Indictment — United States v. Sanda G. Frimpong, Eastern District of North Carolina (Document 1)

Summary

A grand jury Indictment in United States v. Sanda G. Frimpong, Case 5:23-cr-00035-D-RN, in the United States District Court for the Eastern District of North Carolina, filed February 7, 2023. It alleges that Frimpong, described as an active-duty E-4/Specialist in the U.S. Army stationed at Fort Bragg, used his bank accounts to receive and move money from romance and gold scams run with co-conspirators, including cashier's checks of $50,000 and $100,000 later wired to the Republic of Ghana. A second part describes an unemployment assistance scheme involving Pandemic Unemployment Assistance under the CARES Act administered by California's EDD. The forfeiture section seeks at least $365,662.00 for the money laundering counts, Counts One through Three, and at least $154,335.00 in gross proceeds for Counts Four through Nineteen. The filing is a redacted version.

Summary drafted by a model from the text of the original file linked on this page and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“Indictment — United States v. Sanda G. Frimpong, Eastern District of North Carolina (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-5-23-cr-00035-dkt-1-e-d-n-c-d535199de7/, SHA-256 e35016ceea55a2ffe54f1d3fc16f048029127c93f05022cd3843dade562350b1.

Full text

FILED IN OPEN COURT
ON 1- IJI 1-0i~l(3
Peter A. Moore, Jr., Clerk
US District Court
DGB Eastern District of NC

UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA
WESTERN DIVISION

UNITED STATES OF AMERICA )
)
V. )
)
SANDA G. FRIMPONG ) INDICTMENT
)

The grand jury charges that:

INTRODUCTORY ALLEGATIONS

1. At all relevant times, Defendant SANDA G. FRIMPONG

("FRIMPONG") was an active-duty E-4/Specialist in the U.S. Army and maintained

a Secret security clearance. FRIMPONG entered the U.S. from the Republic of Ghana

in 2015 on a Kl Fiance Visa. In December 2015, FRIMPONG married the Kl sponsor

and the two later divorced in March 20 18. FRIMPONG naturalized as a U.S. citizen

in November 2018. At all relevant times, FRIMPONG was stationed at Fort Bragg

and resided in Harnett County, both locations being within in the Eastern District of

North Carolina.

I. The Money Laundering Scheme and Artifice to Defraud

2. Beginning no later than on or about December 2019 and continuing until

m or about February 2022, both dates being approximate and inclusive, in the

Eastern District of North Carolina and elsewhere, t he Defendant, SANDA G.

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 1 of 29
FRIMPONG, G.F., F.A., and B.S., along with others known and unknown to the grand

jury, engaged in a series of schemes and artifices to defraud to obtain money and

property by means of false and fraudulent pretenses, representations, and promises

through the u se of interstate wire communications and interstate mail. To execute

the fraud, conspirators impersonated romantic love interests, diplomats, customs

personnel, military personnel, and assumed other fictitious personas. As set forth in

greater detail below, SANDA G. FRIMPONG knowingly utilized his personal bank

accounts to receive or send money obtained via a variety of frauds , such as the false

promise of a romantic relationship and/or gold.

3. It was the object of the conspiracy that FRIMPONG and his co-

conspirators conducted romance scams targeting victims in the United States and

elsewhere for the purpose of enriching themselves and each other with the unlawful

proceeds of such scams. It was further part of the conspiracy and scheme to defraud

that FRIMPONG and his co-conspirators used false stories and promises to convince

the victims to transfer money on their behalf.

4. FRIMPONG and others used a variety of fraudulent scenarios to

ensnare victims by earning their confidence, including promises of romance, sharing

an inheritance or other riches, or other scenarios intended to fraudulently induce the

victims to provide money or property to the conspirators. FRIMPONG and others

assumed false identities to communicate with victims online.

5. Having established relationships with the victims, the conspirators

ultimately requested money for variou s untrue purposes, including travel expenses

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 2 of 29
and customs fees for gold. The conspirators directed the victims to wire transfer or

deposit money into various accounts, including accounts establish ed and maintained

by FRIMPONG. Often, after the victims transferred money into the specified

accounts, conspirators claimed more money was needed for various purposes.

6. It was further part of the conspiracy and scheme to defraud that

FRIMPONG and his co-conspirators used drop accounts to receive, transfer, and

otherwise convert fraudulently obtained funds from victims. It was further part of

the conspiracy a nd scheme to defraud that FRIMPONG and his co-conspirators

caused the victims to use the wires to transfer money to the drop accounts.

Thereafter, the fraudulently obtained funds were disbursed by using wires to transfer

money to other accounts, by initiating account transfers to other accounts at the same

bank, by withdrawing sums of money, and by transferring funds to other individuals

and entities .

