Indictment — United States v. Eric Upchurch, Western District of Wisconsin

Summary

An indictment filed July 19, 2023 as Document 1 in United States v. Eric Upchurch, Case 3:23-cr-00069-wmc, in the U.S. District Court for the Western District of Wisconsin, citing 18 U.S.C. § 1343 and 18 U.S.C. § 1957(a). The grand jury charges that from about April 2020 to about April 2021 the defendant submitted PPP loan applications for entities including Opportunity, Inc., the Madison Alliance for Black Economic Empowerment and a sole proprietorship, with false payroll figures and fake tax documents, although the IRS had no records of wages paid. It states Summit Credit Union deposited $135,000 for Opportunity, Inc. on May 7, 2020 after an application claiming twelve employees, and that other loans came from Kabbage, Itria Ventures and Cross River Bank. A money laundering count concerns $20,000 wired to Coinbase to buy Bitcoin, and forfeiture of $406,211 is sought.

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IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF WISCONSIN

v. Case No.__23-cr-69-wme |
18 U.S.C. § 1343 .
ERIC UPCHURCH, 18 U.S.C. § 1957(a) .
Defendant.
THE GRAND JURY CHARGES:
Background

At times material to this indictment:

The Small Business Administration

1. The Small Business Administration (SBA) was an executive branch agency
of the United States government that provided support to entrepreneurs and small
businesses. The mission of the SBA was to maintain and strengthen the nation’s
economy by enabling the establishment and viability of small businesses, as well as
assisting in the economic recovery of communities after disasters.

2. As part of this effort, the SBA provided for loans through banks, credit
unions, and other lenders. These loans had government-backed guarantees.

Paycheck Protection Program

3. The Coronavirus Aid, Relief, and Economic Security (CARES) Act was a
federal law enacted in March 2020 and designed to provide emergency financial
assistance to Americans suffering from the economic effects caused by the COVID-19

pandemic. One source of relief provided by the CARES Act was the authorization of
Case: 3:23-cr-00069-wmc Document#:1 _ Filed: 07/19/23 Page 2 of 17

forgivable loans to small businesses for job retention and other authorized expenses
through a program referred to as the Paycheck Protection Program (PPP).

4. To obtain a PPP loan, a qualifying business was required to submit a PPP
loan application signed by an authorized representative of the business. The PPP loan
application required the business, through its authorized representative, to
acknowledge the program rules and make affirmative certifications in order to be
eligible to obtain the PPP loan. In the PPP loan application, the small business, through
its authorized representative, was required to state and certify among other things, its
(1) average monthly payroll expenses, and (2) number of employees. These figures
were used to calculate the amount of money the small business was eligible to receive
under the PPP. In addition, businesses applying for a PPP loan were required to
provide documentation, such as IRS tax returns and payroll reports, to verify their
payroll expenses. Entities were also required to have been in operation on February 15,
2020, and either had employees for whom they paid salaries and payroll taxes or paid
independent contractors, or they were an eligible self-employed individual,
independent contractor, or sole proprietorship with no employees.

5. A PPP loan application was processed by a participating lending
institution. If a PPP loan application was approved, the lender funded the PPP loan
using its own monies, which were guaranteed by the SBA. This initial loan
disbursement was referred to as a First Draw.

6. PPP loan proceeds were required to be used on certain permissible

expenses, including payroll costs, mortgage interest, rent, and utilities. Under the
Case: 3:23-cr-00069-wmc Document#:1 _ Filed: 07/19/23 Page 3of17

applicable PPP rules and guidance, the interest and principal on the PPP loan was
eligible for forgiveness if the business spent the loan proceeds on these expense items
within a designated period of time and used a certain portion of the loan towards
payroll expenses.

7. PPP allowed certain borrowers that previously received a PPP loan to
apply for a Second Draw PPP loan with the same general loan terms as their First
Draw. Second Draw PPP loans could also be used for job retention and other
authorized expenses. A borrower was eligible for a Second Draw PPP loan if the
borrower (1) previously received a First Draw PPP loan and used the full amount only
for authorized expenditures, (2) had no more than 300 employees, and (3) could.
demonstrate at least a 25% reduction in gross receipts between comparable quarters in

2019 and 2020.

