Indictment — United States v. Prince Vamboi, Eastern District of Missouri (Doc. 2)
Summary
A grand jury indictment in United States v. Prince Vamboi, No. 4:21-cr-00323, in the U.S. District Court for the Eastern District of Missouri, filed May 19, 2021 as Doc. 2. Counts 1-3 charge conspiracy to commit wire fraud under 18 U.S.C. §1349, alleging that a co-conspirator posing as a member of the Safety Management Group induced Verona Safety Supply, Inc. to pay $159,000.00 for N-95 masks that were never shipped. Count 4 charges bank fraud under 18 U.S.C. §1344, alleging that Vamboi opened bank accounts under false identities with a counterfeit United States visa and deposited a counterfeit check for $35,098.66 on or about June 24, 2019. A further count charges misuse of a visa under 18 U.S.C. §1546(a). The 8-page indictment seeks forfeiture, and its signature block names United States Attorney Sayler A. Fleming.
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“Indictment — United States v. Prince Vamboi, Eastern District of Missouri (Doc. 2).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-4-21-cr-00323-dkt-2-e-d-mo-903e29242c/
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Case: 4:21-cr-00323-RLW Doc. #: 2 Filed: 05/19/21 Page: 1 of 8 PageID #: 11
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M~Y 19 2021
J .:s. b1sm1cT COURT
EASTERN DISTRICT OF MO
11 ST. LOUIS 1
UNITED STATES DISTRICT COURT I ,
EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
UNITED STATES OF AMERICA, ) I
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Plaintiff, ) i
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V. ) 4:21CR00323 lRW/SRW
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) No.
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PRINCE VAMBOI, )
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Defendant. )
INDICTMENT
The Grand Jury charges:
COUNTS 1-3
Conspiracy to Commit Wire Fraud 18 U.S.C. §1349
A. Introduction
At all times relevant to this indictment:
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1. Verona Safety Supply, Inc., located in Madison, Wisconsin, was a saf~ty
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supply
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company.
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2. Verona Safety Supply, Inc. was part of the Safety Management Group (SMG),
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a group
of business owners and business purchasers who meet and discuss supply and cost~ of safety
merchandise. '.
3. Between late March 2020, and early April 2020, Verona Safety Supply ~ecided to
make a large purchase ofN-95 masks to sell to customers.
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B. · The Conspiracy to Defraud II
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4. Beginning on or about April 1, 2020, and continuing until on or about Apii~ 30, 2020,
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in the Eastern District of Missouri, PRINCE VAMBOI, the defendant herein, :and other
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conspirators, both known and unknown to the Grand Jury, did knowingly and willfully qombine,
conspir.e, confederate and agree with each other and others known and unknown to the Qrand Jury,
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to commit the following offense against the United States:
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a. To devise and intend to devise a scheme to defraud, and to obtain ~oney and
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property: by means of materially false and fraudulent pretenses, representations, and proµiises, and
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for the purpose of executing the scheme described above, and attempting to do so, to cause to be
transmitted by means of wir~, communication in interstate commerce signals and' ~ounds, m
violation of Title 18, United States Code, Section 1343.
5. It was part of the conspiracy to execute a scheme and artifice to defraud that:
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a. On or about April 15, 2020, and April 21, 2020, a co-conspirator unknuwn to the
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Grand Jury falsely posed as a known member of SMG and contacted employees of Veroria Safety
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Supply via email and telephone, respectively. The co-conspirator indicated that he or s~e ,knew of
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a company that would sell a large quantity ofN-95 masks to Verona Safety Supply for,d fair price.
b. On or about October 21, 2019, in the Eastern District of Missouri,; defendant
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PRlNCE VAMBOI ("Defendant") opened the US Bank account number 152320965p75 in the
name of PJ Logistics, using the alias "Patrick L. Jones."
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c. On or about April 15, 2020, a co-conspirator unknown to the Grand Jtjry sent an
email instructing an employee of Verona Safety Supply to wire payment(s) to the PJ Lo~istics US
Bank account number 152320965675 in St. Louis, Missouri, in order to secure the N-95 masks.
d. As further alleged below, between on or about April 7, 2020, and April 20, 2020,
acting on the instructions of Defendant's co-conspirator, Verona Safety Supply made;payments
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totaling $159,000.00, believing that the payments were being made to secure shipments ofN-95
masks.
e. Defendant and his co-conspirators never shipped any N-95 masks ~o Verona
Safety Supply.
C. The Wire Transmission
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The allegations contained in paragraphs 1-5 are hereby realleged and incorporateq. by
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reference herein:
COUNTS 1-3
6. On or about the dates listed below, in the Eastern District of Missouri, the defendant,
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: PRINCE VAMBOI,
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for the purpose of executing the above-described scheme to defraud, did knowingly c;iuse to be
transmitted, by means of wire communication in and affecting interstate commer~e; certain
writings, signs, signals, pictures, and sounds, that being, wire funds transfers and an: electronic
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funds transfer in the amounts listed below, from Oak Bank in Fitchburg, Wisconsin, t~ US Bank
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in St. Louis, Missouri:
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Count Date Transfer Type Amount
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1 April 7, 2020 Electronic Funds Transfer $15,900:~0.
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2 April 17, 2020 Wire Transfer $63,600:00
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3 April 20, 2020 Wire Transfer $79,500.©0
All in violation of Title 18, United States Code, Section 1349.