7. It was further part of the conspiracy that FRIMPONG maintained

numerous bank accounts and mobile payment services. The victims of these frauds,

following the directions of known and unknown conspirators, mailed, wired, or

deposited money into those accounts identified below and maintained by

FRIMPONG. Upon receipt of the money, FRIMPONG typically utilized some of the

proceeds for his own benefit, and transferred some of the proceeds to other accounts

in the United States or overseas. At no time did FRIMPONG utilize the transferred

funds for the purposes communicated to the victims .

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 3 of 29
Financial Institution Account No. Registered
(Last Four) Account Holder
Navy Federal Credit Union *****3467 Sanda G. Frimpong
Navy Federal Credit Union *****9937 Sanda G. Frimpong
JPMorgan Chase *****0680 Sanda G. Frimpong
BB&T *****8845 Sanda G. Frimpong
TD Bank *****5836 Sanda G. Frimoong
Wells Fargo *****6517 Sanda G. Frimpong
Bank of America *****6024 Sanda G. Frimpong

The above banks and credit unions are insured by the Federal Deposit Insurance

Corporation (FDIC) and otherwise meet the definition of a financial institution under

United States Code, Chapter 18, Section 20.

8. Funds in the accounts were rapidly transferred to co-conspirators, other

individuals known to law enforcement or between accounts maintained by

FRIMPONG. These transfers served no apparent valid legal business purpose.

FRIMPONG retained a portion of the funds.

9. FRIMPONG regularly communicated with other members of the

conspiracy using WhatsApp Messenger ("WhatsApp"). WhatsApp is a free, cross-

platform communication application available for Apple, Android, and Windows

cellular telephones, as well as Mac and Windows PC computers. WhatsApp enables

users to communicate securely over the Internet with end-to-end encryption using a

variety of formats, including video, voice calls, and SMS (text) messaging. WhatsApp

is owned by Meta Platforms, which houses WhatsApp's servers outside of North

Carolina. The conspirators also communicated using SnapChat, an instant

messagmg application whose principal feature is that pictures and messages are

usually only available for a short time before they become inaccessible to their

recipients.

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 4 of 29
A. Representative Money Laundering Example #1

10. In one example, K.W., a widower, residing in North Rose, NY, was

contacted in or around October 2020, by an online alias self-identified as "Catherine

White." K.W. engaged in a virtual relationship with "Catherine White" with the

intent of meeting her in person in the future.

11. After communicating back-and-forth for approximately one month,

"Catherine White" claimed to need money to pay a holding fee to release gold that

was held in Canada and inherited by Catherine White's deceased father. White

further claimed to h ave been detained by a Canadian customs officer named Sanda

Frimpong and requested that K.W. wire money to Frimpong's JPMorgan Chase bank

account ending in -0680 to pay duties on the gold "White" was attempting to bring

into Canada. To further perpetuate the scheme, "Catherine White" sent K.W.

photographs of the purported gold bars, a photograph of a woman in handcuffs, and

a counterfeit Canada Border Services Agency document. "Catherine White"

communicated with KW. by text message and using the email address,

comfortwhite10@gmail.com. Google, LLC houses its servers outside of North

Carolina.

12. K.W. wired $6,500 (in two transactions of $6,100 and $400 each) on or

about November 3, 2020 to FRIMPONG's aforementioned JPMorgan Chase account

ending in -0680. FRIMPONG then transferred $6,000 of that money using the money

transfer service known as "Zelle" into his Navy Federal Credit Union (NFCU) account

ending in -3467 in three transactions of $2,000: one each occurring on or about

November 3, 2020; on or about November 4, 2020; and on or about November 5, 2020.

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 5 of 29
On or about December 28, 2020, K.W. wired $900 to FRIMPONG's aforementioned

JPMorgan Chase account ending in -0680. On or about the same day, FRIMPONG

then wired $982 .87 from his aforementioned JPMorgan Chase account ending in -

0680 in transactions of $100 and $882.87, using, respectively, the money transfer

services known as "Western Union" and "Moneygram."

B. Representative Money Laundering Example #2

13. In another example, A.H., a resident of Lakewood, IL, met an individual

in early 2021 with the online alias "Tom Tanner" on an online dating website. A.H.

had recently divorced after 25 years of marriage. "Tom Tanner" purported to be from

Illinois but deployed with the Army in Afghanistan. "Tom Tanner" asked A.H. to

marry him, while delaying an in-person meeting.

14. After gaining their trust, "Tom Tanner" claimed he had access to gold

and diamonds but needed A.H.'s financial assistance to transfer the assets.

"Tom Tanner" communicated with A.H. usmg the email address,

tomtanner022@gmail.com or through Google Hangouts. Google LLC houses its

servers outside of North Carolina.

15. On or about September 8, 2021, A.H. received an email from an

individual claiming to be Tanner's attorney, "Shawn Martins.'' "Shawn Martins"

communicated with A.H. using the email address, advocacylawoffice66@mail.com.