Opportunity, Inc.

8. According to the Wisconsin Department of Financial Institutions (DF),
ERIC UPCHURCH registered Opportunity, Inc. as a domestic business on July 26, 2016.
DF] identified ERIC UPCHURCH as Opportunity Inc.’s registered agent.

9. ERIC UPCHURCH opened bank accounts for Opportunity, Inc. at Summit
Credit Union on January 20, 2017. ERIC UPCHURCH listed himself as the only
authorized signer on the account.

10. | Documents submitted to the Internal Revenue Service (IRS) showed that

Opportunity, Inc. owned the following subsidiaries: (1) Economic Empowerment, Inc.;
Case: 3:23-cr-00069-wmc Document#:1 _ Filed: 07/19/23 Page 4of17

(2) One Red Feather; (3) Madison Alliance for Black Economic Empowerment (MABEE),
and (4) Young Gifted and Black, LLC (YGB, LLC).

11. In 2018, Opportunity, Inc. reported grant income of $17,181 on the
corporate tax return that ERIC UPCHURCH filed with the IRS.

12. In 2019, ERIC UPCHURCH requested an extension to file his personal and
business tax returns.

13. The IRS had no records that Opportunity, Inc. paid wages to any

employees in 2018 or 2019.

Economic Empowerment Wisconsin

14. DFlI had no documents for Economic Empowerment Wisconsin.

15. The IRS had no tax records that showed Economic Empowerment
Wisconsin made a profit or paid employees in 2018 or 2019.

16. | ERIC UPCHURCH and Sharon Johnson opened bank accounts for
Economic Empowerment Wisconsin at Summit Credit Union on November 27, 2020.
ERIC UPCHURCH and Sharon Johnson each owned 50% of the company, and they
listed themselves as the authorized signers on the account.

Economic Empowerment Collaboration, Inc.

17. According to DFI, Economic Empowerment Collaboration, Inc. registered
as a domestic business on June 3, 2020. DFI identified Opportunity, Inc. as Economic
Empowerment Collaboration’s registered agent.

18. The IRS had no tax records that showed Economic Empowerment

Collaboration made a profit or paid employees in 2018 or 2019.
Case: 3:23-cr-00069-wmc Document #:1 Filed: 07/19/23 Page 5 of 17

19. | Economic Empowerment Collaboration used Economic Empowerment
Wisconsin’s bank account at Summit Credit Union for its financial transactions.

Eric Upchurch Sole Proprietorship

20. | ERIC UPCHURCH opened a personal savings and checking account at
Summit Credit Union on April 5, 2016. ERIC UPCHURCH listed himself as the only
authorized signer on the account.

21. In 2018, ERIC UPCHURCH filed a 2018 Schedule C-EZ tax form that
reported a sole proprietorship called Movement Fund made a net profit of $8,727.
UPCHURCH listed no other sole proprietorships on his tax forms.

One Red Feather

22. One Red Feather used ERIC UPCHURCH'’s personal bank account for its
financial transactions.

23. The IRS had no tax records that showed One Red Feather reported a profit
or paid employees in 2018 or 2019.

Madison Alliance for Black Economic Empowerment, Inc.

24. MABEE registered as a domestic business with DFI on May 12, 2017. DFI
identified ERIC UPCHURCH as MABEF's registered agent.

25. ERIC UPCHURCH opened a business savings and checking account for
MABEE at Summit Credit Union on July 1, 2017. ERIC UPCHURCH listed himself as
the only authorized signer on the account.

26. In2018, MABEE reported grant income of $38,194 on Opportunity, Inc.’s

tax return that ERIC UPCHURCH filed with the IRS.
Case: 3:23-cr-00069-wmc Document#:1 _ Filed: 07/19/23 Page 6 of 17

27. The IRS had no tax records that showed MABEE paid a salary to any

employees during 2018 or 2019.

Young Gifted and Black Coalition, Inc.

28. YGBC registered as a domestic business with DFI on May 15, 2015. DFI
identified B.G. as YGBC’s registered agent.

29. | ERIC UPCHURCH opened a business savings and checking account for
YGBC on January 20, 2017. ERIC UPCHURCH listed himself as the only authorized
signer on the account.