COUNT4
Bank Fraud 18 U.S.C. §1344
A. Introduction
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7. At all times relevant to the Indictment, the financial institutions listed inithe tables
below, in Paragraphs 14 and 15, were all financial institutions within the meaning of 1~ U.S.C. §
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20 and were insured through the Federal Deposit Insurance Corporation.
8. At all times relevant to the Indictment, defendant PRINCE VAMBOI was·a citizen of
Sierra Leone and was a resident of St. Louis in the Eastern District of Missouri.
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9. At no time relevant to the Indictment has Defendant lawfully been issued aj legitimate
South African passport.
B. The Scheme to Defraud
10. Beginning on or about October 1, 2019, in the Eastern District of Mi~souri, the
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defendant, PRINCE V AMBOI, aided and abetted by individuals known and unknown to the Grand
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Jury, devised.a scheme and artifice to obtain moneys, funds, and assets owned by an:d under the
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custody and control of federally insured financial institutions by means of false and: fraudulent
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pretenses and representations.
C. Manner and Means
~The Scheme and artifice to defraud was in substance as follows:
1I. . Beginning in 2019, Defendant began opening bank accounts with fraudu~ent, false
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identities in order to facilitate his roles as a money courier for individuals engage1 in fraud
schemes.
12. It was further part of the scheme and artifice to defraud that the proceeds deposited by
Defendant included those obtained from multiple different fraud schemes, including: (a) check
counterfeiting, whereby Defendant deposited a check stolen from the United States, Mails and
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. subsequently counterfeited; (b) the proceeds of the wire fraud scheme alleged in Co~ts 1-3; (c)
fraudulently obtained unemployment insurance benefits.
13. It was further part of the scheme to defraud that once Defendant received the proceeds
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of vario·us fraud schemes, he subsequently transferred those funds to confederates or withdrew the
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proceeds in cash. I
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14. It was further part of the scheme to defraud that on or about the dates listecl below,
Defendant opened various bank accounts, enumerated below, under the name of Denni~ K. King,
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d.b.a. DK King Enterprise, using a counterfeit United States Visa:
Date , ... Bank Account Number 'I
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January 3, 2019 USBank 152320155137 ,I
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January 24, 2019 Commerce Bank 131090477
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January 31, 2019 Bank of America 3540 1247 9456
February 8, 2019 Wells Fargo Bank 2390817548
February 8, 2019 SunTrust Bank · 1000246885023
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15. It was further part of the scheme to defraud that on or about the dates li~ted below,
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Defendant opened various bank accounts, enumerated below, under the name of Patliick Jones,
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d.b.a. PJ Logistics or MaxGen Media Service, using a counterfeit United States Visa:
Date Bank Account Nuniber
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October 21, 2019 USBank 152320965675 I
January 8, 2020 Great Southern Bank 5570810146
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March 6, 2020 Citizens National Bank 945437201
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16. On or about June 24, 2019, in the Eastern District of Missouri, the defenda~t, ·
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PRINCE VAMBOI,
aided and abetted by persons known and unknown to the Grand Jury, did knowingl~ e~ecute a
scheme and artifice to obtain the money, funds, or other property owned by or under, the control
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of Wells Fargo by means of material false or fraudulent pretenses, representations or Ho±nises, in
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that PRINCE VAMBOI did deposit a counterfeit check that had been fraudulentl~ altered to
reflect D .K. Kmg Enterprise as the payee, drafted in the amount of $35,098.66, and 4l";"1 on the
Wells Fargo bank account of "F.C.," into his Commerce Bank account, knowing thal ID'.K. King
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Enterprise was not a legitimate recipient of those funds aiid had no authorized or legal :iJ~ose for
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accepting funds drawn on the account ofF.C., all without the knowledge or consent of p.C.
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In violation of Title 18, United States Code, Sections 1344.
COUNTS
Misuse of Visa 18 U.S.C. §1546(a)
On or about January 24, 2019, in the Eastern District of Missouri, the defendant, :
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PRINCE V AMBOI,
did knowingly use an immigrant visa, in the name Dennis Kenzo King, which the Defendant knew
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to be forged, counterfeited, altered, and falsely made, in that the Defendant presented the I
counterfeit United States Visa to Commerce Bank as identification in order to open an ~ccount.
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In violation of Title 18, United States Code, Section 1546(a).
FORFEITURE ALLEGATION
The Grand Jury further finds by probable cause that:
1. Pursuant to Title 18, United States Code, Sections 98l(a)(l)(C) and Title '.28, United
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States Code, Section 2461, upon conviction of an offense in violation of Title 18, United States
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Code, Section 1349 or 1344 as set forth in Counts 1 through 4, the defendant shall forfeit to the
United States of America any property, real or personal, which constitutes or is defived from
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proceeds traceable to said violation. !
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2. Subject to forfeiture is a sum of money equal to the total value of any pr6p~rty, real
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or personal, constituting or derived from any proceeds traceable to said offenses. I 1
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3. If any of the property described above, as a result of any act or omission of the
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 of the court;
d. has been substantially diminished in value; or
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e. has been commingled with other property which cannot be divided without
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difficulty,
the United States of America will be entitled to the forfeiture of substitute property :gursuant to
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Title 21, United States Code, Section 853(p).
A TRUE BILL.
FOREPERSON
SAYLER A. FLEMING,
United States Attorney
DIANE E.H. KLOCKE, #61670MO
Special Assistant United States Attorney
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