16. "Shawn Martins" told A.H. that he recently spoke to Tanner, and

suggested the transaction could be easily accomplished by sending a cashier's check

to Sanda Frimpong. "Shawn Martins" provided a Spring Lake, NC address, which

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 6 of 29
was associated with FRIMPONG's co-conspirator, B.S . The aliases "Shawn Martin"

and "Tom Tanner" regularly communicated with A.H. through interstate email

communications.

17. A.H. obliged and mailed a $50,000 cashier's check to "Tom Tanner" via

UPS next-day air to the Spring Lake address. On or about September 9, 2021 ,

FRIMPONG messaged with F.A. acknowledging delivery of the check at the Spring

Lake, NC address.

18. On or about September 9, 2021, "Shawn Martins" emailed A.H.

confirming receipt of the cashier's check, but noting the name on the check was

spelled "Sandra" and thus needed to be corrected. "Shawn Martins" attached a photo

of the check that was also exchanged between FRIMPONG and F.A., who was

communicating with FRIMPONG from the Republic of Ghana.

19. On or about September 10, 2021 , the cashier's check was deposited into

FRIMPONG's NFCU account ending in -9937. On or about September 13, 2021,

FRIMPONG wired $50,000 from his NFCU account ending in -9937 to Freddie Frim

Motors located outside of the United States in the Republic of Ghana.

20. On or about September 20, 2021, "Shawn Martins" sent A.H. an email

stating that it was going to cost $36,000 to change the ownership documents. On or

about September 23, 2021, A.H. responded with concern stating she needed to talk to

their financial advisor because there has been a lot of fraud related to military

personnel.

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 7 of 29
21. On or about November 10, 2021 , "Tom Tanner" emailed A.H. two

fraudulent documents relative to reassignment of 100 kilograms of gold bars and

diamonds from Tanner to A.H.

22. On or about December 16, 2021, "Shawn Martins" and "Tom Tanner"

emailed A.H. listing FRIMPONG and B.S.' Spring Lake, NC address. Martins

reminded A.H. to make sure the name was spelled Sanda not Sandra.

23. On or about December 17, 2021, A.H. sent an email to Martins

indicating a cashier's check was on its way to FRIMPONG. FRIMPONG exchanged

messages with F.A. acknowledging receipt of the check, made out for $100,000. On

or about December 20, 2021, the check was deposited into FRIMPONG's NFCU

account ending in -9937.

24. On or about December 21 , 2021 , FRIMPONG wired $100,000 in two

separate transactions of $50,000 each from his NFCU account ending in -9937 to

Freddie Frim Motors and to S.F. (FRIMPONG's sister), both outside of the United

States in the Republic of Ghana.

25. A.H. sent FRIMPONG additional funds around late January 2022 that

were deposited into FRIMPONG's NFCU account ending in -9937 in early February

2022. FRIMPONG repeatedly exchanged messages with F.A. acknowledging the

additional funds.

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 8 of 29
II. The Unemployment Assistance Scheme

A. Regulatory and Program Background

26. Since 1935, The U .S. Department of Labor's Unemployment Insurance

(UI) program has provided unemployment benefits to eligible workers who become

unemployed through no fault of their own. This program ensures that at least a

significant portion of the necessities of life -- most notably food, shelter, and clothing

-- are met on a weekly basis while the worker seeks employment. UI beneficiaries

who meet the requirements of the applicable state law are eligible for this temporary

financial assistance. Each state administers a separate UI program within the

guidelines established by Federal law. For example, in the State of California, the

Employment Development Department (EDD) administers the UI program for

residents and others physically performing work activities in California.

27. Generally, regular UI claimants must be: 1) unemployed through no

fault of their own; 2) able and available for work; 3) willing to accept suitable work;

and 4) actively seeking work.

28. In Response to the COVID-19 pandemic, Congress passed the

Coronavirus Aid, Relief, and Economic Security Act ("CARES Act"), which the

President signed into law on March 27, 2020. The CARES Act provided over $2

trillion in economic relief protections to the American people from the public health

and economic impacts of COVID-19.

29. Prior to the enactment of the CARES Act, to be eligible for UI

administered by EDD, a person must have been employed and worked in California

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 9 of 29
and received at least a certain amount of wages from an employer in the 18 months

preceding his/her UI benefits claim. Because of this requirement, self-employed

workers, independent contractors, and employees with insufficient earnings were not

eligible to receive regular UI benefits. The CARES Act established a new program --

Pandemic Unemployment Assistance (PUA). Under PUA, states are permitted to

provide PUA to individuals who are self-employed, seeking part-time employment, or

otherwise would not qualify for regular UI compensation.