30. The IRS had no tax records that specifically showed YGBC made a profit
or paid employees in 2018 or 2019.

31. | YGBC shared an Employee Identification Number with YGB, LLC.

Young Gifted and Black, LLC

32. YGB, LLC registered as a domestic business with DFI on January 20, 2017.
DFI identified ERIC UPCHURCH as YGB, LLC’s registered agent.

33, YGB, LLC used YGBC’s bank account for its financial transactions.

34, In 2018, YGB, LLC reported grant income of $4,563 on Opportunity, Inc.’s
tax return that ERIC UPCHURCH filed with the IRS.

35. The IRS had no tax records that showed YGB, LLC paid any employees in
2018 or 2019.

PPP Loan Applications

36. ERIC UPCHURCH submitted PPP loan applications on behalf of the

following companies: (1) Opportunity, Inc.; (2) Economic Empowerment Wisconsin,
Case: 3:23-cr-00069-wmc Document#:1 Filed: 07/19/23 Page 7 of 17

(3) Economic Empowerment Collaboration; (4) Eric Upchurch Sole Proprietorship; (5)
One Red Feather; (6) MABEE; (7) YGBC; and (8) YGB, LLC.

Scheme to Defraud

37. From in or about April 2020, and continuing to in or about April 2021, in
the Western District of Wisconsin and elsewhere, the defendant,
ERIC UPCHURCH,
knowingly, and with intent to defraud, devised and participated in a scheme to defraud
and to obtain money and property by means of materially false and fraudulent
pretenses, representations, promises, and by concealment of material facts.
Opportunity, Inc.

38. It was part of the scheme to defraud that on or about April 24, 2020, ERIC
UPCHURCH, on behalf of Opportunity, Inc., submitted a PPP loan application to
Summit Credit Union for $135,000.

39. It was further part of the scheme that on the PPP loan application, ERIC
UPCHURCH falsely claimed that Opportunity, Inc. employed twelve people and had

an average monthly payroll expense of $54,000.

40. It was further part of the scheme that, along with the PPP loan application,
ERIC UPCHURCH provided Summit Credit Union with a fake profit and loss
statement that falsely showed Opportunity, Inc. earned revenue of $1,017,875 and

incurred expenses of $778,690.
Case: 3:23-cr-00069-wmc Document#:1 _ Filed: 07/19/23 Page 8 of 17

41. SBA and Summit approved the PPP loan application, and Summit Credit
Union electronically deposited $135,000 into Opportunity Inc.’s business checking
account on May 7, 2020.

Eric Upchurch - Sole Proprietorship (First Draw)

42. It was part of the scheme to defraud that on or about July 27, 2020, ERIC
UPCHURCH, on behalf of a sole proprietorship, submitted a PPP loan application to
Kabbage for $20,833.

43. It was further part of the scheme that ERIC UPCHURCH stated on the
PPP loan application that the sole proprietorship employed one person and falsely
stated that it had an average monthly payroll of $8,334.

44, It was further part of the scheme that ERIC UPCHURCH included a fake
IRS Schedule C with the PPP loan application that falsely reported the sole
proprietorship had a net profit of $152,923 in 2019.

45. SBA and Kabbage approved ERIC UPCHURCH’s sole proprietorship PPP
loan application, and Kabbage deposited $20,833 into ERIC UPCHURCH’s Summit
Credit Union personal bank account on July 29, 2020.

Madison Alliance for Black Economic Empowerment, Inc. (First Draw)

46. It was part of the scheme to defraud that on or about July 30, 2020,
MABEE submitted a PPP loan application to Kabbage for $62,690.

47. It was further part of the scheme that ERIC UPCHURCH reported on the
PPP loan application that MABEE employed one person and falsely stated that it had an

average monthly payroll of $25,076.
Case: 3:23-cr-00069-wmc Document#:1 Filed: 07/19/23 Page 9 of 17

48. It was further part of the scheme that ERIC UPCHURCH included a fake
2019 IRS Form W-3 for MABEE that falsely reported $284,041 in wages, tips, and other
compensation paid to MABEE’s employees.

