI is a federally funded program for qualified individuals with a disability that

prevents them from maintaining their prior employment or any employment in the national

economy.

5. SSA regulations require RSDI recipients to report accurately their employment

status, disability status, and income so that the SSA can determine if they are disabled within the

meaning of SSA regulations and unable to engage in any substantial gainful employment.

6. The SSA performs a periodic review of eligibility ofRSDI recipients for continued

RSDI benefits, refe1Ted to as a continuing disability review ("CDR"). As part of the CDR,

recipients of RSDI benefits are required to submit a Disability Update Report on Form SSA-455,

on which RSDI recipients must confirm and/or supply information to establish their continued

eligibility for benefits. The Form SSA-455 requires RSDI recipients to report, among other things,

any changes in employment, health, and disability status.

7. Statements in an application for RSDI benefits or as part of the CDR are made

under penalty of pe1jury. The initial application form contains a warning to the effect that anyone

making a false statement or representation of a material fact for use in determining the right to

payment commits a crime. Similarly, the CDR Form SSA-455 contains a warning to the effect that

anyone who knowingly gives a false or misleading statement about a material fact in a statement

or redetermination statement, or causes someone else to do so, commits a crime.

8. The United States Department of the Treasury, which is headquartered m

Washington, D.C. makes payments to RSDI recipients on behalf of the SSA.

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Case 3:24-cr-00097-VDO Document 1 Filed 05/01/24 Page 3 of 10

The Supplemental Nutrition Assistance Program

9. The United States Depmiment of Agriculture ("USDA"), an agency of the United

States, through the USDA's Food and Nutrition Service, provides funding for the Supplemental

Nutrition Assistance Program ("SNAP"), formerly known as the federal Food Stamp Program, and

shares the cost of administering the SNAP program with state pminers. The SNAP program

provides lower-income households with financial assistance to buy food. Eligibility for SNAP

benefits is based on income, resources, and the number of individuals in a household.

10. In Connecticut, the USDA provides funding for SNAP benefits and administration,

while the Connecticut Department of Social Services ("CT-DSS") administers the program in

accordance with federal requirements.

11. SNAP beneficiaries receive their benefits through an Electronic Benefit Transfer

("EBT") card, which is provided once their eligibility is established. Each EBT card is credited

with a dollar amount of benefits for each month. The EBT card can be used to directly purchase

food from certain retailers.

12. To obtain SNAP benefits in Connecticut, an applicant must complete an initial

application and interview, through which they must disclose all income from work and other

sources. Periodically thereafter, beneficiaries must complete a Form W-1 ER to establish their

continued eligibility for benefits, including disclosing any changes in their income. Statements

made in an application for SNAP benefits or on Form W-lER are made under penalty of perjury

and contain warnings to the effect that anyone who knowingly gives a false or misleading

statement about a material fact commits a crime.

13. At all times relevant to this Indictment, the financial institution contracted in

Connecticut for the SNAP EBT program was Conduent, Inc., which is headquaiiered in Florham

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Case 3:24-cr-00097-VDO Document 1 Filed 05/01/24 Page 4 of 10

Park, New Jersey and used a data center located in Sandy, Utah to house individual cardholder

transaction data and make daily settlement payments to retailers in Connecticut.

The Unemployment Insurance Program

14. The United States Depaiiment of Labor ("USDOL"), an agency of the United

States, oversees the federal-state Unemployment Insurance ("UI") program. The UI program

provides financial assistance to individuals who are out of work through no fault of their own. The

funding for unemployment benefits comes from taxes paid by employers.

15. In Connecticut, the UI program is administered by the Connecticut Department of

Labor ("CT-DOL") in partnership with the USDOL. Eligibility for UI benefits is determined based

on an individual's self-reported employment history, current employment status, and availability

for work.

16. To receive UI benefits in Connecticut, an individual must complete an initial

application. To maintain benefits, beneficiaries must complete weekly certifications to confirm or

update their employment status and availability for work. Statements made as part of the weekly

certifications are made under penalty of perjury and contain warnings to the effect that anyone

who knowingly gives a false or misleading statement about a material fact in a weekly certification

statement commits a crime. An individual can elect to have their unemployment benefits directly

deposited to a bank account or debit card.

17. In order to directly deposit unemployment benefits to a recipient's bank account or

debit card, CT-DOL electronically transmits a payment file from servers in Connecticut to JP

Morgan Chase, a financial institution whose servers are located outside of Connecticut. The

payment file contains information about how much money should be deposited to a recipient's

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Case 3:24-cr-00097-VDO Document 1 Filed 05/01/24 Page 5 of 10

bank account or debit card. Upon receiving the payment file, JP Morgan Chase initiates a direct

deposit into the UI beneficiary's bank account or debit card.