30. Under the PUA provisions of the CARES Act, a person who was a

business owner, self-employed worker, independent contractor, or gig worker could

qualify for PUA benefits administered by EDD if he/she previously performed such

work in California and was unemployed, partially unemployed, unable to work, or

unavailable to work due to a COVID-19-related reason.

31. EDD began accepting applications for PUA benefits on April 28, 2020.

To make benefits available as quickly as possible, payments were issued in phases.

If a claimant qualified for PUA benefits, the minimum payments depended on the

claim's start date.

32. A UI claimant could usually collect 26 weeks ofregular state UI benefits.

The CARES Act also established the Pandemic Emergency Unemployment

Compensation ("PEUC") program, which provided up to 13 weeks of additional

payments, for a total of 39 weeks of benefits. PEUC was available to persons who

were or are fully or partially unemployed at any time between from March 29 and

December 26, 2020. Persons with a regular UI claim, a PUA claim or a PEUC

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 10 of 29
extension filed between March 29 and July 25, 2020, also received Federal Pandemic

Unemployment Compensation ("FPUC"), which was an extra $600 per week.

33. Persons applying for PUA benefits did not need to submit any

supporting documents to the EDD with their applications. Claimants entered their

total income for the 2019 calendar year on the applications.

34. Like regular UI claims, PUA claims could be filed online . When an

individual filed a PUA claim online, EDD automatically maintained certain

information regarding the filing of the claim. This information included the date and

time the claim was submitted, the name of the person for whom the claim was filed,

and the IP address of the computer, or ISP account, that was used to file the claim.

35. A PUA claimant must answer various questions to establish his/her

eligibility for PUA benefits. The claimant must provide his/her name, Social Security

Number, and mailing address. The claimant must also identify a qualifying

occupational status and COVID-19-related reason for being out of work.

36. After it accepts a UI claim, including a claim submitted pursuant to the

PUA program, EDD typically deposited UI funds every two weeks to an electronic

benefits debit card administered by a federally insured financial institution, which

the claimant could use to pay for their expenses. The electronic benefits debit card

was sent via the U.S. Postal Service to the claimant at the address the claimant

provided in their UI claim. Claimants could activate their debit card over the phone

or online.

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 11 of 29
37. When receiving UI benefits, including PUA benefits, a claimant must

have completed a Continued Claim Form (DE 4581) and certify every two weeks,

under penalty of perjury, that he/she remained unemployed and eligible to receive UI

benefits. EDD authorized and deposited payment to the electronic benefits debit card

after it received the Continued Claim Form.

B. The Scheme and Artifice to Defraud

38. Beginning as early as April 2020, the Defendant, FRIMPONG, together

with B.S. , and others known and unknown to the grand jury, engaged in a scheme to

defraud the United States Government by submitting false and fraudulent

applications for CARES Act financial assistance relief in the form of unemployment

insurance benefits.

39. FRIMPONG coordinated with B.S. and others in the Republic of Ghana,

to use stolen identities to apply online for federal CARES Act funds and

unemployment benefits from several states, including California as well as Arizona,

Georgia, Illinois, Kansas, Louisiana, Maine, Massachusetts, New Mexico, North

Carolina, Texas, and others. Many state agencies tasked with administering

unemployment assistance disburse benefits through the issuance of physical debit

cards, which were sent to the physical mailing address provided with the application.

The cards were issued by financial institutions insured by the Federal Deposit

Insurance Corporation (FDIC) and mailed by the United States Postal Service.

40. FRIMPONG or others acting on his behalf would complete fraudulent

applications online through the state agencies administering UI benefits, and input

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 12 of 29
a physical address, purportedly associated with the beneficiary. After the state

administering the UI benefits mailed the debit card to that address, FRIMPONG or

another member of the conspiracy, would physically retrieve the debit cards from the

address. FRIMPONG often used B.S.'s address of 604 Eva Circle in Spring Lake, NC,

which is located in the Eastern District of North Carolina.

41. C.M. lived in Gilroy, CA. C.M. never met FRIMPONG or applied for UI.

FRIMPONG or others acting on his behalf used C.M.'s name, date of birth, and/or

social security number without C.M.'s knowledge or permission to complete an online

application for UI through the California EDD. Debit cards issued by Bank of

America in C.M.'s name were mailed to 7271 Katella Ave., SPC 2 in Stanton,

California, 90680. FRIMPONG or other members of the conspiracy acting on his

behalf physically retrieved the debit cards, and transferred the funds into

FRIMPONG'S JP Morgan Chase bank account ending in -0680 through interstate

wire.

42. C.S. lived in Cypress, CA. C.S. never met FRIMPONG or applied for UI.

FRIMPONG or others acting on his behalf used C.S.'s name, date of birth, and/or

social security number without C.S.'s knowledge or permission to complete an online

application for UI through the California EDD. Debit cards issued by Bank of

America in C.S.'s name were mailed to 11901 176th St., Apt. 152 in Artesia,

California, 90701. FRIMPONG or other members of the conspiracy acting on his

behalf physically retrieved the debit cards, and transferred the funds into

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 13 of 29
FRIMPONG'S JP Morgan Chase bank account ending in -0680 through interstate

wire.