49, SBA and Kabbage approved MABEE’s PPP loan application, and Kabbage
deposited $62,690 into MABEE’s Summit business bank account on August 3, 2020.

Eric Upchurch - Sole Proprietorship (Second Draw)

50. It was part of the scheme to defraud that on or about February 2, 2021,
ERIC UPCHURCH’s sole proprietorship submitted a Second Draw PPP loan
application to Kabbage for $20,833.

51. It was further part of the scheme that ERIC UPCHURCH reported on the
Second Draw PPP loan application that his sole proprietorship employed one person
and falsely stated that it had an average monthly payroll of $8,334.

52. SBA and Kabbage approved ERIC UPCHURCH’s sole proprietorship
Second Draw PPP loan application, and Kabbage deposited $20,833 into ERIC
UPCHURCH’s Summit Credit Union personal bank account on February 8, 2021.

Economic Empowerment Wisconsin (First Draw)

53, It was part of the scheme to defraud that on or about January 30, 2021,
ERIC UPCHURCH, on behalf of Economic Empowerment Wisconsin, submitted a PPP
loan application to Ttria Ventures (Itria) for $20,833.

54. It was further part of the scheme that ERIC UPCHURCH claimed on the
PPP loan application that Economic Empowerment Wisconsin employed one person

and falsely stated that it had an average monthly payroll of $9,020.
Case: 3:23-cr-00069-wmc Document#:1_ Filed: 07/19/23 Page 10 of 17

55. It was further part of the scheme that ERIC UPCHURCH included a fake
IRS Schedule C with the PPP loan application that falsely reported Economic
Empowerment Wisconsin had a net profit of $111,204 in 2019.

56. SBA and Itria approved Economic Empowerment Wisconsin’s PPP loan
application. Itria deposited $20,833 into Economic Empowerment Wisconsin's bank
account at Summit Credit Union on February 9, 2021.

Young, Gifted and Black Coalition (First Draw)

57. It was part of the scheme to defraud that on or about January 30, 2021,
YGBC submitted a PPP loan application to Itria for $20,833.

58. It was further part of the scheme that ERIC UPCHURCH reported on the
PPP loan application that YGBC employed one person and falsely stated that it had an

average monthly payroll of $9,020.

59. It was further part of the scheme that ERIC UPCHURCH included a fake
IRS Schedule C with the PPP loan application that falsely reported a net profit of

$108,251 in 2019.

60. It was further part of the scheme that SBA and Itria approved YGBC’s PPP
loan application, and Itria deposited $20,833 into YGBC’s Summit Credit Union

business bank account on February 10, 2021.
Madison Alliance for Black Economic Enrpowerment, Inc. (Second Draw)
61. It was further part of the scheme that on or about March 24, 2021, MABEE

submitted a Second Draw PPP loan application to Cross River Bank for $62,690.

10
Case: 3:23-cr-00069-wmc Document#:1 Filed: 07/19/23 Page 11 of 17

62. It was further part of the scheme that ERIC UPCHURCH included a fake
2019 IRS Form 940 for MABEE that falsely reported total payments of $300,912 to all
MABEE employees and $2,520 in total tax liability.

63. It was further part of the scheme that ERIC UPCHURCH submitted a fake
2019 IRS Form W-3 for MABEE with the PPP loan application that falsely reported
$284,041 in wages, tips, and other compensation paid to MABEE’s employees.

64. SBA and Cross River Bank approved MABEE’s Second Draw PPP loan
application, and Cross River Bank deposited $62,690 into MABEE’s Summit Credit
Union business account on March 26, 2021.

65, It was part of the scheme to defraud that on March 26, 2021, ERIC
UPCHURCH transferred $20,000 of the PPP loan proceeds that MABEE received from
Cross River Bank into his personal bank account at Summit Credit Union.

66. It was further part of the scheme that ERIC UPCHURCH wired the
$20,000 of PPP loan proceeds from his personal bank account at Summit Credit Union.

into his account at Coinbase, Inc., which is located in California.

