Information — United States v. Tyrese Carter, District of Maryland (Document 1)

Summary

A criminal information filed by the United States Attorney for the District of Maryland against Tyrese Carter, Case 1:21-cr-00204-ELH, filed June 9, 2021 as Document 1; Count One charges wire fraud under 18 U.S.C. § 1343. It alleges that Carter, a FEMA Emergency Management Specialist detailed to an SBA virtual call center, took a call from Victim A, a Colorado business owner who was concerned that she may have mistakenly been granted two EIDL advances, then posed as a fictitious SBA supervisor. It states Carter emailed instructions to return $8,738.00 to a PayPal account he had created, and that Victim A's assistant sent that amount on May 5, 2020. The information alleges Carter later moved the funds to his own accounts and withdrew $6,600 cash on October 20, 2020. It is signed by Acting United States Attorney Jonathan F. Lenzner.

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Case 1:21-cr-00204-ELH Document1 Filed 06/09/21 Page 1 of 6 bisrricy COURT

DISTRICT OF MARYLAND
June 09, 2021
CLERK’S OFFICE
SRD/ASJZ USAO 2021R00331 AT BALTIMORE

BY KN, DEPUTY CLERK
IN THE DISTRICT COURT OF THE UNITED STATES —_

FOR THE DISTRICT OF MARYLAND

UNITED STATES OF AMERICA Criminal Number: ELH 21-cr-204

y. Wire Fraud, 18 U.S.C. § 1343

TYRESE CARTER

INFORMATION

COUNT ONE

The United States Attorney for the District of Maryland charges that:

INTRODUCTION

At all times relevant to this Information:

1. Defendant TYRESE CARTER (“CARTER”) resided in Baltimore, Maryland.

2. On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security
(“CARES”) Act was enacted to provide emergency financial assistance to the millions of
Americans suffering from the economic consequences of COVID-19. The Paycheck Protection
Program (“PPP”), established by the CARES Act, is implemented by the Small Business
Administration (“SBA”) with support from the Department of the Treasury. This program
provides small businesses with funds to pay up to eight weeks of payroll costs including benefits.
Funds can also be used to pay interest on mortgages, rent, and utilities. The SBA’s Economic
Injury Disaster Loan (““EIDL”) is available to provide support to small businesses experiencing a

temporary loss of revenue because of the COVID-19 pandemic. EIDL proceeds can be used to
Case 1:21-cr-00204-ELH Document1 Filed 06/09/21 Page 2 of 6

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cover a wide array of working capital and normal operating expenses, such as continuation to
health care benefits, rent, utilities, and fixed debt payments.

3. CARTER was employed by the Federal Emergency Management Agency
(“FEMA”) as an Emergency Management Specialist since at least April 2018. As such,
CARTER was subject to deployment anywhere in the United States in support of FEMA
emergency operations. On April 9, 2020, as part of FEMA’s response to the COVID-19
pandemic, CARTER was detailed to work in an SBA virtual call center. There, CARTER was
assigned to assist potential disaster loan applicants by answering questions about the SBA’s
EIDL program.

4. Victim A, who ran an organic skin care and event center business in Colorado,
applied for both a PPP loan and an EDIL. On April 4, 2020, Victim A submitted an online EIDL
application, and requested an advance of $9,000. Subsequently, Victim A became concerned that
her application did not go through successfully and, on April 13, 2020, filled out a second EIDL
application. Unbeknownst to Victim A, this second EIDL application was rejected as a duplicate
application.

5. Meanwhile, at the request of Victim A, another bank submitted a PPP application
on Victim A’s behalf. On April 28, 2020, the SBA approved the PPP loan and, on April 30,
2020, Victim A received the proceeds of this loan into her bank account. The next day, Victim A
received the proceeds from her original EIDL application into her bank account.

6. Victim A was concerned that she may have mistakenly been granted two EIDL
advances as a result of her filing two online EIDL applications. On or about May 4, 2020, Victim
A called the SBA’s helpline to report what Victim A believed may have been an excess payment.

Victim A spoke to CARTER. Victim A told CARTER that she may have been overpaid by the
Case 1:21-cr-00204-ELH Document1 Filed 06/09/21 Page 3 of 6

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SBA and she wanted to know the procedure for returning the excess funds. CARTER stated he

was not sure how Victim A could return the funds and that a supervisor would call Victim A
with further instructions.