43. J.G., who died in February 2022, lived in Dale City, VA. FRIMPONG or

others acting on his behalf used J.G.'s name, date of birth, and/or social security

number without J.G.'s knowledge or permission to complete an online application for

UI through the California EDD. Debit cards issued by Bank of America in J.G.'s

name were mailed to 7271 Katella Ave., SPC 2 in Stanton, California, 90680.

FRIMPONG or other members of the conspiracy acting on his behalf physically

retrieved the debit cards, and transferred the funds into FRIMPONG'S JP Morgan

Chase bank account ending in -0680 through interstate wire.

44. In each instance, FRIMPONG or others acting on his behalf would

transfer the funds from the debit cards into his J.P. Morgan Chase (JPMC) bank

account ending in -0680.

COUNT ONE
Money Laundering and Aiding & Abetting
18 U.S.C. §§ 1956(a)(l)(B) and 2

45. Paragraphs 2 through 25 are re-alleged as factual allegations and

incorporated by reference as if fully set forth herein.

46. Beginning no later than on or about December 2019, and continuing

until at least on or about February 2022, both dates being approximate and inclusive,

in the Eastern District of North Carolina and elsewhere, the Defendant, SANDA G.

FRIMPONG, aiding and abetting others, known and unknown to the grand jury, did

knowingly engage and attempt to engage, in financial transactions affecting

interstate and foreign commerce; through a financial institution; knowing the

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 14 of 29
property and funds involved in the transactions to be derived from unlawful activity;

such proceeds having been derived from specified unlawful activities, that is Wire

Fraud, in violation of Title 18, United States Code, Section 1343 and Mail Fraud in

violation of Title 18, United States Code, Section 1341; and knowing that the

transactions were designed in whole or in part to conceal and disguise the nature, the

location, the source, the ownership, or the control of the proceeds of Wire Fraud and

Mail Fraud.

All in violation of 18 U.S.C. § 1956(a)(l)(B).

COUNT TWO
Money Laundering and Aiding & Abetting
18 U.S.C. §§ 1956(a)(2)(B) and 2

4 7. Paragraphs 2 through 25 are re-alleged as factual allegations and

incorporated by reference as if fully set forth herein.

48. Beginning no later than on or about December 2019, and continuing

until at least on or about February 2022, both dates being approximate and inclusive,

in the Eastern District of North Carolina and elsewhere, the defendant, SANDA G.

FRIMPONG, aiding and abetting others, known and unknown to the grand jury, did

knowingly transfer and attempt to transfer monetary instruments and funds from

inside the United States to or through a place outside of the United States, the

Republic of Ghana; knowing that the monetary instruments and funds involved in

the transfer represented the proceeds of some form of unlawful activity and knowing

that such transfer was designed in whole or in part to conceal and disguise the nature,

location, the source, the ownership, and the control of the proceeds of unlawful

activity; such proceeds having been derived from various unlawful activities that

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 15 of 29
constituted offenses against the United States, violations of North Carolina criminal

law, and violations of other state and federal laws, including, but not limited to Wire

Fraud, in violation of Title 18, United States Code, Section 1343; Mail Fraud in

violation of Title 18, United States Code, Section 1341; and Obtaining Property by

False Pretense in violation of North Carolina General Statutes, Section 14-100.

All in violation of 18 U.S.C. § 1956(a)(2)(B).

COUNT THREE
Conspiracy to Conimit Money Laundering
18 U.S.C. § 1956(h)

49. Paragraphs 2 through 25 are re-alleged as factual allegations and

incorporated by reference as if fully set forth herein.

50. Beginning no later than on or about December 2019, and continuing

until at least on or about February 2022, both dates being approximate and inclusive,

in the Eastern District of North Carolina and elsewhere, the Defendant, SANDA G.

FRIMPONG and others, known and unknown to the grand jury, did knowingly

combine, conspire, confederate, agree, and have a tacit understanding with each other

to commit offenses against the United States, in violation of Title 18, United States

Code, Sections 1956(a)(l) and 1956(a)(2); specifically, to

a. knowingly engage and attempt to engage, in monetary transactions

affecting interstate and foreign commerce; through a financial

institution; knowing that the property and funds involved in the

transactions to be derived from unlawful activity; such proceeds having

been derived from specified unlawful activities, that is Wire Fraud, in

violation of Title 18, United States Code, Section 1343 and Mail Fraud

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 16 of 29
in violation of Title 18, United States Code, Section 1341 ; and knowing

that the transactions were designed in whole or in part to conceal and

disguise the nature, the location, the source, the ownership, or the

control of the proceeds of Wire Fraud and Mail Fraud; and

b. knowingly transfer and attempt to transfer funds from inside the United

States to or through a place outside of the United States, the Republic

of Ghana; knowing that the funds involved in the transfer represented

the proceeds of some form of unlawful activity and knowing that such

transfer was designed in whole or in part to conceal and disguise the

nature, location, the source, the ownership, and the control of the

proceeds of unlawful activity; such proceeds having been derived from

various unlawful activities including but not limited to Wire Fraud, in

violation of Title 18, United States Code, Section 1343, Mail Fraud in

violation of Title 18, United States Code, Section 1341, and Obtaining

Property by False Pretense in violation of North Carolina General

Statutes, Section 14-100.