67. It is further part of the scheme that on March 26, 2021, ERIC UPCHURCH
used $19,000 in PPP loan proceeds to purchase approximately 0.34417794 Bitcoin from

Coinbase, Inc.
Young, Gifted and Black, LLC (Second Draw)

68. It was part of the scheme to defraud that on or about March 31, 2021, YGB,

LLC submitted a Second Draw PPP loan application to Cross River Bank for $20,833.

11
69. It was further part of the scheme that ERIC UPCHURCH reported on the
PPP loan application that YGB, LLC employed one person and falsely stated that it had
an average monthly payroll of $8,333.

70. It was further part of the scheme that ERIC UPCHURCH included a fake
IRS Schedule C with the PPP loan application that falsely reported YGBC had a net
profit of $108,251 in 2019.

71. SBA and Cross River Bank approved YGB, LLC’s Second Draw PPP loan
application, and Cross River Bank deposited $20,833 into YGBC’s Summit Credit Union
business bank account on April 6, 2021.

Economic Empowerment Collaboration (Second Draw)

72. It was part of the scheme to defraud that on or about March 31, 2021, ERIC
UPCHURCH, on behalf of Economic Empowerment Collaboration, submitted a Second
Draw PPP loan application to Cross River Bank for $20,833.

73. It was further part of the scheme that ERIC UPCHURCH reported on the
PPP loan application that Economic Empowerment Collaboration did business as
Economic Empowerment Wisconsin. Furthermore, ERIC UPCHURCH claimed that
Economic Empowerment Collaboration employed one person and falsely stated that it
had an average monthly payroll of $8,333.

74, It was further part of the scheme that ERIC UPCHURCH provided a fake
IRS Schedule C with the PPP loan application that falsely reported Economic

Empowerment Wisconsin had a net profit of $111,204 in 2019.

12
Case: 3:23-cr-00069-wmc Document#:1 _ Filed: 07/19/23 Page 13 of 17

75. SBA and Cross River Bank approved Economic Empowerment
Collaboration’s Second Draw PPP loan application. Cross River Bank deposited $20,833
into Economic Empowerment Wisconsin's bank account at Summit Credit Union on
April 16, 2021.

One Red Feather

76. It was part of the scheme to defraud that on or about March 18, 2021, One
Red Feather submitted a PPP loan application to Cross River Bank for $20,833.

77. It was further part of the scheme that ERIC UPCHURCH reported on the
PPP loan application that One Red Feather employed one person and falsely stated that

it had an average monthly payroll of $8,333.

78. It was further part of the scheme that ERIC UPCHURCH included a fake
IRS Schedule C with the PPP loan application that falsely claimed One Red Feather had
a net profit of $123,611 in 2019.

79. SBA and Cross River Bank approved One Red Feather’s PPP loan

application, and Cross River Bank deposited $20,833 into ERIC UPCHURCH’s Summit

Credit Union personal bank account on April 19, 2021.
Total Amount of Fraudulent PPP Loans

80. ERIC UPCHURCH, through his businesses, received a total of $406,211 in

fraudulent PPP loans:

13
- Case: 3:23-cr-00069-wmc

Document #: 1

Filed: 07/19/23

Page 14 of 17

Date of Deposit | PPP Loan Amount Business Bank
5/7/2020 $135,000 ; Summit Credit
Opportunity, Inc. Union
7/29/2020 $20,833 Sole Proprietorship Kabbage
8/3/2020 $62,690 MABEE Kabbage
2/8/2021 $20,833 Sole Proprietorship
(Second Draw) Kabbage
2/9/2021 $20,833 Economic
Empowerment Itria Ventures
Wisconsin
2/10/2021 $20,833 Young, Gifted and . ;
Black Coalition Tria Ventures
3/26/2021 $62,690 MABEE Cross River Bank
(Second Draw)
Young, Gifted and
4/6/2021 $20,833 Black, LLC Cross River Bank
(Second Draw)
4/16/2021 $20,833 Economic
Empowerment Cross River Bank
Collaboration
(Second Draw)
4/19/2021 $20,833 One Red Feather Cross River Bank
Total $406,211

81. | ERIC UPCHURCH transferred PPP proceeds to various bank accounts.

ERIC UPCHURCH then used the PPP proceeds to pay for unauthorized investments

and personal expenses.

82.