7. Approximately thirty minutes thereafter, CARTER telephoned Victim A from a
blocked telephone number and falsely identified himself as SBA supervisor Michael Valdes, a
fictitious individual. CARTER told Victim A that he would send an email to Victim A providing
directions on how to return the excess funds. That same day, CARTER created an email account

in the name of “‘valdesmichael.sbafinancial@gmail.com.”

8. On or about May 5, 2020, at 7:56 AM, CARTER sent an email to Victim A from
valdesmichael.sbafinancial@gmail.com with the subject “SBA FINANCIAL.” The email

contained logos appearing to be those of the United States Department of the Treasury and the

SBA:

B

The email contained the following text:

Hello [Victim A], I am reaching out to inform you of the process to reverse the EIDL CASH
TREASURY, please complete the follow [sic] directions below, in (1) week this email will
expire on May 12th 2020. -1961
Case 1:21-cr-00204-ELH Document1 Filed 06/09/21 Page 4of6

PayPal charges 2.9% of any Transaction fee also a 0.30 cent fee for each transaction
2.9% of 9,000.000USD is 261.00USD

The amount you should return is 8,738.00USD

PayPal account

https://www.paypal.me/sbafinancial

9. Based on the above email, Victim A directed her assistant to send $8,738.00 to
PayPal account https://www.paypal.me/sbafinancial (“SBA Financial PayPal Account’) from
Victim A’s bank account. An interstate wire in this amount was sent on May 5, 2020.

10. CARTER created the SBA Financial PayPal Account on May 4, 2020 and closed
it on May 20, 2020.

11. Victim A reported the suspected fraud to PayPal and KeyBank. KeyBank
reimbursed Victim A for the loss related to the fraud and was not reimbursed for these funds. On
or about May 8, 2020, Victim A reported the suspected fraud to the SBA.

12. On May 19, 2020, CARTER transferred $8,738.00 from the SBA Financial
PayPal Account to his Navy Federal Credit Union (NFCU) bank account. This transfer was
initially held up by NFCU. As Victim A was working with KeyBank to cancel the $8,738.00
transaction, Victim A received another telephone call from CARTER, who identified himself as
Valdes. On the call, he asked Victim A to provide an update about the PayPal transfer.

13. In addition, CARTER called Victim A identifying himself as SBA employee
Nathaniel Williams. He asked Victim A who else Victim A talked to so Victim A’s file could be
closed. CARTER then emailed Victim A on May 20, 2020 from email address

nathanielwilliams.sba@gmail.com, and stated the following:

Hello [Victim A],
Case 1:21-cr-00204-ELH Document1 Filed 06/09/21 Page 5 of6

after [sic] looking into your info I suggest you try to reapply because I can not locate
your application number. Do you mind sending me those names so I can close this part
of your case Thanks [sic]

Phone: (202)656-3958
Fax:(202)565-3958

14. On October 19, 2020, NFCU returned $8,738 to PayPal, which deposited the
funds into a second PayPal account belonging to CARTER because the SBA Financial PayPal
Account had been closed. CARTER then transferred $8,728 to an M&T Bank account. On
October 20, 2020, CARTER withdrew $6,600 cash from M&T from the counter followed by
another $1,000 from an ATM.

WIRE FRAUD

15. The factual allegations contained in Paragraphs | through 14 in this Information
are incorporated and re-alleged as it set forth herein. Between in or about April 2020 and in or
about October 2020, in the District of Maryland and elsewhere, the defendant, TYRESE
CARTER, devised and intended to devise a scheme and artifice to defraud Victim A of proceeds
of CARES Act emergency financial assistance, and to obtain money and property by means of
materially false and fraudulent pretenses, representations, and promises. For the purpose of
executing the scheme and artifice to defraud, and attempting to do so, CARTER caused to be
transmitted by means of wire communication in interstate and foreign commerce signals and
sounds, namely an email dated May 5, 2020 sent by CARTER in Maryland to Victim A in
Colorado in which CARTER provided wiring instructions for the funds he fraudulently sought
to obtain from Victim A.

18 U.S.C. § 1343.
Case 1:21-cr-00204-ELH Document1 Filed 06/09/21 Page 6 of 6

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Date. °/ 19/21 /s/ Jonathan F. Lenzner /SRD

Jonathan F. Lenzner
Acting United States Attorney


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