All in violation of 18 U.S.C. § 1956(h).

COUNTS FOUR THROUGH TEN
Wire Fraud & Aiding and Abetting
18 U.S.C. §§ 1343 and 2

51. Paragraphs 26 through 37 are re-alleged as factual allegations and

incorporated by reference as if fully set forth h erein.

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 17 of 29
The Scheme to Defraud

52. From approximately April of 2020 through approximately February of

2022, within the Eastern District of North Carolina and elsewhere, the Defendant,

SANDA G. FRIMPONG, aiding and abetting others, knowingly devised and intended

to device a scheme and artifice to defraud the State of California's unemployment

assistance program, including the extended benefits made available during the

COVID-19 pandemic; the United States; JP Morgan Chase, N.A.; Bank of America,

N.A.; and the victims identified herein; and to obtain money and property by means

of materially false and fraudulent representations and promises.

Manner and Means

53. The Defendant, SANDA G. FRIMPONG, carried out the scheme and

artifice to defraud in the manner and means set forth in paragraphs 38 through 44.

Use of the Wires

54. On or about each of the dates set forth below in the Eastern District of

North Carolina and elsewhere, Defendant, SANDA G. FRIMPONG, for the purpose

of executing and attempting to execute the scheme and artifice to defraud described

above, caused to be transmitted by means of wire communication in interstate

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 18 of 29
commerce the signals and sounds described below for each count, each transmission

constituting a separate count:

Count Date Description

4 9/10/2020 Bank of America fund transfer of $5,000 in the name of
C.M. to JPMC account ending in -0680

5 9/17/2020 Bank of America fund transfer of $5,000 in the name of
C.M. to JPMC account ending in -0680

6 10/06/2020 Bank of America fund transfer of $1,200 in the name of
C.M. to JPMC account ending in -0680

7 9/14/2020 Bank of America fund transfer of $5,000 in the name of
C.S. to JPMC account ending in -0680

8 10/13/2020 Bank of America fund transfer of $1,036 in the name of
C.S. to JPMC account ending in -0680

9 10/16/2020 Bank of America fund transfer of $5,000 in the name of
J.G. to JPMC account ending in -0680

10 10/30/2020 Bank of America fund transfer of $5,000 in the name of
J.G. to JPMC account ending in -0680

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

COUNTS ELEVEN TO THIRTEEN
Mail Fraud & Aiding and Abetting
18 U.S.C. §§ 1341 and 2

55. Paragraphs 26 through 37 are re-alleged as factual allegations and

incorporated by reference as if fully set forth herein.

The Scheme to Defraud

56. From approximately April of 2020 through approximately February of

2022, in the Eastern District of North Carolina and elsewhere, the Defendant,

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 19 of 29
SANDA G. FRIMPONG, aiding and abetting others, with the intent to defraud,

devised and willfully participated in, and attempted to do so, with knowledge of its

fraudulent nature, the above-described scheme and artifice to defraud, and obtain

money and property by materially false and fraudulent pretenses, representations,

and promises.

Manner and Means

57. The Defendant, SANDA G. FRIMPONG, carried out the scheme and

artifice to defraud in the manner and means set forth in paragraphs 38 through 44.

Use of the Mail

58. From approximately April of 2020 through approximately February of

2022, in the Eastern District of North Carolina and elsewhere, the Defendant,

SANDA G. FRIMPONG, aiding and abetting others, for the purpose of executing and

attempting to execute the above-described scheme and artifice to defraud and

deprive, knowingly caused to be delivered by mail or private and commercial

interstate carrier, according to the direction thereon at the place at which it was

directed to be delivered by the person to whom it was addressed the following matter:

Count Approximate Date Mailing

11 August - September 2020 Debit card account number ending in -0258
in the name of C.M. mailed to:
7271 Katella Ave., SPC 2
Stanton, California, 90680

12 August - September 2020 Debit card account number ending in -5454
in the name of C.S. mailed to:

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 20 of 29
11901 176th St., Apt. 152
Artesia, CA 90701

13 August - September 2020 Debit card account number ending in -6155
in the name of J.G. mailed to:
7271 Katella Ave. , SPC 2
Stanton, California, 90680

Each of the above-referenced entries constituting a separate violation of Title

18, United States Code, Sections 1341 and 2.