The Scheme and Artifice to Defraud

18. From on or about April 8, 2002 and continuing through on or about April 30, 2024,

the exact dates being unknown to the Grand Jury, SANTIAGO devised and intended to devise a

scheme and artifice to defraud and to obtain money and property from the SSA, USDOL, CT-

DOL, USDA, and CT-DSS (collectively, the "Agencies") in the form of RSDI, UI, and SNAP

benefits by means of materially false and fraudulent pretenses and representations, including by

omissions of material facts. Specifically, SANTIAGO concealed or failed to accurately report his

income and employment status to the Agencies, thereby obtaining RSDI, UI, and SNAP benefits

to which he was not entitled.

19. As part of the scheme and artifice, SANTIAGO held jobs with numerous

employers, whose identities are known and unknown to the Grand Jury, between April 8, 2002,

and April 30, 2024, earning income from these employers exceeding $500,000, but he provided

false identification information and documents to his employers to conceal this employment

income from the Agencies. For example:

a. On multiple occasions, SANTIAGO obtained employment but reported to

employers a Social Security Number belonging to another individual whose identity is known to

the Grand Jury ("Individual 1").

b. On at least one occasion, SANTIAGO provided a falsified Social Security

Card to an employer as paii of his application for employment, which card showed SANTIAGO's

own name with the Social Security Number belonging to Individual 1.

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Case 3:24-cr-00097-VDO Document 1 Filed 05/01/24 Page 6 of 10

c. On at least one occasion, SANTIAGO submitted a valid Social Security

Card belonging to Individual 1 to an employer as if it was his own.

20. It was further part of the scheme and artifice that SANTIAGO provided materially

false info1mation and failed to disclose material information to the SSA to fraudulently obtain

RSDI benefits:

a. On or about April 8, 2002, SANTIAGO applied for RSDI. Based on his

application, the SSA approved SANTIAGO for RSDI and determined that he first became disabled

on March 28, 2002. The SSA determined that SANTIAGO was disabled for five consecutive

calendar months, and he began receiving monthly RSDI benefits in or around September 2002. As

part of his initial application for RSDI benefits, SANTIAGO agreed to inform the SSA of any

change in his medical condition that would allow him to return to work, or ifhe actually did return

to work, either as an employee or a self-employed person.

b. On or about October 13, 2017, SANTIAGO completed Form SSA-455. On

that form, he represented that his health condition had worsened over the past two years and that

he had not been employed between October 2015 and October 2017. Based on SANTIAGO' s

representations on Form SSA-455, the SSA deferred SANTIAGO's CDR by automated review,

and his RSDI benefits continued.

c. From on or about April 8, 2002, through on or about April 30, 2024,

SANTIAGO failed to disclose to the SSA his employment and income, as set forth above.

d. As a result of these material misstatements and omissions, SANTIAGO

received monthly RSDI payments for which he was not eligible from the SSA totaling more than

$300,000. Since November 1, 2016, SANTIAGO received his monthly RSDI payments as direct

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Case 3:24-cr-00097-VDO Document 1 Filed 05/01/24 Page 7 of 10

deposits from the United States Department of the Treasury into his Achieve Financial Credit

Union account ending -7029.

21. It was fmiher part of the scheme and artifice that SANTIAGO provided materially

false info1mation and failed to disclose material information to the CT-DSS to fraudulently obtain

SNAP benefits:

a. On or about February 28, 2017, SANTIAGO submitted to the CT-DSS his

application for SNAP benefits. As paii of his application, SANTIAGO represented that he had no

earned income from employment. As a result, the CT-DSS dete1mined that he was eligible for

benefits based on the representations on his application. He received an EBT card and began using

it for purchases on or about March 5, 2017.

b. To renew his SNAP benefits, SANTIAGO completed multiple Forms W-

IER on which he failed to report any income from employment, and he continued to receive SNAP

benefits through on or about April 30, 2024.

c. In truth and in fact, as SANTIAGO well knew, SANTIAGO was gainfully

employed when he submitted his application for SNAP benefits on or about February 28, 2017,

and he earned significant income from employment between on or about February 28, 2017 and

on or about April 30, 2024. Had SANTIAGO accurately reported his income, he would not have

been eligible to obtain and renew his SNAP benefits.

d. As a result of these material misstatements and omissions, between on or

about March 5, 2017 and on or about April 30, 2024, SANTIAGO obtained SNAP benefits for

which he was not eligible totaling more than $17,000.