COUNTS 1-5

and elsewhere, the defendant,

ERIC UPCHURCH,

14

On or about the dates listed below, in the Western District of Wisconsin
Case: 3:23-cr-00069-wmc

Document #:1 Filed: 07/19/23. Page 15 of17

for the purpose of executing this scheme, knowingly caused to be transmitted by means

of wire communication in interstate commerce, the writings, signals, and pictures,

described below for each count:

Count

Date of Deposit

Nature of Communication

1

2/8/2021

SOLE PROPRIETORSHIP (SECOND DRAW): Synovus
Bank, on behalf of Kabbage, Inc., wired $20,833 in PPP
loan proceeds to ERIC UPCHURCH’s personal bank
account at Summit Credit Union in Madison, Wisconsin.
This caused electronic signals to be sent from Synovus
Bank’s servers in Georgia to Summit Credit Union’s
servers in Wisconsin.

3/26/2021

MABEE (SECOND DRAW): Cross River Bank wired
$62,690 in PPP loan proceeds to YGBC’s bank account at
Summit Credit Union in Wisconsin. This caused
electronic signals to be sent from Cross River Bank’s
servers in New Jersey to Summit Credit Union's servers in
Wisconsin. |

4/6/2021

YOUNG, GIFTED AND BLACK, LLC (SECOND DRAW);
Cross River Bank wired $20,833 in PPP loan proceeds to
YGBC’s bank account at Summit Credit Union in
Wisconsin. This caused electronic signals to be sent from
Cross River Bank’s servers in New Jersey to Summit
Credit Union’s servers in Wisconsin.

4/16/2021

ECONOMIC EMPOWERMENT COLLABORATION
(SECOND DRAW): Cross River Bank wired $20,833 in
PPP loan proceeds to Economic Empowerment
Collaboration’s bank account at Summit Credit Union in
Wisconsin. This caused electronic signals to be sent from
Cross River Bank’s servers in New Jersey to Summit
Credit Union’s servers in Wisconsin.

4/19/2021

ONE RED FEATHER: Cross River Bank wired $20,833 in
PPP loan proceeds to ERIC UPCHURCH’s bank account
at Summit Credit Union in Madison, Wisconsin. This
caused electronic signals to be sent from Cross River
Bank’s servers in New Jersey to Summit Credit Union’s
servers in Wisconsin.

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

15
Case: 3:23-cr-00069-wmc Document#:1 Filed: 07/19/23 Page 16 of 17

COUNT 6

83. | Paragraphs 1 through 82 are incorporated here.

84. On or about the date listed below, in the Western District of Wisconsin
and elsewhere, the defendant,

ERIC UPCHURCH,
knowingly engaged in, and caused to be engaged in, monetary transactions, affecting
interstate and foreign commerce, as described below, in criminally derived property of
value greater than $10,000, such property having been derived from a specified
unlawful activity, that is wire fraud, in violation of 18 U.S.C. § 1343, specifically, ERIC
UPCHURCH wired $20,000 in PPP proceeds from his personal bank account at Summit
Credit Union in Wisconsin to his account at Coinbase, Inc. in California and purchased
Bitcoin valued at $19,000.
(In violation of Title 18, United States Code, Section 1957(a)).

FORFEITURE ALLEGATION

1. As a result of the offenses charged in Counts 1-5 of this indictment, the
defendant, ERIC UPCHURCH, shall forfeit to the United States, pursuant to 18 U.S.C,
§§ 981 (a)(1)(C), 982 and 28 U.S.C. §2461(c), any property constituting or derived from
proceeds obtained directly or indirectly as a result of the said violations. The property
to be forfeited includes, but is not limited to a money judgment, specifically, a sum of
money equal to $406,211 in United States currency, representing the amount of

proceeds obtained as a result of the wire fraud.

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Case: 3:23-cr-00069-wmc Document#:1 Filed: 07/19/23 Page 17 of 17

2. 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,

e. has been commingled with other property which cannot be divided

without difficulty,

the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title 18,

United States Code, Section 982(b)(1) and Title 28, United States Code, Section 2461(c).

A TRUE BILL
PRESIDING JUROR

Indictment returned: 7/ I a/ 2023

nited States Attorney

17


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