COUNT FOURTEEN
Conspiracy to Commit Wire Fraud and Mail Fraud
18 U.S.C. §§ 1341, 1343 and 1349

59. Paragraphs 26 through 37 are re-alleged as factual allegations and

incorporated by reference as if fully set forth herein.

60. From approximately April of 2020 through approximately February of

2022, in the Eastern District of North Carolina and elsewhere, the Defendant SANDA

G. FRIMPONG, G.F., B.S. and others-known and unknown to the grand jury-did

knowingly combine, conspire, confederate, agree , and have a tacit understanding

with each other to commit offenses against the United States, to wit, Wire Fraud in

violation of Title 18, United States Code, Section 1343; and Mail Fraud in violation

of Title 18, United States Code, Section 1341.

Objects of the Conspiracy

61. Wire Fraud: It was a part and an object of the conspiracy that

FRIMPONG and others, known and unknown to the grand jury, having devised the

above-described schemes and artifices to defraud, and knowingly executed and

attempted to execute the schemes and artifices to defraud, and to obtain money and

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 21 of 29
property by means of materially false and fraudulent pretenses, representations and

promises, and attempting to do so, would and did transmit and cause to be

transmitted by means of wire communication in interstate commerce, any writing,

sign, signal, picture, and sound for purposes of executing said schemes and artifices

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

62. Mail Fraud: It was a part and an object of the conspiracy that

FRIMPONG and others, known and unknown to the grand jury, having devised the

above-described schemes and artifices to defraud, and knowingly executed and

attempted to execute the schemes and artifices to defraud, and to obtain money and

property by means of materially false and fraudulent pretenses, representations and

promises, and attempting to do so, did knowingly caused to be delivered by mail or

private and commercial interstate carrier, according to the direction thereon at the

place at which it was directed to be delivered by the person to whom it was addressed

any matter or thing whatever to be sent or delivered by the Postal Service or private

and commercial interstate carrier.

Manner and Means

63. FRIMPONG and others, known and unknown to the grand jury, carried

out the conspiracy in the manner and means as set forth in paragraphs 38 through

44.

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

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 22 of 29
COUNTS FIFTEEN TO SEVENTEEN
Aggravated Identity Theft
18 US.C. § 1028A(a)(l)

64. Paragraphs 26 through 44 are re-alleged as factual allegations and

incorporated by reference as if fully set forth herein.

65. From approximately April of 2020 through approximately February of

2022, in the Eastern District of North Carolina and elsewhere, the Defendant,

SANDA G. FRIMPONG, did knowingly transfer, possess, and use, without lawful

authority, a means of identification of another person, to wit-the name, date of birth,

and/or social security number of said other person-during and in relation to the

crimes set forth in the corresponding count of this Indictment identified in the table

below, which are felony violations enumerated in Title 18, United States Code,

Section 1028A(c), knowing that the means of identification belonged to another actual

person.

Count Victim Initials Corresponding Counts Predicate Offenses

15 C.M. 4, 5, 6, 11 Wire Fraud (18 U.S.C. § 1343)
Mail Fraud (18 U.S.C. § 1341)

16 C.S. 7, 8, 12 Wire Fraud (18 U.S.C. § 1343)
Mail Fraud (18 U.S.C. § 1341)

17 J.G. 9, 10, 13 Wire Fraud (18 U.S.C. § 1343)
Mail Fraud (18 U.S.C. § 1341)

All in violation of Title 18, United States Code, Section 1028A(a)(l).

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 23 of 29
COUNT EIGHTEEN
Access Device Fraud
18 U.S.C. § 1029(a)(3)

66. From on or about January 1, 2022 through on or about February 28,

2022, in the Eastern District of North Carolina and elsewhere, the Defendant,

SANDA G. FRIMPONG, did knowingly and with intent to defraud possess fifteen or

more devices, identified below-by associated financial institution, account number,

and purported account holder-which were counterfeit and unauthorized access

devices as defined in subsection (e)(2) and (e)(3) of Title 18, United States Code,

Section 1029, to wit, banking and credit card account numbers that can be used, alone

or with other access devices, to obtain money, goods, services, or any other thing of

value, or that can be used to initiate a transfer of funds, such access devices being

lost, stolen, cancelled, and obtained with intent to defraud. This possession in the

aggregate substantially affected interstate commerce because the access devices were

instrumentalities of interstate commerce; because numerous purported account-

holders were domiciled outside of North Carolina; and because the associated

financial institutions were headquartered outside of North Carolina.

Access Institution Last Four Digits of Victim
Device No. Account Number

#1 BanCorp -2442 D.T.

#2 BanCorp -2252 P.P.

#3 BanCorp -7960 P.P.