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Case 3:24-cr-00097-VDO Document 1 Filed 05/01/24 Page 8 of 10

22. It was further part of the scheme and artifice that SANTIAGO provided materially

false information and failed to disclose material information to the CT-DOL to fraudulently obtain

UI benefits:

a. On or about April 1, 2020, SANTIAGO applied for UI benefits through the

CT-DOL. On his application, SANTIAGO provided a false Social Security Number, which

number was associated with Individual 1. Further, on the same application, SANTIAGO reported

that he was unemployed but available for work and physically able to work. The CT-DOL

determined that SANTIAGO was eligible for UI benefits, and he began receiving weekly payments

on or about April 4, 2020.

b. To continue rece1vmg UI benefits, SANTIAGO completed weekly

certifications. On each weekly certification, SANTIAGO again provided a false Social Security

Number, which number was in fact associated with Individual 1. SANTIAGO further affirmed

that he had not completed any work, including self-employment. Based on these weekly

certifications, SANTIAGO continued to receive UI benefits until on or about February 1, 2021.

c. In truth and in fact, as SANTIAGO well knew, SANTIAGO was gainfully

employed when he submitted his application for UI benefits on or about April 1, 2020, and he

earned significant income from employment between on or about April 1, 2020 and on or about

February 1, 2021. Had SANTIAGO accurately reported his income, he would not have been

eligible to obtain UI benefits during this period.

d. As a result of these material misstatements and omissions, between on or

about April 1, 2020 and on or about February 1, 2021, SANTIAGO received UI benefits for which

he was not eligible totaling more than $30,000.

8
Case 3:24-cr-00097-VDO Document 1 Filed 05/01/24 Page 9 of 10

Execution of the Scheme and Artifice

23. On or about the dates listed below, in the District of Connecticut and elsewhere, for

the purpose of executing and attempting to execute the aforementioned scheme and artifice to

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

representations, and promises, including by omissions of material fact, as described above,

SANTIAGO knowingly transmitted and caused to be transmitted, by means of wire

communication in interstate commerce, the following writings, signs, signals, pictures, and sounds,

each of which is a separate count of the Indictment:

Count Date Benefit DescriQtion

ONE December 29, RSDI Direct deposit of $1,620.00 RSDI payment from the
2023 United States Department of the Treasury to
SANTIAGO's Achieve Financial Credit Union
account ending -7029 .
TWO March 1, 2024 SNAP Electronic transmission of EBT purchase of $26.84 at
Walmart in Hartford, Connecticut to Conduent, Inc.' s
servers in Utah.
THREE February 1, 2021 UI Electronic transmission of payment file from CT-DOL
to JP Morgan Chase containing information for
payment of $848.00.

All in violation of Title 18, United States Code, Section 1343.

FORFEITURE ALLEGATION

24. Upon conviction of one or more of the wire fraud offenses alleged in Counts One

through Three of this Indictment, the defendant RICARDO SANTIAGO, shall forfeit to the United

States of America, pursuant to Title 18, United States Code, Section 981(a)(l)(C) and Title 28,

United States Code, Section 2461 (c), all right, title, and interest in any and all prope1iy, real or

personal, which constitutes or is derived from proceeds traceable to violations of Title 18, United

States Code, Section 1343, and a sum of money equal to the amount of proceeds obtained as a

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Case 3:24-cr-00097-VDO Document 1 Filed 05/01/24 Page 10 of 10

result of the offense.

25. If any of the above-described forfeitable property, as a result of any act or omission

of the defendant, cannot be located upon the exercise of due diligence, has been transferred, sold

to, or deposited with a third party, has been placed beyond the jurisdiction of the court, has been

substantially diminished in value, or has been commingled with other property which cannot be

divided without difficulty, it is the intent of the United States, pursuant to Title 21, United States

Code, Section 853(p), as incorporated by Title 28, United States Code, Section 2461(c), to seek

forfeiture of any other property of said defendant up to the value of the forfeitable property

described above.

All in accordance with Title 18, United States Code, Section 981 (a)(l ); Title 21, United

States Code, Section 853; Title 28, United States Code, Section 2461(c); and Rule 32.2(a) of the

Federal Rules of Criminal Procedure.

A TRUE BILL

/s/

UNITED STATES OF AMERICA

VANESSA ROBERTS AVERY
UNITED STATES ATTORNEY

NAT ONT
ASSI TATES ATTORNEY

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