#4 Lincoln Savings Bank -4462 L.S.

#5 Lincoln Savings Bank -4158 R.F.

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 24 of 29
#6 Lincoln Savings Bank -6510 A.C.

#7 Lincoln Savings Bank -6077 J.D.

#8 Lincoln Savings Bank -1980 A.B.

#9 Lincoln Savings Bank -4797 D.W.

#10 Lincoln Savings Bank -9959 S.H.

#11 Lincoln Savings Bank -3628 D.S.

#12 CashApp -9157 S.H.

#13 Fidelity Investments -7158 L.S.

#14 Fidelity Investments -7363 A.L.

#15 Fidelity Investments -9070 A.C.

#16 Key Bank -3598 J.L.

#17 U.S. Bank -1430 A.B.

All in violation of Title 18, United States Code, Section 1029(a)(3).

COUNT NINETEEN
Access Device Fraud
U.S.C. § 1029(a)(5)

67. Paragraphs 26 through 44 are re-alleged as factual allegations and

incorporated by reference as if fully set forth herein.

68. From on or about September 1, 2020 through on or about October 31,

2020, in the Eastern District of North Carolina and elsewhere, the Defendant,

SANDA G. FRIMPONG, did knowingly and with intent to defraud effect transactions

with one or more unauthorized access devices-debit cards issued by Bank of

America, N.A. for fraudulently obtained UI benefits-issued to other persons (C.M.,

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 25 of 29
C.S., and J.G.) to receive United States Currency in excess of $1,000 during the

calendar year of 2020, which did not exceed one year. The access devices were

counterfeit and unauthorized access devices as defined in subsection (e)(2) and (e)(3)

of Title 18, United States Code, Section 2019, to wit, banking and credit card account

numbers that can be used, alone or with other access devices, to obtain money, goods,

services, or any other thing of value, or that can be used to initiate a transfer of funds,

such access devices being lost, stolen, cancelled, and obtained with intent to defraud.

This conduct substantially affected interstate commerce because the access devices

were instrumentalities of interstate commerce; because the associated electronic

transactions involved the transmission of wire communication in interstate

commerce through FIDC-insured financial institutions like Bank of America, N.A.

and JPMorgan Chase, N.A.; because the debit cards were mailed through the United

States Postal Service; and because the victims and the accounts were domiciled in

California or Virginia.

All in violation of Title 18, United States Code, Section 1029(a)(5).

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 26 of 29
FORFEITURE NOTICE

Notice is hereby given that all right, title and interest in the property described

herein is subject to forfeiture.

Upon conviction of any offense charged herein constituting "specified unlawful

activity" (as defined in 18 U.S.C. §§ 1956(c)(7) and 1961(1)), or a conspiracy to commit

such offense, the defendant shall forfeit to the United States, pursuant to 18 U.S.C.

§ 981(a)(l)(C), as made applicable by 28 U.S.C. § 2461(c), a ny property, real or

personal, which constitutes or is derived from proceeds traceable to the said offense.

Upon conviction of any violation of 18 U.S.C. §§ 1956, 1957 or 1960 charged

herein, the defendant shall forfeit to the United States, pursuant to 18 U.S.C.

§ 982(a)(l), any property, real or personal, involved in such offense, or any property

traceable to such property.

Upon conviction of any violation of, or conspiracy to violate, Section 1029 of

Title 18 of the United States Code, the defendant shall forfeit to the United States,

pursuant to 18 U.S.C. § 982(a)(2)(B), any property constituting, or derived from,

proceeds obtained directly or indirectly as a result of the said violation, or, pursuant

to 18 U.S.C. § 1029(c)(l)(C), any personal property used or intended to be used to

commit the said offense.

The forfeitable property includes, but is not limited to, the following:

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 27 of 29
Forfeiture Money Judgment:

a) A sum of money representing the value of the property involved in the money

laundering offense(s) charged herein in Counts One through Three, in the

amount of at least $365,662.00.

b) A sum of money representing the gross proceeds of the offense(s) charged

herein in Counts Four through Nineteen, in the amount of at least $154,335.00.

Personal Property:

c) Approximately $47,590.35 m Funds seized from PNC Smart Access Card

Account No. XXXXXXXXXXXX:3560, issued in the name of B.S.

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

omission of a defendant: cannot be located upon the exercise of due diligence; has

been transferred or 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),

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 28 of 29
to seek forfeiture of any other property of said defendant up to the value of the

forfeitable property described above.

ATR_DE BILL

F6REPERSON

Date: J ~ ~ t)~

MICHAEL F. EASLEY, JR.
Unite_:S~a!~ ~ __

~#~
DAVID G. BERAKA
Assistant United States Attorney
Criminal Division

Case 5:23-cr-00035-D-RN Document 1 Filed 02/07/23 Page 29 of 29

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